Privacy Policy

Panasonic Well LLC is the provider of the Umi suite of services, which we created to help families wellness as a team. This Privacy Policy ("Privacy Policy" or "Policy") explains our practices regarding the collection, use, and disclosure of information that we receive when you are logged in to your account and using our services on our websites (well.panasonic.com, www.joinumi.com) (the "Sites"), our mobile applications, including Umi Coach and others that we may develop (the "Apps"), and our communications with you (collectively, the "Services"). It also serves as a way to help you understand and exercise your privacy rights.

Revisions to the Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them within the Services or by sending you an email or other notification, and we’ll update the “Last Updated” date above to indicate when those changes become effective.

Scope of the Privacy Policy

This Privacy Policy applies to all users of our Services including without limitation, account holders and App users, admins and non-admins (as applicable) (all such users of the Services collectively referred to as “Users”).  This Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our Services. Nor does this Privacy Policy apply to the public pages of our Sites, which each have their own privacy policies. 

What Information We Collect

This section describes the different types of “Personal Data” (information about or related to you that could be used to identify you) which we may collect or obtain.

Information that You Provide Directly 

• Sign Up Information: When you sign up to create an account, we may collect and retain certain Personal Data, including, in the case of account creation: your full name, email address, date of birth, phone number, residential address, and account profile photo. 

• Profile Information: In the course of creating and building out your profile within the Services, there may be a wide range of information that we collect when you provide it to us, including for instance, your family size, names of your family members, your personal or family health and wellness goals, tasks you’re trying to accomplish, your health and wellness routines, your height and weight, photos you may provide, and reflections on your health and wellness journey.

• Through Use of the Services and Communicating with Us: You may provide information to us when you use the Services, for instance, photos you may choose to upload, text or audio or video messages you send to or through the services, tasks and goals you choose to share. You may also provide information when you contact us, respond to surveys, or provide feedback about the Services. This information may include your name, email address, phone number, address, order payment information, and other information that may relate to you or identify you. We collect any information you choose to provide to us when you are using the Services, when you send us emails with queries or feedback, or when you communicate with us for any other reason. 

• Through Interactive Features: If you use any of our interactive features, such as messaging between Users, comment features, or social features, we will collect information that you might submit or make available. Information that you provide through public sharing features of the Services will be considered public, except where contrary to applicable law.

• Contact Information of Others: If you choose to share the names or contact information of other individuals with us, for example if you are using a referral feature or a friend finder feature, or inviting a family member to join, we will collect and retain that information that you provide. Please only share the contact information of close friends and relations to you, or of others who have consented to such sharing of their information. 

Information Collected Automatically

• Information Sent by Your Device: We collect certain information that your mobile device, laptop, or other hardware device sends when you use our Services, including but not limited to IP Address, user agent information, network and connectivity information, device identifiers, advertising identifiers, language preferences, user settings, software and operating system names and versions, hardware models, as well as other information about your use of our Services. You may also choose to enable certain settings or permissions on your device that allows our Apps to receive data that your device collects about you, including, but not limited to, your precise location, health and activity permission, calendar access permission, camera permission, bluetooth permission, network state, microphone permission, photo and video library permission, notifications, and OS-level identity verification services. 

• Health and Activity Data: If you use the health and activity tracking apps provided by Google or Apple on your mobile device, you will have the choice in some of our Services, via a device level permission, to share that health and activity data tracked by that app. The extent of the data that can be shared will be visible to you when your operating system presents you the choice around that permission, but could include for instance, daily steps, activity types, heart rate and blood pressure, and a variety of other health information. If you choose to share this data with us, the data collection will be ongoing until you change the permission.

• Calendar Data: If you choose to connect external calendars - for example a Google or Outlook calendar - to the Services, we will collect information from that calendar account, such as event names and dates and time, meeting notes, attendees, and other related information. Sharing your calendar with us may also grant us the ability to add, delete, or modify events on your calendar. More information is presented to you at the time of this selection, and our third party vendor that facilitates calendar integration will also have access to the same information you choose to share with us.

• Location Information: When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location, by requesting precise location through your browser settings, or, when interacting with our mobile application, by accessing your mobile device’s GPS or location services, which may provide more precise geolocation information, if you enable location services on your device. 

