Privacy Policy

Interwell Learning


INTERWELL LEARNING PRIVACY POLICY

This Privacy Policy explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information by Interwell Learning. Interwell Learning knows that you care how information about you is used and shared. This Privacy Notice explains what we may do with information that we collect from or about you when you use our website at learning.interwellhealth.com or other affiliated websites or applications that link to or post this Privacy Notice.
In this Privacy Notice, “personal information” means information that may identify you as an individual. Personal Information does not include information that has been “deidentified” in such a way that your identity cannot reasonably be determined.


CONTACTING US

If you have general questions about your account or how to contact customer service for assistance, please contact InterwellLearning@interwellhealth.com. For questions specifically about this Privacy Policy or our use of your personal information, cookies or similar technologies, please contact privacy@interwellhealth.com.
Please note that if you contact us to assist you, for your safety and ours, we may need to authenticate your identity before fulfilling your request.


COLLECTION OF INFORMATION

We receive and store information about you such as your name, employees, email addresses, addresses or postal code, payment method(s), and telephone numbers. We collect this information in a number of ways, including when you enter it while using our service, interact with our customer service or otherwise provide information to us through our service or elsewhere. We also collect certain information automatically regarding you, your use of our service, and your interactions with us. This information includes:

  • your activity using Interwell Learning Streaming;
  • your interactions with our emails and texts, and with our messages through push and online messaging channels;
  • details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
  • device IDs or other unique identifiers;
  • financial information including credit card numbers and payment information,
  • resettable device identifiers (also known as advertising identifiers), such as those on mobile devices, tablets, and streaming media devices that include such identifiers (see the "Cookies and Internet Advertising" section below for more information);
  • device and software characteristics (such as type and configuration), connection information, statistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information; information collected via the use of cookies, web beacons and other technologies. (See our "Cookies and Internet Advertising" section for more details.)



USE OF INFORMATION

We use information to provide, analyze, administer, enhance and personalize our services, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use information to:

  • prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • communicate with you concerning our services so that we can send you news about Interwell Learning, including new content and features. These communications may be conducted by various methods, such as email, push notifications, text messages, online messaging channels, and matched identifier communications such as cookies which are described below. You may opt out of receiving our marketing emails by using the “unsubscribe” link contained in any marketing email that we send;
  • assist you with operational requests with the website, application, or services such as password reset requests;
  • personalize and improve your experience on our website and to allow us to deliver the type of content and product offerings in which you are most interested;
  • process your transactions; and
  • verify your identity.



DISCLOSURE OF INFORMATION

We disclose your information to third parties for certain purposes as described below:

The Interwell Learning company: We share your information at Interwell Learning as needed to store and process data; to provide access to our services and for customer support; to make decisions about service improvements and content development; and for other purposes described in the Use of Information section of this Privacy Policy.

Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you.

Protection of Interwell Learning and others: Interwell Learning and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, (d) protect against harm to the rights, property or safety of Interwell Learning, its users or the public, as required or permitted by law, (e) pursue available remedies or limit damages; and (f) respond to an emergency.

Business transfers: In connection with any reorganization, restructuring, merger or sale, dissolution, or other transfer of assets, whether as an ongoing concern or as part of bankruptcy, liquidation or similar processing in which personal information held by us is among the assets transferred, we will transfer information, including personal information.


ACCESS TO ACCOUNT AND PROFILES

To remove access to your Interwell Learning website account from your devices: (a) choose the “logout” button or (b) delete your Interwell Learning settings from your device (steps vary by device and the option is not available on all devices). Where possible, users of public or shared devices should log out at the completion of each visit.

If you share or otherwise allow others to access your account, they will be able to see your information (including in some cases personal information) such as your watch history and account information (including your email address or other information in the "Account" area of the Interwell Learning website). This remains true even if you use our profiles feature.

