Privacy Policy

vellum is an organizational health tool for fostering healthy habits, connecting individuals to the people around them, and linking to other support resources.

This Privacy Policy describes how Vellum Wellness, Inc. (“vellum”, “we”, “us” and/or “our”) handles the personal information that we collect from and about you in connection with our website, currently located at https://www.vellum.team (the “Site”); our mobile application (the “vellum App”); and all associated content, features, functionalities, user interfaces, and applications we may offer (collectively, our “Services”). This Privacy Policy also describes certain legal rights you may have, subject to applicable law, and how you can exercise them.

For the purposes of this Privacy Policy, “Personal Information” means information about an identifiable person, as defined by applicable law. This includes information that alone or in combination with other information may be used to identify, contact, or locate you, such as your name, address, email address, or phone number. It also includes information about your physical, mental, or psychological health, such as your responses to prompts about your feelings and mood which you may provide via the vellum App (“Check-in Information”). For the avoidance of doubt, Personal Information includes Check-In Information.

By using any of vellum’s Services, you confirm that you have agreed to the vellum Terms of Service and End User License Agreement, as applicable, and to the extent permitted by law, and have read and understood this Privacy Policy.

‍1. Information We Collect
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1.1 Information You Give Us Directly
‍Some information we collect directly from you. For instance, we collect information that you voluntarily provide in the following ways:

●  When you set up an account and populate your profile. When you download the vellum App and create an account, we ask you to provide a unique email address which serves as your username, create a password so we can authenticate you at sign in, and provide certain basic information about yourself such as your full name (first name, last name), and/or employer email address. Creating an account allows you to recover your data and log in on a different or shared device. We may also ask for a referral or access code which allows us to verify your affiliation with the employer who has provided you with access to the vellum App. We may offer you the option to add a profile photo and any biographical information (e.g., demographics, hospital, unit, role, etc.) you choose to your profile. Doing so is entirely voluntary and is simply offered as a way to personalize your account. If you choose to add this type of information, it will be visible to other vellum App users affiliated with your employer.

●  When you complete check-ins through the vellum App. When you complete a check-in via the vellum App, we collect any information you provide in connection with that check-in, including information about how you are feeling, your moods, your reflections, and personal notes. Check-in Information may be captured by selecting an emotion on the feeling wheel or by providing free-form written notes which can include any information you choose. If you wish, you have the option of sharing the emotion you chose on the feeling wheel and your written note with your co-workers. If you do decide to share, we let you decide how much and how broadly you want to share this information. For instance, you may share only the emotion you selected on the feeling wheel, or both the emotion and your accompanying written note. You can also choose whether you want to share this information only with certain co-workers or with your entire team and whether you want your name attached or not.

●  When you communicate with other vellum App users. We may offer you the ability to communicate with other vellum App users, including the ability to send direct messages or otherwise respond or react to your co-workers’ check-ins. To provide this functionality, vellum may receive some data regarding the communications, including the date and time of the message and the content of the communication. vellum will only use the contents of communications for customer services purposes (such as resolving disputes between users) and for safety and security purposes.

●  When you participate in surveys or research studies. We may contact you to ask if you would be willing to participate in a survey or research study. If you decide to participate, you may be asked to provide demographic information, feedback, and any other information relevant to that survey or study.

●  When you use certain app features. From time to time, we may request permission to access and collect information from certain aspects of your mobile device. For instance, we may ask for permission to access your device’s location which lets us remind you to check in when you arrive at work. We may also ask for permission to access your mobile device’s photo storage so you can upload profile photos. No information will be collected unless you explicitly agree to these permissions. We will never import files other than those you choose to upload and you can change the permissions you grant at any time using your device settings.

●  When you sign up to receive email communications from us, including newsletters or updates about programs and events we may offer. When you engage in one of these activities, we may collect your name, email address, and any additional information you choose to provide to us as part of that request.

●  When you contact us. When you contact us by email; through our branded social media accounts or customer support site; through any integrated chat providerswe may provide; or by telephone, SMS, or physical mail, we may collect your name, social media username (if applicable), email address, phone number, physical address, and the contents of your communication which can include any information you choose to provide.

