Definitions and Interpretation

1.  In this Privacy Policy, the following definitions are used:
‍
Data
collectively all information that you submit to Wellence via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited tothe GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
GDPR
the UK General Data Protection Regulation;
Wellence, we or us
Wellence, a company incorporated in England and Wales with registered number 13499958 whose registered office is at 6 Florey Lodge, Admiral Walk, London, W93TF;
User or you
any third party that accesses the Website and is not either (i) employed by Wellence and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Wellence and accessing the Website in connection with the provision of such services;
Website
the website that you are currently using, wellence.me, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
2.  In this Privacy Policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this Privacy Policy.

Scope of this Privacy Policy

3.  This Privacy Policy applies only to the actions of Wellence and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
4.  For purposes of the applicable Data Protection Laws, Wellence is the "data controller". This means that Wellence determines the purposes for which, and the manner in which, your Data is processed.

Data Collected

5.  We may collect the following Data, which includes personal Data, from you:
a. name;
b. date of birth;
c. gender;
d. job title;e. profession;
f. contact Information such as email addresses and telephone numbers;
in each case, in accordance with this Privacy Policy.

How We Collect Data

6.  We collect Data in the following ways:
a. data is given to us by you; and
b. data is collected automatically.

Data That is Given to Us by You

7.  Wellence will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you register with us and set up an account to receive our products/services;
c. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
d. when you make payments to us, through this Website or otherwise;
in each case, in accordance with this Privacy Policy.

Data That is Collected Automatically

8.  To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

Our Use of Data

9.  Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. improvement of our products / services;
b. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
in each case, in accordance with this Privacy Policy.

10.  We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

11.  When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Who We Share Data With

12.  We may share your Data with the following groups of people for the following reasons:
a. our employees, agents and/or professional advisors - To customise the service for users;
in each case, in accordance with this Privacy Policy.

Keeping Data Secure

13.  We will use technical and organisational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a user name that is unique to you.
b. we store your Data on secure servers.

14.  Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any
misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail
address: team@wellence.me.
‍
15.  If you want detailed information from Get Safe Online on how to protect your information and your computers and
devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online
is supported by HM Government and leading businesses.

Data Retention

16.  Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.

17.  Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

18.  You have the following rights in relation to your Data:
a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
e. Right to data portability - the right to request that we move, copy or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

19.  To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: team@wellence.me.

20.  If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO).The ICO's contact details can be found on their website at https://ico.org.uk/.

21.  It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to Other Websites

22.  This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

23.  Wellence may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Wellence. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

24.  We may also disclose Data to a prospective purchaser of our business or any part of it.

25.  In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

26.  You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights
under this Privacy Policy where we reasonably believe your rights will not be affected.

27.  If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid,
illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and
enforceability of the other provisions of this Privacy Policy will not be affected.

28.  Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a
waiver of that, or any other, right or remedy.

29.  This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising
under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to This Privacy Policy

30.  Wellence reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations. You may contact Wellence by email at team@wellence.me.

Attribution

31.  This Privacy Policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en).

This Privacy Policy was created on 02 November 2023.

Please read this Privacy Policy carefully.

This Privacy Policy applies between you, the User of this Website, and Wellence, the owner and provider of this Website. Wellence takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

PRIVACY POLICY

Privacy Policy

This Privacy Policy explains how Wellence Ltd ("Wellence", "we", "us") collects, uses, shares, and protects your personal information when you interact with our services. It applies to your use of our website, as well as our Slack and Teams integrated software platform (the "Wellence Platform").

If you have any questions or concerns, please contact us at

legal@wellence.me

Who We Are

Wellence Ltd is a UK-based company (Company No. 15287383), registered at: 6 Florey Lodge, London, W9 3TF, United Kingdom

Wellence provides an AI-powered management platform delivered through workplace tools like Slack and Microsoft Teams. We do not operate a standalone login system; users access the Wellence app entirely via their Slack (or Microsoft Teams) credentials.

Our role in relation to your personal data depends on the context in which it is collected. We are a data controller for data we collect through our website, marketing and communications. For data processed inside the Wellence Platform, your organisation is the data controller and Wellence acts as a data processor (see “Our Role” below).

Scope of This Policy

This policy covers:

  • Visitors to our website (www.wellence.me)

  • Users of the Wellence Platform via Slack or Teams

It does not cover any third-party websites or services linked from our platforms.

