Privacy Policy

Introduction

This Privacy Policy explains how WELL Health Inc. d/b/a Artera (“Artera,” “we,” “us,” or “our“) collects, uses, and discloses information from website visitors, job applicants, and our current or prospective clients (“clients” or “you“) when you use our website, platform, and other online products and services that link to this policy (collectively, the “Services“) or when you otherwise interact with us.

As used in this Privacy Policy, “personal information” means any information that can be used to individually identify a person or household, and may include, but is not limited to, name, email address, postal code or physical address, title, and other information reasonably linkable to an individual or household with or without other identifying information in our possession. Personal information also includes information relating to a person’s professional background, and may include education, training, employment history, and certifications.

This Privacy Policy does not apply to protected health information (“PHI“) under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), its rules, or other privacy law applicable to your relationship with your healthcare provider (“Provider“). Any collected information that constitutes PHI is governed by, and will be used and disclosed solely as permitted under, the business associate agreement or services agreement between Artera and your Provider, as required by law, to safeguard PHI. For more information about the privacy of your PHI, please contact your Provider or refer to their Notice of Privacy Practices. To the extent that we receive PHI about you, that information is subject to electronic disclosure to the extent permitted by applicable law.

We may aggregate or de-identify information for various purposes, including to improve our products and Services. Aggregated or de-identified information cannot be reasonably used to identify you and is not subject to this Privacy Policy.

Updates may be made to this Privacy Policy from time to time, and will inform you by revising the date at the bottom of this policy. In some cases we may provide you with additional notice. We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Collection of Personal Information

Artera’s Services are not intended for individuals under the age of eighteen, and Artera does not intentionally collect personal information of individuals under the age of eighteen. If you are a parent or guardian of a minor and believe Artera collected or is otherwise processing personal information of a minor, you can reach out to [email protected] for further assistance.

There are three general categories of personal information we collect:

1. Information you provide to us;
2. Information we automatically collect from your use of the Services; and
3. Information we collect from third parties.

Information you provide to us

We collect information you provide directly to us, for example, when you create an account, participate in any interactive features of the Services, fill out a form, request customer support, apply for a job with us, or otherwise communicate with us.

The types of information we may collect from you include:

• Account information: when you register for an account with our Services, you will need to provide us with certain personal information to complete the registration, including information that can be used to contact or identify you, which may include your name, email address, username, password, and phone number.
• Customer information: when you contact our sales team or customer support team, or when you request more information about our Services, we may collect your name, email address, phone number, profession, company name, company address, number of employees, company website, and other professional information.
• Information about others: we may collect information about other individuals, such as the names and the contact information of your Providers and dependents under your care. 
• Other information you choose to provide: we may collect additional information that you provide, such as when you request technical or customer support, communicate with us, or apply for a job with us.

Information we collect when you use the Services

When you access or use our Services, we automatically collect information about you, including:

• Usage information: we may collect information about your activity on our Services. 
• Log information: we may collect log information about your use of the Services, including the type of browser you use, access times, pages viewed and visited, and your IP address.

Information collected by cookies and other tracking technologies: we and our service providers may use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experiences, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used on our Services or emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. Please see our separate Cookie Policy to learn about how we use cookies on the Services and your choices in relation to the use of cookies.

Information we collect from other sources

We may obtain personal information from other sources and use it as contemplated herein, including to provide the Services and otherwise communicate with you.

Use of Personal Information

We may use personal information about you for various purposes, including to:

• Provide and deliver the products and Services you request;
• Maintain and improve our Services;
• Send you technical notices, updates, security alerts, and support and administrative messages;
• Inform you of job opportunities and evaluate your suitability for a job;
• Respond to your comments, questions, and requests, and provide customer service;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by Artera and others, and provide information we think will be of interest to you;
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Artera and others; and
• Such other purposes as you may consent or may be permitted or required by law.

Sharing of Personal Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants, and other service providers who need to access such information to carry out work on our behalf;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process;
• With other users of the Services as you direct through your use of the Services;
• In relation to exercising or protecting the rights, property, and safety of Artera and others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
• Between and among Artera and its current or future parents, affiliates, subsidiaries, and other companies under common control and ownership to the extent permitted by applicable law; and
• With your consent or at your direction, or as may be permitted or required by applicable law.