‍1.2 Information We Collect Automatically When You Use Our Services

‍We also collect certain information automatically as you navigate our Services or interact with our communications, including the following:

●  Information about the devices you use to access our Services (including your internet protocol (IP) address, browser type, and operating system);

●  The address of the web page visited before and after using our Services;

●  Details about your interactions with our Services (such as the date, time, lengthof stay, and specific pages accessed during your visits);

●  Search terms used to reach our Services;

Usage information (such as the number and frequency of visitors to our Site);

●  Location information (such as GPS information or general location information inferred from your IP address); and

●  App Analytics (such as app launches, taps, clicks, scrolling information, screen visits, session durations, and crash reports)We collect some of the information above using cookies or similar technologies. A “cookie” is a small text file that websites send to a visitor’s computer or other internet- connected device to uniquely identify the visitor’s browser or device or to store information or settings in the browser/device. We, and our third-party service providers, use cookies in order to do things such as recognize you when you return to our Site, save your preferences (including your preferences regarding cookie handling), understand usage patterns, and improve our mobile applications. We use both session cookies (which expire when you close your browser or app) and persistent cookies (which stay on your device until you delete them or until they expire).If you do not want us to collect information through the use of cookies, you can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to the guidance offered by your chosen web browser if you would like help managing your cookie preferences. Please note that if you reject or block cookies, the Services may not work as intended.We also may partner with third parties who provide analytics services and serve advertisements on our behalf across the Internet and in mobile applications. These third- parties may use cookies and similar technologies to track your engagement with our Site as well as our online advertising and email marketing campaigns and permit us and them to analyze and track data, and do things like determine which advertising or marketing source brough someone to our Site and target advertisements to an audience based on prior browsing patterns on our Site.

‍Your Check-In Information is never shared with our third-party advertising and analytics partners.


1.3 Information We Collect from Other Sources

‍We may also obtain Personal Information from other sources. For instance, we may collect Personal Information about you from the following third-party sources:

●  Your employer. Your employer may provide us with certain information about you, including your business contact information and information relevant to your role, such as unit, schedule, and floor assignment information.

●  Another user. We may collect information about you from another vellum App user with whom you have interacted via our Services. This information may include Personal Information. We collect this information in order to maintain our high standards of inclusiveness and civility.We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.

‍2. How We Use Your Information
‍We use the information described above to do the following:

●  Provide our Services (including creating your account and identifying you when you sign in; managing your access to and use of our Services; fulfilling your requests and registrations; and sending you technical notices, updates, security alerts, and support and administrative messages);

●  Operate and improve our Services (including monitoring and analyzing usage, trends, and activities related to the Services and identifying, fixing, and troubleshooting bugs and service errors);

●  Communicate with you (including responding to your requests, inquiries, comments, and suggestions);

●  Conduct data analysis (including de-identifying and/or aggregating information and using it to perform research and provide statistical information and trend data)  

●  Personalize content (including tailoring content we send or display to you in order to provide you with information and resources we think will be relevant to you);

●  Further our networking, marketing, and social strategies (including posting testimonials; notifying you about programs, services, offers, promotions, and events; and promoting our programs and services);

●  Protect against, identify, investigate, and respond to misuse of our Services (including preventing and detecting fraud, unauthorized access, and other unlawful behavior);

●  Support our general business operations (including maintaining our business and legal record keeping); and

●  Carry out any other purpose described to you at the time the information was collected.

‍3. How We Share Your Information
‍We may share information about you with third parties in the following circumstances:

●  Companies under common control.
‍We may share Personal Information between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with vellum.

●  Vendors and service providers.
‍We may share Personal Information with vendors, consultants, and other service providers who need to access the data in order to perform services on our behalf, such as providing analytics services, website hosting, or cloud-storage services.

●  Your employer.
‍If you receive access to the vellum App through your employer, we may share de-identified, aggregate information and insights derived from your use of the vellum App with that employer to allow the employer to conduct further analysis and make organizational interventions to improve the staff experience. We contractually require the employer to agree that it will not attempt to re-identify the data and will not transfer the de-identified data to another party unless that party also agrees in writing not to attempt to re-identify the de- identified data.

●  Your co-workers.
‍Certain profile information (such as your name) and any information you elect to share about your check-ins may be visible to other vellum App users you work with (including your managers or other supervisory staff) for up to twenty-four (24) hours after you share it. We may also offer interactive features that allow you to connect with other vellum App users you work with in public or semi-public spaces. If you use these features, that information may be displayed and viewable by other vellum App users affiliated with your employer.

●  Advertising and Analytics Partners.
‍We may share your Personal Informationwith other third parties that provide online analytics and advertising services in order to better understand how individuals interact with our Services and other online services over time and across devices. However, we do not share Check- In Information with these partners.

