PRIVACY POLICY

 

Delos Welltek Australia (“Delos,” “we,” “us,” or “our”), is committed to protecting your privacy and the data on the DARWIN™ app (the “DARWIN app”). To demonstrate this commitment, we have adopted this privacy policy (this “Policy”). The Policy is designed to help you understand generally how the DARWIN app collects, uses or discloses information about you. Your use of the DARWIN app is subject to this Policy and our Terms of Use; by accessing the DARWIN app you acknowledge and agree to accept this Policy, which we may amend at any time. If we update this Policy, we will post the updated Policy here. Any such changes will be effective upon posting. You should consult the “Privacy Policy” on the DARWIN app periodically.

The DARWIN Ecosystem is a wellness intelligence platform incorporating science-based technologies and solutions designed to enhance physical and emotional well-being in homes. DARWIN creates and maintains the natural environment in your home that is essential for enhanced health, wellbeing and performance. Based on the learnings gained from over 7 years with the foremost medical and scientific institutions in the world, the DARWIN platform monitors the health of your home to meet the needs of occupants

I. NOTICE OF OUR POLICY
This Policy tells you, among other things, what information we gather from you and why, how we may use or disclose that information, and how you can update your information.

Please read this Policy carefully, and feel free to contact us at [email protected] if you have questions about this Policy or if you would like to update information you have provided to us.

Please note that this Policy applies only to the DARWIN app, and not to any other application or website linked to the DARWIN app, including any social media websites linked to the DARWIN app, or any other interaction with Welltek. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites and application before you disclose any personal information to them.

II. WHAT TYPES OF INFORMATION ARE COLLECTED AND WHY?
Welltek may collect personally identifiable information or non-personally identifiable information through your use of the DARWIN app. Personally identifiable information (or personal information) is information that personally identifies you, such as your name, postal address and email address, and non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregated data about users of the DARWIN app. Information is collected in order to provide services to you, tailor services to you based on your preferences and display information to you about the environment inside your home, as well as to improve our services and offerings and for other general research purposes. Information can be collected if you submit it to us or it may be collected automatically through technology. The DARWIN app uses information it collects in order to recognize and identify the property, sensors and other appliances and products in your home, and collect data generated from those sensors and other appliances and products. We also may use your personal information to respond to your requests and provide support, to communicate with you, to provide updates to you about relevant products and services, and otherwise provide our products and services to you.

  1. Information submitted by you
    You may submit information to us when you use the DARWIN app.  For instance, you may submit information in order to authenticate your credentials and input your preferences including your name, email address, social connection (single sign on user option), log-in and password credentials created by you, additional users that may access the DARWIN app, your preferences, your favorites, your schedule, and other information you provide to help us customize our services for you and optimize system performance.
  2. Location Information You may submit location information, including your time zone and address, in your preferences and certain location information may be collected automatically by using the DARWIN app such as Internet Protocol address, street address (including city, state, territory and postcode), and the products and appliances in your home compatible with the DARWIN app. Time zone and location data is used to customize settings in your home, such as triggering dawn simulation and controlling other lighting timers. By registering and using the DARWIN app, you consent to such collection and use of this information.
  3. Device and environmental information collected automatically The DARWIN app recognizes devices in your home that you choose to connect to the DARWIN app and collects information about those devices to display the information to you so that you can better understand the environment inside your home. Whenever you select to activate devices via the DARWIN app, we automatically receive and record information on our servers, logs and databases from the DARWIN app or device(s). In particular, the DARWIN app is designed to allow you to connect various devices you choose to connect in your home (for example your lighting, HVAC system, and/or water filter) to the DARWIN app. While connected to the DARWIN app, these devices automatically report information to our servers, logs and databases (including information you may have provided when setting up the devices or the DARWIN app). For instance, if you connect an indoor environmental quality (“IEQ”) sensor to the DARWIN app and activate the IEQ portion of the DARWIN app, the IEQ data (along with other information such as applicable room, device name and location) will be transmitted and displayed to you via the DARWIN app. Specifically, your home contains sensors to help you monitor the environment in your home. Some information the DARWIN app collects from your sensors and displays for you on the DARWIN app if you activate this feature include temperature, relative humidity and air quality conditions, such as Particulate Matter 10, Particulate Matter 2.5, carbon dioxide, total volatile organic compounds, temperature and humidity.
  4. Use of Non-personal information and aggregated dataThe DARWIN app collects data about your use of the DARWIN app such as commands triggered and other DARWIN app usage metrics. Welltek may use non-personally identifiable information and anonymized, aggregated data to understand better how the DARWIN app is used, including average time spent using the DARWIN app and pages viewed, to provide users with customized services and information, and to gather other relevant statistics and information. Welltek collects this information to measure the use of the DARWIN app and to improve the content of the DARWIN app. Such information, and other information we derive from an individual user’s information, supports our continued research, and allows us to continue to grow and improve our services and products.
  5. Information collected by technology Welltek and its agents use technologies like cookies to help you use our services more easily and help us continuously improve the DARWIN app and our services. Personal and non-personal information that may be collected using such technologies may include IP addresses, time spent on the DARWIN app, location information and a user’s internet service provider. A “cookie” is a small data file that a website can send to your browser, which may then be stored on your hard drive to help the website “remember” information about you when you return to the website, such as your preferences for the website or account identifications. We use simple session based cookies for logged in users on the website linked to the DARWIN app to track active sessions. You may have the option of setting your browser to reject cookies; however, doing so may affect the performance of the DARWIN app or restrict the way in which we may provide our services to you.

