Privacy Policy

Last updated August 22, 2024

Thank you for choosing to be part of our community at HandsFree Health (“HandsFree”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please complete a contact form on our website www.handsfreehealth.com.

When you use our Products (as defined below), you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to clearly explain to you what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Products.

This privacy policy applies to all information collected through use of our website, https://handsfreehealth.com, our mobile app(s), our device(s), and/or any related services, sales, promotions or events (we refer to them collectively in this privacy policy as the “Products“). Additionally, this privacy policy applies to your purchase of our devices from us or to other information provided to us online or offline by third parties when we associate that information with you as a user of the Products. However, it does not apply to information collected from our employees, contractors, or vendors.

By accessing or using the Products, you consent to this privacy policy. Information gathered through the Products may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the Products, you agree to the transfer, use, and storage of your personal information in the United States and those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Products are deemed to occur in the United States, where our servers are located.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

WHAT INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
YOUTUBE
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS POLICY?
HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, health information, and social media login data.

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when using the Products or otherwise contacting us. By “personal information” we mean information that can identify or reasonably be linked to an individual.

The personal information that we collect depends on the context of your interactions with us and the Products, the choices you make and the features of the Products you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Health Information. We collect the health information you provide us when using or interacting with the Products.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (for example, a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

Mobile Device Information. Certain aspects of the Products may also access certain features of your mobile device, including its camera, location services (GPS), microphone, and contacts, and collect information from those features, such as photographs, videos, your precise location, audio recordings, and contact information. You consent to this access.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. If you fail to do so, you may not be able to use the Products.

Information automatically collected

In Short: Some information – such as IP address and/or browser information regarding Product usage and device characteristics – is collected automatically when you use our Products.

We automatically collect certain information when you visit, use or navigate the Products. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, approximate location, information about how and when you use our Products and other technical information. This information is primarily needed to maintain the security and operation of our Products, and for our internal analytics and reporting purposes.

We will not use this non-personal information to try to identify you, and if we associate any non-personal information with information that personally identifies you, then we will treat it as personal information.

Like many businesses, we also collect information through cookies and similar technologies when you use our Products.

Information collected from other sources

In Short: We may collect limited data from public databases, promotional partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, promotional partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Products for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the personal information and non-personal information we collect or receive:

To provide and support the Products. We use personal information and non-personal information to provide and maintain the Products, to provide you with customer service, and to process transactions with you.
To send you and promotional communications about our Products. We and/or our third party promotional partners may use certain personal information you send to us for to contact you or others about our Products, if this is in accordance with your preferences. You can opt-out of the promotional materials about our Products at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges.
To post testimonials. We post testimonials on our public website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at support@HandsFreeHealth.com and be sure to include your name, testimonial location, and contact information.
Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
Request Feedback. We may use your information to request feedback and to contact you about your use of our Products.
To protect our Products. We may use your information as part of our efforts to keep our Products safe and secure (for example, for fraud monitoring and prevention).
To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
To enforce our terms, conditions and policies.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond, and to respond to a subpoena or other legal request to the extent we are required to do so.
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Products, services, promotions and your experience.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to protect your rights, to fulfill business obligations, or other lawful purposes.We may share data based on the following legal basis:

Consent:We may process your personal information if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests to the extent permitted by applicable law.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including, without limitation, in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person or illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and promotional efforts. We may allow selected third parties to use tracking technology on the Products, which will enable them to collect data about how you interact with the Products over time. This information may be used for our internal purposes to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this privacy policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may transfer information (including your personal information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Products, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example via email or by posting notice on our website.
Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:We may use cookies and other tracking technologies to collect and store your information.

When you use our Products, we collect personal information and non-personal information (as discussed above) regarding that use. For example, to improve our Products, we collect how, when, and which parts of the Products or there features you use. Also, we may use your device’s unique identifier (UDID) or other unique identifiers to assist us in collecting and analyzing this data.

In order to assist us in collecting and storing non-personal information about your use of our website, including when you access our website on your mobile phone, we may employ a variety of technologies, including “Cookies,” local browser storage, and “web beacons,” “pixels,” or “tags.” A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website. A Cookie may also refer to web-browser-based storage provided by Adobe’s Flash plugin (a “Flash Cookie”). A web beacon, pixel or tag is a small, usually-transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a Cookie.

