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Wember Privacy Policy

Effective Date: 8 January 2024

At Wember, we take your privacy seriously. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use our websites (including wember.me) and related services (“Services”).

By using our Services, you agree to the terms described in this Policy.

1. What This Policy Covers

This Privacy Policy applies to personal data collected through Wember’s platform, including interactions via our website, mobile app, and services delivered through Third Party Providers. This Policy does not apply to other organizations such as your employer, or to Third Party Providers’ own privacy practices.

If you use Wember through an employer-sponsored program or as a qualifying Family Member, we may receive or share data with the organization that grants you access.

Wember Estonia Ltd. (registered in Tallinn, Estonia) is the data controller for users in the European Economic Area, the UK, and other applicable regions.

2. Data We Collect

We collect personal data in the following ways:

a. Data You Provide

  • Registration Information: name, email, phone number, password, profile picture, location, and any other data you voluntarily submit.
  • Payment Information: credit/debit card data and billing address, either directly or via our payment provider.
  • Feedback & Communications: messages, reviews, survey responses, and support queries.

b. Data We Collect Automatically

  • Usage Information: check-ins, bookings, interactions with Third Party Providers.
  • Device & Log Data: IP address, browser type, cookies, device ID, geolocation (if enabled), access time, and pages visited.

c. Data from Third Parties

  • Sponsor Data: if your employer or another sponsor enrolls you, we may receive your name, work email, employee ID, and eligibility status.
  • Social Media: if you log in or interact with Wember via social media (e.g., Google or Facebook), data may be shared with us according to your settings.
  • Referral Data: personal data of referred individuals or businesses.
  • Public Sources: we may use publicly available data for business purposes.

3. How We Use Your Data

We use your data to:

  • Provide and manage your Wember account and subscription
  • Confirm eligibility and process payments
  • Deliver services from Third Party Providers
  • Respond to support requests
  • Send relevant updates, recommendations, and offers
  • Analyze and improve the Wember Platform
  • Conduct reporting and business planning
  • Comply with legal obligations and prevent fraud
  • Fulfill contractual obligations with our partners

We rely on various legal bases under data protection laws, including contract performance, legitimate interest, legal compliance, and your consent (where required).

4. How We Share Your Data

Your personal data may be shared with the following:

  • Third Party Providers: gyms, wellness studios, trainers, and apps to facilitate your bookings and access to services.
  • Sponsors (e.g., Employers): to verify eligibility, administer benefits, run challenges, report on engagement, or address misuse.
  • Indirect Partners: benefits aggregators or wellness platforms engaged by your Sponsor.
  • Vendors & Service Providers: companies that support operations like hosting, analytics, communication, and customer service.
  • Affiliates: other Wember entities that help deliver and improve the Services.
  • Social Media Services: when you interact with Wember through their platforms.
  • Legal Authorities: to comply with legal obligations, protect rights, and address fraud or misconduct.
  • Corporate Transactions: in connection with a merger, sale, restructuring, or similar event.
  • User Submissions: content (e.g., names, location, uploaded media) may be visible to Third Party Providers when booking sessions.
  • Aggregated or De-identified Data: may be used for analytics or shared with partners in a form that doesn’t identify you personally.

5. Cookies and Tracking

We use cookies and similar technologies to improve your experience and understand how you use our Services. You can manage cookie preferences through your browser or device settings. For details, please review our Cookie Policy.

6. Communications

We may contact you via email, app notifications, or occasionally by phone or SMS:

  • You can opt out of promotional communications at any time via unsubscribe links or account settings.
  • Transactional and service-related messages (e.g., account, security, or legal updates) are required and cannot be opted out of.
  • You can manage or disable mobile notifications in your device settings.

7. Data Security

We use technical and organizational safeguards to protect your personal data from unauthorized access or misuse. However, no system is completely secure. Please take care to protect your login credentials and devices.

8. Data Retention and International Transfers

We retain your data only as long as necessary to provide the Services, fulfill legal requirements, and support business operations.

Wember operates globally. We may transfer data outside your country and use appropriate safeguards (such as EU Standard Contractual Clauses) to protect your rights.

9. Your Rights

Subject to applicable laws, you may have the right to:

  • Access your personal data
  • Correct or update inaccurate data
  • Delete your data (“right to be forgotten”)
  • Restrict or object to processing
  • Receive your data in portable form
  • Withdraw consent where applicable
  • Lodge a complaint with a data protection authority

To exercise your rights or update your data, contact us through your account settings or our Help Center. We may need to verify your identity before fulfilling your request.

10. Children’s Privacy

Wember is intended for users aged 18 and over. If you believe a child has used our Services without proper consent, please contact us and we will delete the data.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We encourage you to review it regularly. Continued use of our Services after changes means you accept the updated terms.

12. Contact Us

For general support, visit our Help Center.

For privacy-related questions or to contact our Data Protection Officer, email: dpo@wember.me

You may also contact the Estonian Data Protection Authority, our lead supervisory authority for EU users.