My Welly Privacy Policy

Effective date:  May 21, 2024

Your privacy is very important to us. Before we get to the details, check out our Privacy Label to see a summary of our privacy practices. Click on the links to learn more and read the full policy below.

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Privacy Label

Collection and Sale of Data

Privacy Controls

Tracking

Communication

Privacy Policy

Introduction

Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our websites and the related mobile applications and services (collectively, the “Services”). Please also read our Terms of Service which sets out the terms governing the Services. APP is headquartered in San Francisco, California, USA and our Services are provided to you by app, Inc. This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to our subsidiaries (which have their own privacy policies) or third party products or services, including other companies you might interact with on or through the Services. Questions or comments about this Privacy Policy may be submitted by mail or email using the contact information below or via https://support.app.com.

APP, Inc.
– location mywelly.wellytech.vn

Information My Welly Collects

Welly collects information about you, including information that directly or indirectly identifies you, if you or your other APP users choose to share it with app. We receive information in a few different ways, including when you track, complete or upload activities using the Services. My Welly also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your friends, and your activities with My Welly. For example:

Account, Profile, Activity, and Use Information

We collect basic account information such as your name, email address, date of birth, gender, weight, username and password that helps secure and provide you with access to our Services. We also use dates of birth to enhance safety and privacy for our younger users, to place you on age-group leaderboards, and to provide more accurate performance analysis. Profile, activity and use information is collected about you when you choose to upload a picture, video, post, or activity (including date, time and geo-location information as well as your speed and pace and perceived exertion), join a challenge, add your equipment usage, view others’ activities, or otherwise use the Services. We use your contact information so we can contact you when needed. For example, to respond to your support requests.

Location Information

We collect and process location information when you sign up for and use the Services. We do not track your device location while you are not using the Services. But in order to use our core features (e.g., GPS activity tracking, routes, segment leaderboards, etc.), it is necessary for you to permit us to track your device location while you use the Services. If you would like to stop the device location tracking, you may do so at any time by adjusting your device settings.

Content You Share

We gather information from the photos, videos, posts, comments, kudos, ratings, reviews, and other content you share on the Services, including when you participate in partner events or create segments or routes.

Contacts Information

You can choose to add your contacts’ information by connecting your contacts from your mobile device or social networking accounts to My Welly. If you choose to share your contacts with My Welly, we will, in accordance with your instructions, access and store your contacts’ information in order to identify potential connections and help you connect with them. Learn more about how we collect information about your contacts, how we use that information, and the controls available to you.

Connected Devices and Apps

My Welly collects information from devices and apps you connect to My Welly. For example, you may connect your Garmin watch or Flywheel account to My Welly and information from these devices and apps will be passed along to My Welly.

Health Information

My Welly may collect or infer health information. Certain health information may be inferred from sources such as heart rate or other measurements, including power, cadence, and weight or other indicators. Before you can upload health information to My Welly, you must give your explicit consent to the processing of that health information by My Welly. You can withdraw your consent to My Welly processing your health information at any time. You can also hide certain statistics, such as your heart rate, from being viewed by others on individual activities.

Payment Information

When you make a payment on My Welly, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry (PCI) compliant third-party payment services and we do not store your credit card information.

Third-Party Accounts

My Welly allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Meta, Google, or Apple (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences. This information is collected by the Third-Party Account providers and is provided to My Welly under their privacy policies. You can generally control the information that we receive from these sources using the privacy controls in your Third-Party Account.

Technical Information and Log Files

We collect information from your browser, computer, or mobile device, which provides us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information. Learn more about how we use cookies and manage your preferences by visiting our Cookie Policy. The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track user movement in the aggregate, and gather broad demographic information (e.g., country residence) for aggregate use. IP addresses may be linked to session IDs, athlete IDs and device identifiers.

Other Information

We may collect information directly from you or through our service providers, such as when we collect your feedback through surveys. We may also collect information about you from other My Welly users such as when they give you kudos or comment on your activities.

How My Welly Uses Information

My Welly uses the information we collect and receive as described below.

To provide the Services

We use the information we collect and receive to provide the Services, including providing you with the ability to: 
  • Record your activities and analyze your performance. For example, to compare your past efforts, analyze your training, and – with your consent – use your heart rate information to provide you with interesting and useful performance analysis. We may also match your GPS activities to specific segments or routes to analyze your efforts against those of other users and to establish leaderboards.
  • Interact with other users. For example, to compete on segments, participate in clubs, challenges, or events, follow other users, message other users, and use features that help users interact with one another, such as group activities or flyby.
  • Manage your training. For example, to set goals and use your training dashboard.
  • Explore new places to go. For example, to discover routes or segments where you can engage in your activity. Similarly, if several users run a specific route, that information may be used to suggest the route to other users.
  • Visualize your activities in new ways. For example, by creating personal heatmaps or using your training log.
  • Share insights with My Welly
  • community. For example, by sharing your public reviews and photos of specific routes or segments. We may also analyze your public photos from specific routes or segments to attach characteristics to those routes or segments (e.g., shaded, waterfalls, flowers, etc.)