• Information Collected Using Cookies and other Web Technologies: We use tracking technologies like cookies, web beacons, and pixel tags (together, “cookies”) to provide, improve, protect, and promote our Services. For example, cookies help us remember your preferences, understand how you interact with our Services, and improve them based on that information. We may also use third-party service providers - e.g. payment processors - who set cookies and similar technologies to when you are on our Services or on other devices, apps, websites, or in the emails you may receive from them. You can learn more about how cookies and other tracking technologies work, as well as how to exercise control over cookies in our Cookie Policy.

• Interaction and Inference Data: We collect information about the way you use our Services, such as actions you take in your account and the way you use our Sites and mobile Apps and generate and store inferences about you from interaction data and your Personal Data in general, such as purchase preferences, the types of services or activities you may enjoy, or your health and wellness goals and progress. 

Information Collected from Third Parties

• Information From Third Parties: We may also obtain information about Users from third parties, including but not limited to family members, affiliates, joint marketing partners, lead providers, fraud and risk mitigation vendors, and identify verification services.

How We Use Your Personal Data

Our primary goals in collecting information are to provide and improve our Services, to customize content and the Services for you, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and easily navigate our Services. We will use your Personal Data for the following purposes:

• To Provide and Personalize Our Services. We use your Personal Data to provide and personalize our Services. For example, we use your payment information to process your subscription payments, as well as any payments you may make to third parties. We also use and analyze your information to tailor our Services, such as personalizing the content and features users interact with when using our Services, developing our algorithms, and generally improving the Services we offer.

• To Understand, Troubleshoot, and Fix Issues with the Services. We may use your Personal Data – such as feedback you provide or bugs that you report to us – to identify and troubleshoot issues and make sure our Services are working properly.

• To Evaluate and Develop New Features, Technologies, and Improvements to the Services. We use your Personal Data to better understand how you use our Services, as well as  your interests and preferences, and to develop new features and technologies that we think might benefit you or other users. For example, we may use your Personal Data to conduct research and development related to the features you and other Users would like to see in our Services.

• To Communicate with You. We use your Personal Data to communicate with you, provide customer service, respond to your communications and requests, and contact you about your use of our Services. For example, we may contact you about changes to your account, such as confirmation of payment, upcoming subscription renewals, or cancellations.

• To Promote the Services. We will occasionally send you news about features, upgrades, and promotional offers related to our Services that may be of interest to you. These communications may be by various methods, including email, in-product notifications, and push notifications. Please see the “Your Choices” and “Your Privacy Rights” section below to learn how to set or change your communications preference.

• To Protect You, Others, and Our Business. We use your Personal Data to protect you, others, and our business, including (a) detecting, investigating, and preventing spam, fraud, and other abusive behavior; (b) enforcing our Terms of Service and other policies; and (c) protecting our systems from malware and other security risks.

• To Comply with Our Legal Obligations and Law Enforcement Requests. Our Services are subject to certain laws and regulations which may require us to process your Personal Data. For example, we may process your Personal Data to fulfill our contractual obligations with third parties; establish, exercise, or defend legal claims; or respond to requests from law enforcement.

• To Further our Legitimate Business Purposes. We may also use your Personal Data to further our legitimate interests and business purposes, such as conducting business planning and analysis, auditing, reporting, and forecasting.

• To Carry Out Your Instructions. We may also use your personal data for other purposes to which you have consented.

• Limits on Use of Your Google User Data. Notwithstanding anything else in this Privacy Policy, if you provide us access to your Google Calendar data, our use of that data will adhere to the Google API Services User Data Policy and will be subject to these restrictions, as required by Google:

  • We will only use our access to read, write, or modify your Google Calendar data to perform the specific services that you request from us (for example, scheduling or canceling an event on your calendar, looking for free time on your calendar), and we will not transfer the Google Calendar data to others unless doing so is necessary to perform such services, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
  • We will not use this Google Calendar data for serving advertisements.
  • We will not allow humans to read the Google Calendar data unless doing so is necessary to perform the services or tasks that you’ve requested of our specialists or guides, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized.

We may use Personal Data and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, or de-identified information about the device from which you access our Services.

We may also use your information for any other purpose disclosed to you at the time we collect or receive your information, or otherwise with your consent. 