●  Business transfers.
‍We may share Personal Information with another company in connection with or during negotiations of any merger, acquisition, financing, re- organization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.

●  Legal requirements.
‍We may share Personal Information when we believe it is necessary to comply with a legal obligation, including lawful requests from public authorities to meet national security or law enforcement requirements. We may also share Personal Information when we believe it is necessary to protect our rights and property, to protect the safety of our users, and to defend against legal liability.

●  Consent.
‍We may share Personal Information with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information.We may also share aggregate or de-identified information, which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations; for business or marketing purposes; or to assist third parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services.4. Your Rights and Choices
‍You have a variety of rights and choices related to our use of your Personal Information.●  Opting out of email marketing.
‍You can opt out of receiving our promotional emails at any time by following the instructions included in those emails. Please be aware that it may take up to ten (10) days for us to process your request, and you may continue receiving promotional communications from us during that period. If you opt out of receiving such communications, please be aware that we may continue to send you non-promotional emails (such as emails related to our business relationship or emails about changes to our legal terms).

●  Restricting cookies/Do Not Track.
‍vellum does not currently change its behavior in response to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consultthe help section of your browser to find out how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In the event that a universally accepted standard emerges on how organizations should respond to “do not track” or similar opt-out signals, we will assess and provide an appropriate response to those signals.

●  Access, update, or delete your information.
‍If you would like to access, update, or delete Personal Information you have provided you may do so through your account settings or by emailing us at privacy@vellum.team. To learn how to close your account, please contact us by email. Please note that we may keep certain Personal Information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also keep cached archived copies of Personal Information for a certain period of time.

●  Limiting information in your account.
‍You can control the information we collect about you by limiting what information you provide through your account. Please note that if you choose not to provide certain information it may make it difficult or impossible for you to access some services (for example, to register for a program).

●  Disabling push notifications.
‍With your consent, we may share push notifications or alerts to your mobile device. We use push notifications to send you reminders to check-in and to inform you of important updates. You can manage or deactivate these notifications at any time by turning off the notifications setting in the app or by disabling notifications through the device settings on your mobile device. If you choose not to receive push notifications, you may still receive certain in-app notifications.

●  Limiting device permissions.
‍From time to time, we may request permissions to access and collect information from certain aspects of your mobile device, such as your device’s photo storage. You can change the permissions you grant at any time using your device settings.

‍5.  Children’s Privacy
‍Our Services are intended for adults and we do not knowingly collect Personal Information from children. If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us Personal Information without your consent, please email us using the contact information below.

‍6.  Links to Other Websites and Third-Party Content
‍We may provide links to third-party websites, services, and applications that are not operated or controlled by vellum. This Privacy Policy does not apply to the privacy practices of those third parties. The fact that we link to a website, service, or application is not an endorsement, authorization, or representation of our affiliation with that third party. We encourage you to review the privacy policies of any third-party service before providing any Personal Information to or through them.

‍7.  Data Transfer
‍Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States where we are based or in any country where we have operations or where we engage vendors or service providers. These countries may not have the same data protection laws as the country in which you originally provided the data. By using our Services or submitting your Personal Information to us, you agree to such transfers.

‍8.  Data Retention
‍We only keep your Personal Information for so long as reasonably necessary for the purposes described in this Privacy Policy, as required by law, or as necessary to resolve disputes and enforce our rights and agreements. To dispose of Personal Information, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

‍9. Security
‍vellum uses generally accepted administrative, physical, and technical safeguards we believe are appropriate to protect the confidentiality, integrity, and availability of your Personal Information. Although we make reasonable efforts to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the internet and storing information electronically. vellum cannot and does not guarantee absolute security.

‍10. Changes to Our Privacy Policy
‍We may change this Privacy Policy from time to time to reflect changes in our practices or in the law. If we make changes to this policy, we will post the updated Privacy Policy on our website and indicate when it was last revised. You are advised to review this policy periodically to stay informed of our practices. If we make material changes, we may provide you with additional notice, such as posting a statement on our homepage or sending you an email notification, if we have your email address on file. Your continued use of the Services after the revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Policy, to the extent permitted by law.

‍11. Contacting Us
‍If you have any questions about our Privacy Policy or how we protect your Personal Information, please contact us at privacy@vellum.team or you may write us at 8520 Allison Pointe Blvd suite 223, PMB 27892, Indianapolis, IN 46250.