Draft for review — this document is a template and has not been reviewed by legal counsel. It must not be published as-is.
This privacy policy describes how [COMPANY LEGAL NAME] ("we", "us", "our") handles personal information in connection with the BeWell'r application and this website (together, the "Services"). It is written to be read; if anything is unclear, contact us at [CONTACT EMAIL].
1. Information we may collect
Depending on how you use the Services, we may collect the following categories of information:
- Account information. Where you create an account, we may collect details such as your name, email address, and authentication credentials.
- Content you provide. Where you use features of the app that involve entering information — such as plans, reflections, self-assessment responses, or messages — that content is collected in order to provide those features.
- Usage information. Where enabled, we may collect information about how the Services are used, such as feature interactions, device type, operating system, and app version.
- Communications. Where you contact us, we may retain the correspondence and the contact details you provide.
We do not collect categories of information beyond those necessary to operate, maintain, and improve the Services.
2. How we use information
Where we process personal information, we do so for purposes such as: providing and operating the Services; maintaining your account; delivering features you have chosen to use; responding to your requests; ensuring security and preventing misuse; complying with legal obligations; and, where applicable and lawful, improving the Services. Where a use requires your consent under applicable law, we will seek that consent.
3. How information may be shared
We do not sell personal information. Where we share information, it is limited to circumstances such as:
- Service providers. Where we engage third parties to perform services on our behalf (for example, hosting or customer support), they may process information solely as needed to perform those services and under appropriate contractual obligations.
- Legal requirements. Where disclosure is required by law, regulation, legal process, or enforceable governmental request.
- Business changes. Where we are involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to this policy or a successor policy.
- With your direction. Where you ask us to share information, or use a feature designed to share it.
4. Retention
Where we retain personal information, we keep it only as long as necessary for the purposes described in this policy, to comply with legal obligations, to resolve disputes, or to enforce agreements. Retention periods vary by category of information; where retention is no longer necessary, information is deleted or de-identified.
5. Your rights and choices
Depending on your location, you may have rights under applicable law, which may include the right to access, correct, delete, or receive a copy of your personal information; to object to or restrict certain processing; and to withdraw consent where processing is based on consent. To exercise any right, contact us at [CONTACT EMAIL]. We will respond within the time required by applicable law. You may also have the right to lodge a complaint with a supervisory authority in [JURISDICTION] or your place of residence.
6. Security
Where we hold personal information, we use administrative, technical, and organizational measures designed to protect it, appropriate to the nature of the information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
7. Children
The Services are not directed to children under the age at which parental consent is required in your jurisdiction, and we do not knowingly collect personal information from such children. If you believe a child has provided us personal information, contact us at [CONTACT EMAIL] and we will take appropriate steps to delete it.
8. International transfers
Where personal information is transferred across borders, we take steps designed to ensure it receives appropriate protection consistent with applicable law, which may include contractual safeguards.
9. Changes to this policy
We may update this policy from time to time. Where changes are material, we will provide reasonable notice — for example, within the app or by email — before they take effect. The "updated" date at the top of this page reflects the latest revision.
10. Contact
Questions, requests, or concerns about this policy or our data practices can be directed to:
[COMPANY LEGAL NAME] [CONTACT EMAIL]
This policy is governed by the laws of [JURISDICTION], without prejudice to any protections you are entitled to under the laws of your place of residence.