Subject to your privacy controls, your information, including parts of your profile, username, photos/videos, users you follow and who follow you, clubs you belong to on My Welly, your activities, the devices you use, and kudos and comments you give and receive will be shared on My Welly so that you may be able to participate in the Services, for example to show your place on a leaderboard. Certain information (e.g., your name, and some profile information) is also available to non-users on the web. Your precise location information, such as where you run or ride, may also be shared on My Welly or to non-users, in accordance with your privacy controls.

To provide the messaging Services

We use the information we collect and receive (including your name, avatar, athlete ID, and content you choose to share) in connection with your use of My Welly Messaging on the basis of our legitimate interest in enabling you to find new ways to interact by using the Services. When you use Messaging, we use your information (i) to provide you with the My Welly Messaging service, (ii) to improve My Welly Messaging, for example to increase the functionality of Messaging by analyzing usage data to identify technical and design improvements and by assessing feedback you provide in relation to Messaging, and (iii) to protect you and other users of the Messaging service and the Services, for example by enforcing our Terms of ServiceAcceptable Use Policy and Community Standards. We use automated tools to assist us in protecting and safeguarding you and other users and to keep the Messaging service secure, for example to detect misuse and bad actors. To help us provideMy Welly Messaging, we share your information with a third party service provider that specializes in messaging services and keeping these safe and secure.

To customize your experience

We use the information we collect and receive to customize your experience. For example, we may suggest segments, routes, challenges, or clubs on My Welly that may interest you, users that you may want to follow, or new features that you may want to try. For example, if we know that you like to hike, we may tell you about new hiking routes or show you sponsored content related to hiking. Or if we see that you bike ride in a certain area, we may suggest joining a club or a race in that area.

To provide you with targeted promotions

We use the information we collect and receive to serve you with relevant promotions, subject to your notification and email preferences. For example, if we see you are an active user who has been on a monthly subscription plan for an extended period of time, we may serve you a promotion to switch to a discounted annual plan. Or if you are an active user who has never subscribed, we may send you an offer for a free subscription trial.

To protect you and the Services

We use the information we collect and receive to protect users, enforce our Terms of ServiceAcceptable Use Policy, and Community Standards, and promote safety. For example, we find and remove content that violates our terms, such as hate speech or spam, as well as suspend or terminate accounts that share such content. My Welly reserves the right to review accounts and user actions on the Services to ensure compliance with our Terms. You can learn more about how to report content that violates our terms and standards here.

To assist you with a support request

We use the information we collect and receive to provide support in response to your requests and comments. Depending on your request, this may require us to access your account, for example, to troubleshoot or replicate a reported issue.

To improve our Services

We also use the information we collect and receive to conduct research, and to analyze, develop, troubleshoot, and improve the Services. To do this, My Welly may use third-party analytics providers to gain insights into how our Services are used, using aggregated data, and to help us improve the Services.

To communicate with you

We may also use the information we collect and receive to market and promote the Services, activities and events on My Welly, and other commercial products or services, including using email and push notifications, in accordance with your preferences. We may also contact you for partnership opportunities, when investigating alleged violations of our terms, or to send proactive customer support messages.

To process your subscription

We use the information we collect to process your subscription, including using your location data to determine your country pricing.

How Information is Shared

We do not sell your personal information for monetary value. We may share personal information in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below. In addition, we may sell or share aggregated data about our users, as described in more detail in the “Aggregate Information” section below.

Service Providers

We may share your information with third parties who provide services to My Welly such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf, to promote My Welly or display information that may be relevant to your interests on the Services or other websites or services.

Publicly Available Information

When you join the My Welly community as an individual of 18 years of age or older, your profile and your activities are set to be viewable by everyone by default. If you do not customize your privacy controls within a short period of time, My Welly will begin hiding the first and last 200 meters of your activity maps by default. Your name and other profile information is viewable by other My Welly users and the public and, subject
to your privacy controls, additional information and content you share may also be viewable. For example, your media content and routes may be accessed by other My Welly users and non-users or viewable on publicly accessible My Welly pages or in search engine results.