Information that We Share with Third Parties

We may share information you provide us, including your Personal Data, with third parties, in the types of scenarios, and for the types of reasons described in this section.

• Service Providers and Business Partners: We may engage third-party service providers to help us administer, provide, and improve the Services, including but not limited to the following types of partners: third party financial financial institutions and financial services companies, web hosting providers, third party software vendors, data integration partners, cloud hosting providers, fraud detection services, identity verification services, fulfillment service providers, and customer support partners. For example, we may share your Personal Data with a cloud hosting provider (for example, Amazon Web Services) as part of our utilization of their hosting services.  These third-party service providers will have access to your Personal Data for the purpose of performing services on our behalf. 

• At Your Request: We may share information about you with third parties in the event that you request we do so, for example, with other Users or groups of Users or the public if you request that or if, for instance, you use a feature that performs that type of sharing function. Similarly we may share information about you with companies offering complimentary services, promotions, or offers through our Services, if you request, or consent, that we share your information.

• Other Third Parties: We may share de-identified or aggregated data we collect from the use of the Services, including but not limited to de-identified or aggregated: transaction or investment  information, location information, information about the computer or device from which you access the Services, market trends, and other analysis that we create based on the information we receive from you and other Users. 

• Our Subsidiaries and Affiliates: Panasonic Well shares infrastructure, systems, technology, and data with its Corporate Affiliates for a wide range of purposes, including to provide, improve, protect, and promote our and their products and services. “Corporate Affiliate” means a company or other business entity that is controlling, controlled by, or under common control with Panasonic Well LLC, including companies within the Panasonic Holdings Corporation worldwide group. We reserve the right to share your data with our current and future Corporate Affiliates as permitted by applicable law and in accordance with their terms and policies.

• With Your Consent: There may be other circumstances where we will notify you of information that we seek to share with a third party not listed here, and will do so with your consent.

• With Your Family Members: If you invite others to use the Services alongside you within a “family,” or if you are invited to join a family within the Services (and you accept), we may share your Personal Data with other members of your “family” group.  

• Information Shared with Web Analytics Services Providers: We may use some or all of the following analytics services:

  • Google: We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how Users engage with our Services. For more information about Google Analytics, please visit this page. You can opt out of Google’s collection and processing of data generated by your use of the Services by going here.
  • Mixpanel: We use a service provided by Mixpanel, Inc. (“Mixpanel”) to provide us with analytics data regarding Users’ interactions with our Services. You may opt-out of Mixpanel’s automatic retention of data that is collected while using the Services by visiting this page. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.
  • Segment: We use a service provided by Segment, Inc. (“Segment”) to provide us with analytics data regarding Users’ interactions with our Services. You may opt-out of Segment’s automatic retention of data that is collected while using the Services by visiting this page. To track opt-outs, Segment uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Segment opt-out cookie.
  • Microsoft: We also use Microsoft Clarity, a service provided by Microsoft, Inc. (“Microsoft”), to gather information about how Users engage with our Services. For more information about Microsoft Clarity, please visit this page. You can opt out of Microsoft’s collection and processing of data generated by your use of the Services by running the DAA analytics tool here and selecting the opt out function next to “Microsoft.”

• Information Disclosed in Connection with Business Transactions: We may share your Personal Data with third parties (including Corporate Affiliates in connection with a corporate reorganisation, merger, transfer, change of control, sale, joint venture, acquisition of all or a portion of our business by another company, assignment or other disposition of all or any portion of Panasonic's business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

• Information Disclosed for Our Protection and the Protection of Others: We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

• With Advertising Partners and Social Media. Your Personal Data may be shared with certain advertising partners who conduct or assist us with marketing, as well as advertising and social media partners who we allow to place cookies (or similar technology) in our Services as necessary to their provision of various services, including but not limited to ad attribution, ad placement, audience measurement, social sharing, and site analytics.

Your Privacy Rights

Based upon the laws that apply in your jurisdiction, you may have some or all of the following rights, related to your privacy and Personal Data. Please note that, for each of the rights below, we may have valid legal reasons to decline your request. In such instances, we will let you know if that is the case. To inquire about or to exercise any of these rights, you may contact us at privacy@well.panasonic.com. We will process such requests in accordance with applicable laws.