This policy explains:

  • What personal data we collect and how

  • How and why we use it

  • The legal basis for doing so

  • Who we share it with

  • Your rights under data protection law

  • Our approach to data security and retention

What Data We Collect

We only collect data necessary to deliver and improve our service. This includes:

From Slack

  • Slack workspace and user ID

  • Display name, email address, and profile photo

  • Role information (e.g. manager, team member)

User Activity

  • Interaction history with the app (e.g. questions asked, actions taken)

  • Feedback submitted via app prompts

  • Participation in onboarding sessions and support

Analytics

  • Aggregated usage data (e.g. feature usage, performance trends)

  • No personally identifiable insights are shared externally

How We Collect Data

We collect Personal Data in the following ways:

  • Directly from you (e.g. when interacting with the app)

  • From your organisation (e.g. your Slack workspace)

  • Automatically through logs and analytics tools

Our Role
(Controller vs Processor)

  • Wellence acts as a data controller for personal data we collect through our website, sales processes, billing, and communications.

  • For all personal data processed inside the Wellence Platform (including employee check-ins, responses, goals, feedback, and usage signals), your organisation is the data controller and Wellence acts as a data processor, processing this data only under your organisation’s instructions and in accordance with our Data Processing Addendum (DPA).

How and Why We Use Your Data

We process your data:

PURPOSE

To provide our core services (check-ins, coaching prompts, insights)
To respond to your enquiries
To improve our product via aggregated analytics
To comply with legal obligations
LEGAL BASIS
Performance of a contract (your organisation's agreement with us)
Legitimate interests
Legitimate interests (with appropriate safeguards)
Legal requirement

We do not use personal data for automated decision-making that has legal or similarly significant effects. We do not sell or rent personal data. We will never use your Slack credentials or identity outside the authorised workspace.

Special Category Data

The Wellence Platform is not designed to collect special category data under the UK GDPR (e.g. health information, racial or ethnic origin, political views, religious beliefs, sexual orientation, biometric or genetic data).

We intentionally design our questions and prompts to avoid soliciting sensitive information, and we ask users not to include such information in free-text responses.

If special category data is inadvertently provided, we do not use it for analytics or product improvement and will delete or anonymise it where appropriate.

Subprocessors

We use third-party subprocessors to help operate our services. These subprocessors are contractually required to safeguard your data and comply with relevant laws:

SUBPROCESSOR

OpenAI
LangChain
Mixpanel
PURPOSE
Language processing (no user/company context shared)
Message orchestration between Slack and OpenAI
Aggregated analytics for product insights
DPA LINK
Link
Link
Link

We are currently updating public DPA links for each sub-processor following a website restructure. We can provide all DPA links or PDF copies upon request.

Data Retention

No personal identifiers (like names or email addresses) are sent to OpenAI or Mixpanel. We minimise personal identifiers sent to subprocessors and, where possible, use anonymised or pseudonymised data. We may also disclose data if required by law, or in the context of a business sale or merger (see Business Transfers section). We retain personal data only as long as needed for the purposes outlined above or as required by law.

User-generated content is retained while the client subscription is active. Some analytics and aggregated data may be retained longer in anonymised form.

Personal data processed inside the Wellence Platform is retained for the duration of your organisation’s active subscription, unless required otherwise by law or the organisation acting as data controller.

Aggregated or anonymised analytics data may be retained for longer to improve our services, but this data cannot reasonably be used to identify an individual.We may disclose data if required by law or in the context of a business sale or merger (see “Business Transfers”).

Your Rights

Under the UK GDPR, you have the right to:

  • Access your personal data

  • Correct inaccurate or incomplete data

  • Erase your data (in some cases)

  • Object to or restrict processing

  • Port your data to another provider

  • Withdraw consent (if processing is based on consent)

To exercise your rights, contact legal@wellence.me

You also have the right to lodge a complaint with the ICO at www.ico.org.uk

Security

We will use technical and organisational measures to safeguard your Data, including:

  • Secure cloud hosting

  • Access controls and encryption

  • Role-based internal access

  • Regular security audits and vulnerability reviews

  • Regular review of subprocessors

If you suspect unauthorised access or misuse, please notify us immediately at
team@wellence.me

Business Transfers

If Wellence is involved in a merger, acquisition, or asset sale, your data may be transferred. We will notify affected users before such a transfer takes place.

Children's Data

Our services are not intended for use by individuals under 18. We do not knowingly collect personal data from children.

Cookies and External Links

Our website may use cookies for analytics or performance improvement. You may also find links to third-party websites. We are not responsible for the privacy policies of those external sites.

Changes to This Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated clearly via email or platform notification. The most current version will always be available at www.wellence.me/privacy.

Contact

Data Protection Contact:

Email: legal@wellence.me

Registered address: Wellence Ltd, 6 Florey Lodge, London, W9 3TF, UK

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