When you join the My Welly community as an individual under the age of 18, your profile and your activities are set to be viewable by followers only by default. In order for another My Welly user to be able to see your detailed profile information or your activities, the My Welly user must first request to follow you and you must accept that request. For example, a My Welly user will not be able to see your uploaded activities or photos until after you have granted the My Welly user permission to follow you.

We provide a variety of privacy controls to manage the sharing of your information and enco

urage our users to adjust their controls to align with their desired experience.

Sharing Information and Activities

We share your information with other My Welly users and the public in accordance with your privacy controls. You can change the visibility of the activities you upload to My Welly. Also, you can tell us about important locations, such as your home or work address, by using our “Hide a Specific Address” feature in your privacy controls. We will hide any portion of your activity on your activity map that starts or ends near your hidden addresses. Using My Welly, you can choose to invite your trusted contact(s) to view your live location while recording activities. You can also share your activities with your contacts via text, email, or on social media applications like Meta, Instagram, and Twitter. If you link your My Welly account to other social networks and share your activities, they will be viewable on such third-party platforms, including your location information. You should use caution when sharing information via third parties and you should carefully review the privacy practices of such third parties.

Targeted Advertising

We may use the information we collect and receive about you to provide you with targeted advertising if you accept non-essential cookies using our cookie banner. You may opt-out of targeted advertising by clicking the “Do Not Share My Personal Information” link in the footer below or in our app by clicking on the “Personal Information Sharing” link in your Privacy Controls and following the instructions.

Third Party Business via API or Other Integrations

We enable you to share your information and content with third party apps, plugins, or websites that integrate with the Services, as well as with third parties who work with My Welly to offer an integrated feature, such as a challenge sponsor, media streaming, or tracking device. You can choose to share your profile data and activity data (including private activities) with these third parties. Information collected by these third parties is subject to their terms and policies and may not provide you with the same privacy controls that are available on My Welly (for example, hiding a specific address or the start and end points on activity maps). My Welly is not responsible for the terms or policies of third parties.

Aggregate Information

My Welly may deidentify and aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties. Examples include information about equipment, usage, demographics, routes, performance, and challenge participation and completion. My Welly may use, sell, license, and share this aggregated information with third parties for research, business or other purposes such as to improve walking, running or riding in cities via My Welly or to help our partners understand more about users, including the people who use their products and services. My Welly also uses aggregated data to generate our Global Heatmap and other community-powered features such as Points of Interest and Start Points. Please visit your privacy controls if you would like to opt out of My Welly using your information for these purposes. 

Subsidiaries and Acquirors of our Business or Assets

We may share your information with our subsidiaries, such as Recover Athletics and FATMAP, who are required to handle your personal information in accordance with their own Privacy Policies.

If My Welly becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction.

Legal Requirements

We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that this is reasonably necessary or appropriate to: (1) prevent any person from death or serious bodily injury; (2) to address issues of national security or other issues of public importance; (3) to prevent or detect violations of our Terms of Service or fraud or abuse of My Welly or its users (4) or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

Managing Your Settings

Privacy Controls

My Welly offers several features and settings to help you manage your privacy and share your activities. Most privacy controls are located in your privacy controls page, but some are specific to individual activities, athletes, routes, or features. My Welly provides you the option to make your activities visible to everyone, only your followers and you, or just youClick here to manage your privacy controls.

Adjust Notification and Email Preferences

My Welly offers various ways to manage the notifications you receive. You can choose to stop receiving certain email notifications by indicating your preferences here. You may also unsubscribe from these emails by following the instructions contained at the bottom of these messages. In our app, you can access your “Push Notifications” in the settings menu. Where permitted by local regulations, we may opt you into marketing-related communications if you substantially interact with the Services or purchase a subscription. We may also send you periodic communications asking if you would like to opt into receiving marketing-related communications.

If you receive marketing communications from one or more of our subsidiaries, you must opt-out individually from each subsidiary you are receiving brand-specific marketing from.

Any administrative or service-related emails (for example, to confirm a purchase, to notify you of pricing changes, to deliver a training plan you requested, or provide an significant update to our policies, etc.) may not offer an option to unsubscribe as they are necessary to provide the Services you requested. You are responsible for providing us with a valid email address and keeping it updated to ensure you get these email notifications.

Updating Account Information

You may correct, amend or update profile or account information at any time by adjusting that information in your account settings. If you need further assistance correcting inaccurate information, please contact MyWelly at mywelly.wellytech.vn

Deleting Information and Accounts and Downloading Your Data

You can delete your account or download your data using our self-service tools. Follow the instructions here to download your data, including your activity files. To delete your account please follow the instructions provided here.