• Access: the right to access Personal Data about you, including: (i) confirming whether we are processing your Personal Data; (ii) obtaining access to or a copy of your Personal Data; and (iii) receiving an electronic copy of Personal Data that you have provided to us, or asking us to send that information to another company (the “right of data portability”);

• Correction: the right to request correction of your Personal Data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Data;

• Deletion: the right to request deletion of your Personal Data; 

• Objection: the right to request restriction of or object to our processing of your Personal Data; 

• Withdraw Consent: the right to withdraw your consent to our processing of your Personal Data;

• Portability: the right to receive a copy of your Personal Data in a portable format that would allow you to share it with another service provider; 

• Opt Out Rights: the right to opt out of the sale or sharing of your Personal Data to certain third parties, as well as the right to opt out of targeted advertising and profiling that may impact your legal rights; and

• Non-Discrimination: the right to not be discriminated against in response to your choice to exercise your rights related to your Personal Data

Your Choices

We offer you choices regarding the collection, use and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

• Device Permissions: There are various device permissions that our Apps may request, including for instance, precise location, health and activity permission, calendar access permission, camera permission, bluetooth permission, network state, microphone permission, photo and video library permission, notifications, and OS-level identity verification services (e.g. TouchID). You are free to allow, disallow, or revoke any of these permission requests at any time, however some features of the Services may not function properly without the permission being granted. 

• Opt-Out of our Mailings: We may periodically send you free newsletters and emails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (by following the unsubscribe instructions provided in the email you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Use or this Privacy Policy or information about billing.

• Cookie and Ad Tracking Choices: You can opt out of the collection and use of your information for ad targeting by going here or here or here to limit collection through the Sites, by configuring the settings on your browser, by setting preferences in the cookie consent manager service on our Sites, or by using cookie blocking extensions in your browser (such as Privacy Badger or Ghostery). 

• Modifying Your Information: You can access and modify the Personal Data associated with your account by sending an email to privacy@panasonic.com. If you want us to delete your Personal Data or your account, please contact us at privacy@panasonic.com with your request. We’ll take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

• Mobile Device Notifications. We may send you push notifications through our Apps. You may opt out of receiving these notifications by changing the settings on your mobile device. 

• Additional Choices: As discussed elsewhere in this Policy, additional choices may be available to you under the laws and regulations of other jurisdictions.

Responding to Do Not Track Signals

Due to a lack of an agreed upon standard for interpreting Do Not Track (DNT) signals, our systems currently do not respond to DNT signals from browsers visiting our Sites. Please note that cookie-based opt-outs are not effective on mobile applications

The Security of Your Information

We implement reasonable physical, technical, and organizational measures designed to help safeguard your Personal Data against loss, theft, unauthorized access, use, and modification.  However, please note that no system is ever completely secure, and we cannot guarantee the security of our systems 100%.

Data Retention

We need to retain the information you provide us in order to provide our Services, and we may retain such information until you request deletion of your account, subject to the provisions of this section. We also retain certain relevant information, including transaction, location, device, and usage information, for as long as it is required to do so, in connection with regulatory, tax, insurance, legal, administrative, and other requirements. You may request deletion of your account at any time as provided above. Following such a request, we will delete the information that it is not necessary to retain. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit or debt on your account or an unresolved dispute, ongoing investigation (e.g. for fraud or misuse), or we believe that we may be required to retain your account for legal reasons. Upon resolution of the issue preventing deletion, we will delete your account as described above. We may also retain certain information if necessary for our legitimate business interests, such as fraud prevention and enhancing Users' safety and security. For example, if we shut down a User's account because of security or fraud incidents, we may retain certain information about that account to prevent that User from opening a new account in the future.

Links to Other Sites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

Processing Information in the United States

We are headquartered in the United States and may use service providers that operate in other countries. Your Personal Data may be transferred to, and maintained on, computers located outside of your state, province, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We strive to safeguard your information consistent with the requirements of applicable laws by taking reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you from unauthorized access, use, or disclosure. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Our Policy Toward Children

Our Services are not intended for children under 13 years of age, and we do not knowingly collect Personal Data from children under 13. If you are a parent or guardian of a child under 13 and become aware that your child has provided Personal Data to us without your consent, you may review and request deletion of your child’s Personal Data by contacting us at privacy@well.panasonic.com if you are a U.S. resident. If we learn that we have collected Personal Data from a child under 13, we will take reasonable steps to delete that Personal Data.