Links to Third Party Sites

Our Services may contain links to other websites, and other websites may reference or link to Artera and our Services. These other websites are not controlled by Artera. Artera does not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or web applications, and encourage users to review each website’s own Privacy Policy.

Security

Artera takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. However, please be advised that when information is transmitted over the internet, it cannot be guaranteed to be completely secure.

Retention of Your Personal Information

Artera will retain information about you only for as long as is necessary for the purposes set out in this Privacy Policy or as long as we have a legitimate business need for it. If you no longer want Artera to use information about you to provide the Services to you, you may cancel your account. Artera will retain and use such information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We also retain log files for internal analysis purposes. These log files are generally retained for a limited period of time, except in cases where they are used for the safety and security of the Services, to improve functionality of the Services, or we are legally obligated to retain them for longer periods of time.

How We Respond to “Do Not Track” Signals

Some browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. Artera’s website honors these signals once they have been implemented on your browser. To implement out-opt preferences on a browser level, you can implement browser extensions. Your activity outside of Artera’s website, such as on our partners’ websites or within the Artera platform, may be tracked in accordance with this Privacy Policy even if your browser’s “Do Not Track” feature is activated. 

Use from Outside the United States

If you are using our Services from a country outside of the United States, we will collect, store, and process your personal information in the United States or other countries in the world where we or our service providers operate. Any such transfers will comply with safeguards as required by relevant law. The privacy laws that apply to us may be different from and not as comprehensive or protective as those in the country where you are. By using our Services, you understand and accept the transfer of your personal information to the United States.

Contact Us

If you have any questions about Artera’s privacy practices, please contact us by email at [email protected].

Additional Information for Residents of Certain Jurisdictions

Notice to California residents

This notice is for residents of the state of California regarding state-specific privacy rights and responsibilities. For residents of California, this section supersedes any other possibly divergent or conflicting aspects of this Privacy Policy. This part of the document uses the term “personal information” as defined by the California Consumer Privacy Act (CCPA).

Information that can be defined as “health information” per the Confidentiality of Medical Information Act (CMIA) is excluded from this Privacy Policy as it is governed in a similar manner as PHI.

Personal information we collect, their sources, and their uses

We have collected the following categories of personal information about you in the preceding twelve months: identifiers including IP address, interactions with our Services, and cookies. This information is collected automatically through your use of our Services via your device or web browser. If you have completed a Contact Us form, we will collect the identifiers you have provided to us. We retain this information as described in the section above titled “Retention of Your Personal Information.”

If you submit a job application through our website, we will collect the following personal information from you as you complete your application: race or ethnic origin, professional or employment-related information, and education information. We collect this information to process your application and facilitate the recruitment process, and this information is kept for ten years. In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

For information that can be considered sensitive personal information under the California Consumer Privacy Act (CCPA), Artera uses this data either in a transient manner or to support Artera’s human resources activities.

Personal information that has been disclosed for a business purpose

Artera has disclosed identifiers to third parties associated with cookies in the preceding twelve months for internal development and analysis purposes. For more information about Artera’s use of cookies, please refer to our Cookie Policy.

Personal information that has been sold or shared

Artera has shared identifiers associated with cookies in the preceding twelve months for behavioral advertising purposes. 

Artera has sold information related to identifiers and other tracking technology for behavioral advertising purposes in the preceding twelve months. Artera does not knowingly share or sell the personal information of individuals under the age of 18. Management and collection of minors’ data is discussed at the beginning of this Privacy Policy. 

For more information about cookies and information Artera sells or shared, please refer to our Cookie Policy.

Your California privacy rights

• The right to know. You have the right to know the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared.
  • In case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
    • For sales, the personal information categories purchased by each category of recipient; and
    • For disclosures for a business purpose, the personal information categories obtained by each category of recipient.
• The right to request the deletion of your personal information. You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law. If no legal exception applies, we will delete your personal information and direct any of our service providers or contractors to do so.
• The right to correct. You have the right to correct any inaccurate personal information that Artera maintains about you, and we will honor your request to the extent that we are able to technically.
• The right to opt-out of sale or sharing of your personal information. You have the right to opt-out of the sale or sharing of personal information. 
• The right to limit the use and disclosure of your sensitive personal information. You have the right to request a limitation on the use and disclosure of your sensitive personal information.