After you make an account deletion request, we permanently and irreversibly delete your personal information from our systems, including backups. Once deleted, your data, including your account, activities and place on leaderboards cannot be reinstated. Following your deletion of your account, it may take up to 45 days to delete your personal information and system logs from our systems. Additionally, we may retain information where deletion requests are made to comply with the law and take other actions permitted by law.

Note that we do not have control over content you have shared directly with others, such as photos or videos on other social media platforms, or that others may have copied. In other words, content or information may remain available after you have deleted your account or deleted specific information from your own profile. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

My Welly also provides you the option to remove individual activities you have posted without deleting your account. Once removed, the activities may remain on MyWelly’s systems until you delete your account.

Children’s Privacy

Our services are not intended for, nor directed to, children under 13 years of age. We use technical measures to prevent children under 13 years of age from creating an account and therefore do not knowingly collect personal information from anybody under 13 years of age. If you are under 13 years of age, do not use the Services.

Moreover, we strive to provide additional privacy and safety protections for individuals under 18 years of age. For example, when users under 18 years of age create an account, their profile and activities are set by default to be viewable by followers only. We also may limit how we collect or process the personal information of individuals under 18 years of age. For example, you must be at least 16 years of age to upload heart rate data or receive heart rate analysis.

How We Protect Information

My Welly implements technical, physical, and organizational measures and controls to safeguard and protect the transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity.

Please be aware that despite our efforts, we cannot guarantee absolute security of your account or information. In addition, you can take steps to protect your account and information such as creating a unique password for My Welly that is not easily guessed and that you don’t use anywhere else, not sharing your password with others, and promptly reporting suspicious activity or unauthorized account access.

Your Rights and Our Legal Bases

We provide the same suite of privacy controls to all of our users worldwide. Particular rights may be available to you if you reside in certain locations, such as the EEABrazil or certain U.S. states such as CaliforniaLearn more about your rights and how to exercise them.

Your Legal Rights in the EEA

If you reside in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. MyWelly’s lead supervisory authority in the EEA is the Data Protection Commission of Ireland. Learn more.

Our Legal Bases

My Welly relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • as necessary to provide the Services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide the Services unless we collect and use your location information;
  • where you have consented to the processing;
  • where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  • to protect your vital interests, or those of others, such as in the case of emergencies; and
  • where necessary for the purposes of MyWelly’s or a third party’s legitimate interests, such as our interests in protecting our users, our partners’ interests in collaborating with our users, and our commercial interests in ensuring the sustainability of the Services.

Cross Border Data Transfers

The Services are operated from the United States. If you are located outside of the United States and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in the United States, as it is necessary to provide the Services and perform the Terms of Service.

Whenever we transfer personal data internationally, we use legal mechanisms, such as Standard Contractual Clauses, to ensure data transfers comply with applicable law.

Retention of Information

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted or becomes inactive. In making these determinations, we consider the amount, nature, and sensitivity of the personal information, the purposes for which the information is processed, whether we can achieve those purposes through other means, and applicable legal requirements.

In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account. For example, if you withdraw your consent to MyWelly processing your health-related information, MyWelly will thereafter delete all health-related information from activities you upload. Following your deletion of your account, it may take up to 45 days to fully delete your personal information and system logs from our systems. Additionally, we may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our Services to you may be de-identified or aggregated with other non-personal data to provide insights that are commercially valuable to MyWelly, such as statistics of the use of the Services. For example, we may retain publicly available segments or routes and other depersonalized geolocation information to continue to improve the Services, and we use aggregated information in MyWELLY Metro and our Global Heatmap. This information will be de-associated from your name and other identifiers.

Other MyWelly Sites

MyWelly maintains certain websites that can be accessed outside of https://mywelly.wellytech.vn, such as https://mywelly.wellytech.vn or https://mywelly.wellytech.vn (the “Other Sites”). The Other Sites may maintain the look and feel of the Services, but are hosted by outside service providers with their own terms and privacy policies. If you interact with the Other Sites, your information may be stored, processed, or shared outside of the Services. If you interact with the Other Sites, you acknowledge that you may be subject to the terms and conditions and policies applicable to such Other Sites, which may differ from this Privacy Policy. Please be aware that any personal information you submit to the Other Sites may be read, collected, or used by other users of these forums indefinitely, and could be used to send you unsolicited messages. MyWelly is not responsible for the personal information you choose to submit via the Other Sites.

Privacy Policy Updates

MyWelly reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If MyWelly makes changes to this Privacy Policy, the updated Privacy Policy will be posted in a timely manner. If we make changes we deem to be material, we will provide a prominent notice. If you object to any changes to this Privacy Policy, you should stop using the Services and delete your account.

Past Privacy Policy Versions

  • May 21, 2024
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