Introduction

Nothing is Obvious LTD, trading as WellStream, complies with the New Zealand Privacy Act 2020 (the Act) when dealing with personal information.  Personal information is information about an identifiable individual (a natural person).

This policy sets out how we will collect, use, disclose and protect your personal information.

This policy does not limit or exclude any of your rights under the Act.  If you wish to seek further information on the Act, see www.privacy.org.nz.

 

Changes to this policy

We may change this policy by uploading a revised policy onto the website.  The change will apply from the date that we upload the revised policy.

This policy was last updated on 18 October 2024.

 

Who do we collect your personal information from

We collect personal information about you from:

• you, when you provide that personal information to us, including via the website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products
• third parties where you have authorised this or the information is publicly available.

If possible, we will collect personal information from you directly.

 

How we use your personal information

We will use your personal information:

• to verify your identity
• to provide services and products to you
• to market our services and products to you, including contacting you electronically (e.g. by text or email for this purpose)
• to improve the services and products that we provide to you
• to bill you and to collect money that you owe us, including authorising and processing credit card transactions
• to respond to communications from you, including a complaint
• to conduct research and statistical analysis (on an anonymised basis)
• to protect and/or enforce our legal rights and interests, including defending any claim
• for any other purpose authorised by you or the Act.

 

Disclosing your personal information

We may disclose your personal information to:

• any business that supports our services and products*, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products
• a person who can require us to supply your personal information (e.g. a regulatory authority)
• any other person authorised by the Act or another law (e.g. a law enforcement agency)
• any other person authorised by you.

*A business that supports our services and products may be located outside New Zealand.  This may mean your personal information is held and processed outside New Zealand.

 

Disclosing metadata

Metadata is a set of data that describes and gives information about other data. We create and disclose metadata to better understand and improve mental wellbeing for you. One example of metadata that we create is statistics around the wellbeing of a group of people using our service e.g. the average mental wellbeing of Auckland in August.

We may disclose metadata when:

• your privacy and anonymity is protected
• we do not foresee that disclosure of the metadata will harm or compromise you
• no reasonable grounds exist that give cause to prevent disclosure of specific metadata.

 

Protecting your personal information

We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse.

We believe that your personal information and health information should be protected from unauthorized access to the fullest extent possible. To that end, we have implemented security measures to protect your personal information in line with the highest industry standards, including encrypting your personal information at rest on our hosted servers, encrypting your app data in transit, limiting access to and sharing of your personal information only for purposes of running our services and delivering our products to you.

WellStream does not sell member personal information

Our business model is to provide highly valuable product experiences and services to our members in exchange for membership fees. We do not monetize your identifiable health information or other personal information. In fact the terms of the WellStream EULA states that you own your personal data which is stored for you through the app. As such, we do not sell or disclose your health information or other personal information.

Accessing and correcting your personal information

Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information.  Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction.  If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

If you want to exercise either of the above rights, email us at hello@thewellstream.com.  Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).

We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.

Deleting your WellStream account and associated personal data

You may choose to delete your WellStream account and all personal information at any time. This is best achieved through the WellStream app and instructions for this process can be found here.

Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you post your personal information on the website’s comments section, or our social media pages, you acknowledge and agree that the information you post is publicly available.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information.  We suggest you review that site’s privacy policy before you provide personal information.

COOKIES

We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website.  You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.

 

CONTACTING US

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us at hello@thewellstream.com