III. HOW DOES WELLTEK DISCLOSE MY INFORMATION?
We may share non-personal and aggregated information we collect from the DARWIN app in a manner permitted by law including to our affiliates and other companies with whom we conduct business.

We may disclose your personal information to our affiliates and other entities and individuals we engage to perform functions on our behalf and to help us to operate the DARWIN app and our business and deliver our services to you, or we may disclose information if you consent to such disclosure. Some of these other entities and individuals may include technology and other consultants, attorneys, accountants, clerical staff, website or database hosting companies, service and technical support companies, analytics companies, e-commerce providers and financial institutions (for the purpose of processing credit card transactions in the event you make a purchase from the DARWIN app). These entities and individuals will have access to your personal information to the extent necessary to perform services on our behalf. Some of these service providers may be located in countries outside of Australia, including the United States, the European Economic Area and India.

We may also disclose your personal information if legally required to do so, if requested to do so by a government entity, or if we believe in good faith that such action is necessary to conform to legal requirements or comply with legal process, protect the rights or property of Welltek, prevent a crime, or protect the integrity of the DARWIN app and personal safety of our users or the public.

We may also disclose and transfer your personal information to a third party who acquires any or all of our assets, whether by way of acquisition, merger, consolidation, or purchase of all or a substantial portion of our assets. In addition, in the event Welltek becomes the subject of an insolvency proceeding, whether voluntary or involuntary, Welltek or its liquidator, administrator, receiver or administrative receiver may sell, license, or otherwise dispose of such information in a transaction approved by the court.

IV. HOW CAN I OPT-OUT OF RECEIVING EMAIL COMMUNICATION?
We may email you in order to notify you of changes or offer you services we think you may be interested in. We will not send unsolicited messages to you if you indicate that you do not wish to receive such messages. However, if you, as a user, do not want your personal information used as otherwise detailed in this Policy, then you must not use the DARWIN app.

V. SECURITY
The security of your information is important to us, and we endeavor to protect your personal information. However, there is no such thing as perfect security on the Internet, and you provide personal information to us at your own risk. Welltek expressly disclaims all liability for any damages, losses or claims of any kind relating to any personal information that you provide to us or others through the DARWIN app. When you use the DARWIN app, we encourage you to protect your information and use precautions, including but not limited to, using strong passwords and not sharing your password and account information with any other person.

VI. INFORMATION REGARDING CHILDREN
This DARWIN app is not directed to children (persons under 15 years of age), and Welltek does not knowingly collect any personal information from children. If a child under 15 has provided personally identifiable information to us through the DARWIN app, a parent or guardian may inform us at the address for notices below, and we will use commercially reasonable efforts to delete it from our database, subject to applicable law and this Policy.

VII. HOW CAN I UPDATE MY INFORMATION, ASK A QUESTION OR ISSUE A COMPLAINT?
You can always update your account information or correct information you provided through profile settings in the DARWIN app, and if you require further assistance, please visit delos.com.au/support. To ask any questions or submit a complaint about this Policy and information handling, please contact us at [email protected], 1-3000-DELOS.

Last Updated: 28 September 2018