Privacy Notice for California Residents

If you are a California resident, you have certain additional privacy rights under the California Consumer Privacy Act of 2018, as modified by the California Privacy Rights Act of 2023 (“CCPA”). Those rights are all discussed in this Privacy Notice for California Residents section of our broader Privacy Policy.

Your Rights Under the California Consumer Protection Act

The following rights (in this section) are available  to California residents. While the term “Personal Data” is used in this section, for the purposes of this section that term is intended to align with the definition of “personal information” within the CCPA.

• Right to request disclosure of information collected. You have the right to request details on the specific Personal Data we’ve collected about you during the past 12 months. We provide detailed information about the types of  information we collect throughout this broader Privacy Policy, but you may also contact us directly to inquire about your Personal Data specifically, as described in this Privacy Notice for California Residents section.

• Right to request disclosure of information shared or sold.  We do “share” (within the meaning of that term in the CCPA) certain Personal Data about some of our Users with our advertising service providers, in connection with our use of third party adtech cookies on the Sites. This sharing is outlined in this broader Privacy Policy. And you do have the right under CCPA to contact us at any time, as described in the section below, to request this information from us.   

• Right to opt out of selling of your Personal Data.  As stated above, we do “share” (within the meaning of that term in the CCPA) certain Personal Data about some of our Users with our advertising service providers, in connection with our use of third party adtech cookies on the Sites. In order to opt out of that sharing, you can utilize our cookie consent manager or contact us at privacy@well.panasonic.com.

• Right to request deletion of data.  You have the right to request deletion of your data, unless an exception applies. Examples of exceptions include when we need to keep data to meet legal obligations, detect fraud, investigate reports of abuse or other Terms of Use violations, or fix security issues. Additionally, an exception would apply if we would be unable to provide the services that you signed up for without the data, in which case, you are free to request account deletion and cease use of the services. See more about this throughout the broader Privacy Policy. Once we’ve verified your request, we’ll delete your Personal Data (unless an exception applies) and will direct our service providers to do the same.

• Timely response. You have the right to make two free requests in any 12-month period. We will respond to your request within 45 days, and in more difficult cases we may extend our response time by another 45 days. 

• Non-discrimination. You are entitled to exercise the rights described above free from discrimination. We will not discriminate against you because you exercise your rights. For example, we will not deny you any goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights under the CCPA. 

Contacting Us (CCPA Purpose)

To make any inquiries, request, or exercise any of your rights granted under California Consumer Protection Act, you can contact us by email at privacy@well.panasoni.com. Please state whether you are a California resident in that communication. We may need to go through a few verification steps after you reach out, but we’ll help you through that. If you are a resident of California, an authorized agent may make a verifiable consumer rights request related to your personal information. If you are an authorized agent making a request on behalf of a consumer, you must provide us with signed permission by the consumer that you are authorized to act on behalf of that consumer. If you are a legal entity, you must also provide us with documentation of your registration with the California Secretary of State.

Information We Collect (CCPA Required Disclosure)

As we address throughout this Privacy Policy, we collect Personal Data for a range of purposes, though primarily to enable us to provide and improve our services. In the last twelve months, we have collected the following types of Personal Data about our Users. In some cases the data is provided directly by Users. In other cases it was provided by third parties, or obtained through User interaction with our services.

• Identifiers, such as your name, email address, IP address, username, or other similar identifiers. We primarily use these identifiers to create your account, maintain security of our services, and communicate with you. 

• Customer records information, such as social security number, government ID, signature, passport information, telephone number, bank account number, credit card number, or debit card number. We primarily use these types of information to facilitate transactions and payments and to communicate with our Users. (This category under CCPA overlaps with other categories.)

• Characteristics of protected classifications under California or federal law, such as your gender, race, or age, or other potentially sensitive categories of information that you choose to disclose in the course of interacting with our Services. We primarily use this information to provide the services and understand our user base.

• Commercial information, such as payment history and purchase history. We primarily use this type of information to keep track of User transactions and for internal business and financial recordkeeping. 