Your operating system and web browser may allow you to erase information stored in Cookies, Flash Cookies, and local browser storage. But if you do so, you may be forced to login to our website again and you may lose some preferences or settings. You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of our website may not function properly without it. We may use Cookies to keep you logged in, save your preferences for our website, and to collect information about how you use our website.

More information about managing Cookies is available at http://www.allaboutcookies.org. Cookie management tools provided by your browser may not affect Flash Cookies. More information about managing Flash Cookies is available at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.

Certain tools that we use may collect information automatically, in which case personal information and non-personal information received by the tools are subject to the tool provider’s privacy policy. Some tool providers may allow you to opt out of certain collection and/or uses of your information. You can read more here:

https://policies.google.com/privacy?hl=en_US

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only retain your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required by law (such as tax, accounting, or other legal requirements).

Unless we delete your personal information as provided in this privacy policy, when we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing (except as may be necessary for us to comply with a legal or regulatory obligation) until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented commercially reasonable and appropriate technical and organizational security measures designed to protect the security of any personal information we store or process. For example, we utilize Transport Layer Security (TLS) or similar encryption technology when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network. However, please also remember that we cannot guarantee that any data storage method or Internet connection is 100% secure. Although we try to protect your personal information, using or transmitting your personal information to or from any Product is at your own risk. You should only use the Products and transmit information to and from the Products within a secure environment.

We restrict access to personal information in our possession to our employees and service providers who need to know that information in order to operate, develop, improve or support our Products. If we share personal information with service providers, we require that they use reasonable information security measures to safeguard your personal information.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or promote our Products to children under 13 years of age.

We do not knowingly solicit data from or promote our Products to children under 13 years of age. By using the Products, you represent that (i) you are at least, 18 or (ii) you are the parent or guardian of a minor that you are providing information about and consent to such minor dependent’s use of the Products. If we learn that personal information from users less than 18 years of age has been collected without the consent of a parent or guardian, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 13 or believe that information from a minor has been collected without the consent or a parent or guardian, please contact us at support@HandsFreeHealth.com.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

You may request access to your personal information by sending an email to support@handsfreehealth.com. We will try to locate and provide you with your personal information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. You may also update or delete certain personal information from within the Products. However, we (and you) are not able to control information that you have already shared with other users or made available to third parties through the Products.

We ask users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your personal information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please be aware that if you request us to delete your personal information, you may not be able to continue to use the Products. Also, even if you request that we delete your personal information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

You can opt out of receiving e-mails promoting our Products from us by clicking on the “unsubscribe” link in the e-mails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Also, even if you opt out of promotional e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.

We may use third-party service providers that collect information for interest-based advertising purposes (advertisements that are tailored to your likely interests, based on categories in which you have shown an interest). To learn more about these third parties and the choices they offer users, please visit the Network Advertising Initiative’s choices http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance’s choices http://www.aboutads.info/choices/. You can learn more about the DAA’s mobile choices program http://www.aboutads.info/appchoices.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Some web browsers include a Do- Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to any mechanism that automatically communicates your choice not to be tracked when using a Product. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

10. YOUTUBE

WellBe Smart Speaker uses have the ability to stream music from YouTube via the YouTube API. By streaming music from YouTube on the WellBe Smart Speaker, you agree to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms). The WellBe Virtual Assistant App allows users to link their Google account to the WellBe Smart Speaker so that they can access their personal playlists and music library. Users can revoke access at any time by clicking the “Unlink” button on the Music Settings screen in the app or via the Google security settings page at https://security.google.com/settings/security/permissions.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. Yes, if you are a resident of Nevada, you have additional rights.

You may have heard of the California Privacy Protection Act which provides certain rights to California (CCPA) residents in connection with their personal information. Our Products are not currently subject to the CCPA. However, we do provide notice and transparency about our collection and use of personal information as described in this privacy policy.

Additionally, California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account for use with the Products, you have the right to request removal of unwanted data that you publicly post using the Products. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Products, but please be aware that the data may not be completely or comprehensively removed from our systems.

12. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws or to reflect changes to our operations.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes on our website. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at support@HandsFreeHealth.com.