Profiles allow users to have a distinct, personalized Interwell Learning experience, built around the Interwell Learning Content, as well as separate watch histories. Please note that profiles are available to everyone who uses your Interwell Learning account, so that anyone with access to your Interwell Learning account can navigate to use, edit and delete profiles. You should explain this to others with access to your account, and if you do not wish them to use or change your profile, be sure to let them know. Profile users may be offered the opportunity to add an email address, phone number or other information to the profile and will be provided with notice of collection and use at the time such information is requested.


YOUR INFORMATION AND RIGHTS

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you by contacting us at InterwellLearning@interwellhealth.com. You may also request that we delete personal information that we hold about you.

To make requests, or if you have any other question regarding our privacy practices, please contactprivacy@interwellhealth.com. We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical and could require disproportionate technical effort. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Policy. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.


SECURITY

We use commercially reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. We take reasonable precautions to help protect the personal information that we collect and store from our websites. However, no system or online transmission of data is completely secure and Interwell Learning cannot guarantee the security of personal information transmitted online. We encourage you to take reasonable precautions to safeguard your personal information.


CHANGES TO THIS PRIVACY POLICY

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with state and federal law. Your continued use of the Interwell Learning Service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Policy, you may cancel your use of the Interwell Learning Service. To see when this Privacy Policy was last updated, please see the "Last Updated" section below.


COOKIES AND INTERNET ADVERTISING

We and our Service Providers use cookies and other technologies such as web beacons and resettable device identifiers for various reasons. For example, we use these technologies to make it easy to access our services by remembering you when you return and to identify usage patterns to improve the functionality of the website. For instance, we use cookies and resettable device identifiers to help us understand your preferences based on previous or current website activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about website traffic and website interaction so that we can offer better website experiences and tools in the future.

We want you to be informed about our use of these technologies, so this section explains the types of technologies we use, what they do and your choices regarding their use.


WHAT ARE COOKIES?

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work, or to work more efficiently, as well as to provide reporting information and to assist with service or advertising personalization.

Cookies are not the only types of technology that enable this functionality; we also use other, similar types of technologies. See below for more information and examples.


WHAT ARE RESETTABLE DEVICE IDENTIFIERS?

Resettable device identifiers (also known as advertising identifiers) are similar to cookies and are found on many mobile devices and tablets (for example, the "Identifier for Advertisers" (or IDFA) on Apple iOS devices and the "Google Advertising ID" on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant.


WHY DOES INTERWELL LEARNING USE COOKIES AND RESETTABLE DEVICE IDENTIFIERS?


Essential cookies: These cookies are strictly necessary to provide the Interwell Learning website. For example, we and our Service Providers may use these cookies to authenticate and identify our members when they use the Interwell Learning websites, Interwell Learning Tablets, and Interwell Learning Streaming so we can provide our services. They also help us to enforce our “Terms of Use,” to prevent fraud and to maintain the security of our service.

Performance and functionality cookies: These cookies are not essential but help us to personalize and enhance your online experience with Interwell Learning. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during member sign up). We also use these cookies to collect information (such as viewing patterns, click-through and other information) about our visitors' use of the Interwell Learning Service so that we can enhance and personalize the Interwell Learning website. Deletion of these types of cookies may result in limited functionality of our service.


HOW CAN I EXERCISE CHOICE REGARDING COOKIES AND RESETTABLE DEVICE IDENTIFIERS?

At this time, we do not respond to Web browser "do not track" signals. You can choose, however, to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Google Chrome or Internet Explorer) settings. Each browser is a little different, so look at your browser “Help” menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that make your website more efficient and some of our services will not function properly.


HOW DOES INTERWELL LEARNING USE WEB BEACONS AND OTHER TECHNOLOGIES?

Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. We and our Service Providers may use them for similar purposes as cookies, such as to understand and enhance the use of our service, improve site performance, and actions on our site. Because web beacons often work in conjunction with cookies, in many cases, declining cookies will impair the effectiveness of web beacons associated with those cookies.

We use other technologies that are similar to cookies, such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL). Like cookies, some of these technologies may store small amounts of data on your device. We may use these and various other technologies for similar purposes as cookies, such as to enforce our terms, prevent fraud, and analyze the use of our service. There are a number of ways to exercise choice regarding these technologies. For example, many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area; see your browser's help function or support area to learn more. Other technologies, such as Silverlight storage, may be cleared from within the application.