• Internet or other electronic network activity information, such as session logs, search history, information about your  interaction with a website, application, or advertisement. We primarily use this type of information to help understand how our services are performing, as well as to improve our own understanding of our services. 

• Geolocation information, such as your IP address which provides a rough approximation of location, or from your mobile device’s GPS or location services, if you use an App and enable location services. We use this data primarily to understand where Users  are accessing the services, and in some cases to provide more relevant recommendations and advertising.  

• Audio, electronic, visual, or similar information, such as audio or photos or videos that you may upload or provide in the course of using the Services. We primarily use this information to provide the core Services and custom your experience of the Services.

• Professional or employment-related information, such as the type of work you do, if you choose to provide it. We primarily use this type of information to offer more customized services and recommendations.

• Inferences, such as your purchase preferences, the types of services or activities you may enjoy, your health and wellness goals and progress. We primarily use this type of information to provide the core Services and customize our recommendations for you.

Information Sharing (CCPA Disclosure) 

In the past 12 months, we’ve disclosed the above categories of information for business purposes, or at your direction, with our service providers, affiliates, and other third-parties. For instance, we share Personal Data about our Users with our data hosting and storage providers. For more details please refer to the section above entitled Information That We Share with Third Parties. We have agreements with our service providers which limit their ability to use your information and require them to ensure its confidentiality.

Updates to this CCPA Section of the Privacy Notice for California Residents

We will update this Notice every 12 months and let you know when we’ve made updates, consistent with our Privacy Policy. 

Privacy Notice for European Users

We are providing this supplemental privacy notice to European data subjects (including Users in the EEA, UK, and Switzerland), pursuant to European data protection laws including the General Data Protection Regulation (“GDPR”). Panasonic Well LLC is the controller of your Personal Data. This means that Panasonic Well LLC is responsible for how your Personal Data is handled. And we encourage you to review the remainder of this section to understand the bases upon which we process Personal Data as well as the rights afforded to you.

Bases for Processing of Personal Data 

Pursuant to the GDPR,  we may process Personal Data under only the following conditions:

Rights Under the GDPR 

Where the GDPR applies, you have rights in relation to the Personal Data we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request. In such instances we will let you know if that is the case. To inquire about or to exercise any of these rights, you may contact us at privacy@well.panasonic.com.

• Access: You have the right to know whether we process Personal Data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

• Portability: You have the right to receive a subset of the Personal Data you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party. If you wish for us to transfer the Personal Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party.

• Correction: You have the right to require us to correct any Personal Data held about you that is inaccurate and have incomplete data completed. When you request correction, please explain in detail why you believe the Personal Data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the Personal Data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

• Erasure: You may request that we erase the Personal Data we hold about you in the following circumstances: where you believe it is no longer necessary for us to hold the Personal Data; we are processing it on the basis of your consent and you wish to withdraw your consent; we are processing your data on the basis of our legitimate interest and you object to such processing; you no longer wish us to use your data to send you marketing; or you believe we are unlawfully processing your data. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please know there may be some types of Personal Data that we are required to retain for legal, regulatory, or accounting reasons, or other legitimate interests.

• Restriction of Processing to Storage Only: You have a right to require us to stop processing the Personal Data we hold about you other than for storage purposes in the following circumstances: you believe the Personal Data is not accurate for the period it takes for us to verify whether the data is accurate; we wish to erase the Personal Data as the processing we are doing is potentially unlawful but you want us to simply restrict the use of that data; we no longer need the Personal Data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or you have objected to us processing Personal Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Personal Data while we determine whether there is an overriding interest in us retaining such Personal Data.

• Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.

• Withdrawal of Consent: Where you have provided your consent to us processing your Personal Data, you can withdraw your consent at any time by emailing us at the address above in this section.

Complaints and Questions

If you’re based in the EU, you can always file a complaint with the supervisory authority in your Member State. That said, we’d encourage you to reach out to us directly first (at privacy@well.panasonic.com ) so we can try to assist you with your questions or help you exercise the rights you’re seeking to exercise.

Privacy Questions

We know issues of privacy and data protection are complex. But we’re here to help in any way we can. So please contact us, via email (below) if you have any questions about your Personal Data, our data practices, or this Privacy Policy. 

Panasonic Well LLC

3460 Hillview Ave.

Palo Alto, CA 94304-1338.

privacy@well.panasonic.com