The right to nondiscrimination. You have the right to nondiscrimination for exercising your privacy rights, and Artera will not discriminate against you for exercising your rights.

How to exercise your California privacy rights

You can exercise the rights described above in the following ways:

• For updating cookie preferences, please click the following button Cookie Settings
• To limit the sale or sharing of your personal information, or to exercise other rights, please click this link.
• Email us at [email protected]. 

Certain requests, by law, require identity verification – these requests include the right to know, right to delete, and right to correct. In those instances, we will confirm your identity to ensure that it is you or your representative placing the request. We will not be able to fulfill those requests if we are unable to confirm your identity. If you personally cannot submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. Adults may make requests on behalf of a minor under their parental authority.

How we will handle your request

We will confirm receipt of your verifiable request within ten days and provide information about how we will process your request. We will then respond to your request within forty-five days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. Please note that we may take up to ninety days to fulfill your request. 

If we deliver our response electronically, the information enclosed will be portable, or in other words, delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible. 

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

California’s Shine the Light

We will give you the opportunity to decide whether you allow us to share your personal information with third parties for those third parties’ direct marketing purposes before we collect your personal information.

Notice to Colorado residents

This notice is for residents of the state of Colorado regarding state-specific privacy rights and responsibilities. For residents of Colorado, this section supersedes any other possibly divergent or conflicting aspects of this Privacy Policy. This part of the document uses the term “personal data” as defined by the Colorado Privacy Act (CPA).

Information that can be defined as “protected health information” per the Health Insurance Portability and Accountability Act (HIPAA) is excluded from this Privacy Policy.

Personal data we collect and their uses

The Personal Data we collect is described in the “Collection of Personal Information” section of this Privacy Policy. The purpose for the collection of Personal Data and how we use it are described in the “Use of Personal Information” section of this Privacy Policy.

Personal data that has been sold or shared

Artera has shared identifiers associated with cookies in the preceding twelve months with third-party advertisers for behavioral advertising purposes.

Artera has sold information related to identifiers and other tracking technology to third-party advertisers for behavioral advertising purposes in the preceding twelve months. Artera does not knowingly share or sell the personal data of individuals under the age of 18. Management and collection of minors’ data is discussed at the beginning of this Privacy Policy.

For more information about cookies and information Artera sells or shares, please refer to our Cookie Policy. You may also opt out of selling or sharing your personal data for targeted advertising using the steps outlined below.

Your Colorado privacy rights

Residents of the State of Colorado have the following data rights:

• Opt out of sales of personal data and use of their personal data for targeted advertising, as those terms are defined under applicable law.
• Opt out of “profiling” under certain circumstances, as defined under applicable law.
• Confirm processing of and access to personal data under certain circumstances.
• Correct personal data under certain circumstances.
• Delete personal data under certain circumstances.

How to exercise your Colorado privacy rights

You can exercise the rights described above and submit requests in the following ways:

• For updating cookie preferences, please click the following button Cookie Settings
• To limit the sale or sharing of your personal information, or to exercise other rights, please click this link,
• Email us at [email protected], or
• Mail us a letter at:

Well Health Inc. d/b/a Artera
1025 Chapala Street
Santa Barbara, CA 93101

You may, under certain circumstances, authorize another individual or a business, called an authorized agent, to make requests on your behalf.

We must verify your identity before responding to your authorized agent request. We verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity.

We will not use personal information we collect in connection with verifying or responding to your authorized agent request for any purpose other than responding to your authorized agent request.
Once your identity has been verified and your authorized agent request has been approved, your authorized agent may submit a request to opt out of the processing of consumer personal data on your behalf, pursuant to the CPA. Such a request from your authorized agent may be submitted in the following ways:

• Email us at [email protected] or
• Mail us a letter at:

Well Health Inc. d/b/a Artera
1025 Chapala Street
Santa Barbara, CA 93101

To appeal the decision associated with your request, you can use either the above methods of communication to contact us or reach out to us in the manner we provided the decision to you.

Universal opt-out mechanisms will be recognized and honored. We may process other personal information about you, such as personal data you submit in a job application.