We may allow others to provide analytics services on our behalf (such as Google Analytics). For example, we use analytics partners to help us analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests and other websites and better understand your online activity. You can learn more about how Google Analytics uses your data by visiting https://www.google.com/policies/privacy/partners/.

Last Updated: March 29, 2024



LINKS TO OTHER WEBSITES AND APPLICATIONS

We may include links to other websites or applications, such as social media plug-ins. If you visit the link, you may be subject to another party’s privacy practices and policies, which may differ from this Privacy Notice. A link to a third-party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these linked sites (including if a specific link does not work).


RETENTION OF PERSONAL INFORMATION

We will store the personal information you provide for as long as we believe is necessary or appropriate (i) to carry out the purpose(s) for which we collected it, or (ii) to comply with applicable laws, contracts, or other rules or regulations.


USERS OUTSIDE THE UNITED STATES

This website is intended for users located in the United States, and this Website Privacy Notice describes how we use and disclose your personal information pursuant to United States law. We make no representation that this site is appropriate or available for use in locations outside of the United States. The privacy laws of the United States and other countries may be different from those in your country, and you understand that by using this website, your personal information will be processed in the United States or in the countries where our vendors are located.


SPECIAL NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 provides California residents with the right to receive additional information about how certain personal information is collected, used and disclosed. We adopt this notice to comply with the CCPA and to supplement our other practices described in our Privacy Policy. Any terms defined in the CCPA have the same meaning when used in this notice.


Personal Information We Collect

California law defines “personal information” as information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.
We collect different categories of personal information from different individuals, depending on their relationship to Interwell Learning. We may collect this information directly from you or from our websites, mobile applications, service providers or affiliates.
In the preceding 12 months, we have collected the following categories of personal information for our business purposes, including: 

  • Identifiers (e.g. name, mailing address, email address, phone number, credit/debit card number)
  • Personal Information in Consumer Records (e.g. your signature, physical characteristics or description, telephone number, other financial or medical information protected by CCPA)
  • Commercial information (e.g. products or services purchased, purchase history)
  • Internet or other electronic network activity (e.g. browse or search history)
  • Geolocation data (e.g. latitude or longitude)
  • Audio, electronic, visual, or similar information (e.g. recording of calls)
  • Professional or Employment Information (e.g. Information about your professional and employment status)
  • Education Information (e.g. transcripts)
  • Inferences drawn from any of the above (e.g. preferences or characteristics)


For purposes of California law, the definition of personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated information that does not identify an individual
  • Information excluded from CCPA’s scope, such as:
  • Health or medical information that is protected by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), including medical information that we collect from you for treatment or clinical research purposes;
  • Personal information that is protected by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.


Sharing Personal Information

We may disclose the personal information described above to third parties for business or commercial purposes, such as our affiliates, service providers and others who you or your agents authorize to receive your personal information in connection with products or services we provide to you. The recipient is required to maintain the confidentiality of your personal information unless you consent or further disclosure is authorized by law.

De-Identification of Protected Health Information

In certain instances, we collect Protected Heath Information as defined under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). We may de-identify such information in accordance with the HIPAA Safe Harbor method or the HIPAA Expert Determination method described in 45 C.F.R. § 164.514. Once information is deidentified, it is no longer considered personal information under HIPAA.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

This section describes California residents’ rights with respect to personal information protected by the CCPA, as well as how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. We will disclose in response to a verifiable consumer request:

  • The categories and sources for personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
  • Although we do not sell personal information, if we ever do so in the future, we will provide a list of such sales, identifying the personal information categories that each category of recipient purchased.


Deletion Request Rights

You have the right to request that we delete personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.


Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request by e-mailing InterwellLearning@interwellhealth.com

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We aim to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


“Shine the Light Law”

California residents who provide personal information when obtaining products or services for personal, family or household use are entitled to request and obtain information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.