Notice to European Economic Area and the United Kingdom residents

In addition to the aforementioned information, the following information applies to any individual located in the European Economic Area (“EEA“) or in the United Kingdom (“UK“). For the purposes of this section, any defined terms have the meaning under the European Union’s General Data Protection Regulation (“GDPR“) or the UK General Data Protection Regulation as applicable. If you are a resident of the EEA or UK, you have certain rights and protections under the law regarding the processing of your Personal Data.

Data Controller

Well Health Inc. d/b/a Artera
1025 Chapala Street
Santa Barbara, CA 93101

Data Protection Officer / Representative: [email protected]

Artera may also act as a data processor or business associate on behalf of third-party data controllers and may receive Personal Data from such data controllers. Personal Data received by Artera as a processor will be governed by the privacy policies and contracts with the applicable data controller.

Lawful basis for processing

If you are a resident of the EEA or the UK, we primarily rely on the following bases to process your Personal Data lawfully.

• First, it is necessary for us to process your Personal Data in certain ways in order to provide the Services to you.
• Second, where you have given us valid consent to use your Personal Data in certain ways, we will rely on your consent. For example, this includes situations where we will obtain your consent prior to sending you information about our products and Services.
• Third, in certain cases we may process your Personal Data where necessary to further Artera’s legitimate interests, where those legitimate interests are not overridden by your rights or interests. This includes usage statistics, analytics and internal analyses we run to better understand how to use our Services so that we can improve our Services and also provide you with recommendations on how to get the most out of our Services. This also includes information we process and disclose to detect, prevent, and address fraudulent and illegal activities on our Services.
• Fourth, in some cases we may process your Personal Data where necessary to satisfy our legal obligations. This includes records containing your Personal Data that we may be required to retain for a period of time or may be legally required to disclose to a government authority or third party.

Data subject rights requests

Except for information we collect on our website, we are a processor for Providers who act as data controllers; thus, if you are a patient of a Provider and wish to exercise your rights, you must contact your Provider, not Artera. However, you have the following rights related to the information that we maintain about you when you use our websites:

• The right to be informed about how your information is used. This is the reason we provide this Privacy Policy to you.
• The right to access the information we hold about you.
• The right to request the correction of inaccurate information we hold about you.
• In some circumstances, the right to request that we delete your information, or stop processing it or collecting it.
• The right to stop direct marketing messages, which you can do by clicking on any “unsubscribe” link in any marketing email you receive from us. You also have the right to withdraw your consent for other processing activities for which you have given us your consent.
• The right to request that we transfer your information either to you or a third party.
• The right to complain to your data protection regulator.

If you want to exercise your rights, please complete the UK/EU Data Subject Request Form.

If you have any questions or concerns, please reach out to us using the contact information in this Privacy Policy.

Transfers outside of the EEA and the UK

Artera is headquartered in the United States. Artera may transfer or provide access to your Personal Data to affiliates, service providers or collaborators in countries that do not provide the same level of protection as your own region, including the EU and UK. Artera is committed to complying with this Privacy Policy and EU and UK privacy laws with regard to information transferred from those jurisdictions. We rely on safeguards contained in model form contracts approved by regulators in the EU and UK for these transfers, or other approved transfer mechanisms.

Questions or complaints

If you are a resident of the EU/EEA or the UK and have a concern about our processing of your Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside. For contact details of your local Data Protection Authority, please see the links below:

For individuals in the EEA or the UK:

http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Notice to Canada residents

Canadian privacy laws may provide you with the right to request access to, or correction of, your Personal Information (as that term is defined in Canada law) in our control. If you want to exercise your rights, please complete the Canada Data Subject Request Form.

We may need to verify your identity before responding to your request. In some circumstances, we may not provide access to your Personal Information, for example, if it contains the Personal Information of other persons, if it constitutes confidential commercial information, or if it is otherwise not properly the subject of an access request. In some instances, we may transfer your Personal Information outside of Canada to the United States for processing.

If you have any questions, requests or complaints about our personal information practices, please contact our Privacy Officer.

You may contact our Privacy Officer by email at [email protected] or by mail at the following address:

Privacy Officer
Well Health Inc. d/b/a Artera
1025 Chapala Street
Santa Barbara, CA 93101

Last Updated: June 17, 2024