Website Privacy Policy

This Privacy Policy explains how your Personal Information may be collected, processed, or disclosed when you visit our website www.wehealth.org (the “Site”). Our goal is to offer an effective contact exposure notification solution while preserving individuals’ privacy. This Site is where we keep information about our company and the mobile application (the “App”) we created to help users discover if they may have come into contact with the coronavirus.

This Privacy Policy describes our practices on our Site only to keep things clear. If you would like information about how the App collects data:  Access the Covid Watch Arizona App Privacy Policy via the AZHDS website. 

Access the WeHealth Bermuda App Privacy Policy below. 

What Data We Collect and How We Use It

When you use or visit our Site, we may collect information that could identify you directly or indirectly (“Personal Information”). Personal Information does not include publicly available information in government records or any data that has been deidentified, aggregated, or otherwise anonymized.

  • Sign up for Newsletters: If you’d like to receive periodic updates and subscribe to our newsletter, we will collect your email address. You may always unsubscribe from newsletters by following the “unsubscribe” link on the bottom of the email.
  • When you Contact Us: If you email us, we may collect your name, email address, and information related to your request, question, or other inquiry.
  • Data from Cookies: Our Site uses cookies to collect usage and analytics data to improve the Site. A cookie is a small piece of code placed on your website browser, device, or hard drive when you visit a website or use an application. You may control Google analytics by visiting Google’s website. For more information on how you can customize your browser’s cookie setting please visit the link to your web browser below:
    • Chrome
    • Safari
    • Internet Explorer
    • Firefox

When We Share Data

Besides us, the only other parties that usually have access to your Personal Information are our service providers and vendors who help the Site function and make our business work.

For example, we use a service provider to support our email communications and a payment processing vendor to process your payment information if you make a donation.

We do not share your Personal Information with third parties for their direct marketing purposes. 

Under certain circumstances, we may need to disclose your Personal information to:

  • Prevent, investigate, or provide notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, our Site, App, or data systems;
  • Comply with federal, state, or local laws;
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
  • Cooperate with law enforcement agencies about conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
  • Protect or defend against legal actions or claims; or,
  • Transfer Personal information as part of an actual or proposed organizational transaction, such as a merger or dissolution, or in the event of insolvency, bankruptcy, or receivership.

How to Control Your Information

Under certain circumstances, you may have the right to access or correct your Personal Information by contacting us at contact@wehealth.org.

If you signed up for newsletters and wish to opt out, you can always unsubscribe by following the “unsubscribe” link at the bottom of any messages, or by contacting us at contact@wehealth.org.

You may control Google analytics by visiting Google’s website. You may control cookies by visiting the link to your web browser below:

  • Chrome
  • Safari
  • Internet Explorer
  • Firefox

What if You Share Content on Third-Party Apps or Websites?

Our Site allows users to share information through other third-party websites and applications. These links are provided solely as a convenience to you if you share content.

When you visit third-party websites or applications, those third parties may collect your Personal Information along with all content you share. We do not control those websites and applications, and we are not responsible for how they may treat your information. We encourage you to check the privacy policies and terms of those websites and applications to learn more about their practices.

 

Data about Children

The Site is not intended for children under 13. We do not knowingly collect Personal Information from children under 13. If we discover we have collected Personal Information from a child under 13 we will delete it. If you are the parent or legal guardian of a child under 13 and you find out your child has been using the Site without your permission please contact us at contact@wehealth.org.

 

Changes to this Privacy Policy

Our company is growing and expanding its service offerings, and this Site is undergoing development. That means this Privacy Policy may change as those developments are implemented. If any changes to this Privacy Policy are material, we will use reasonable means to notify you. This Privacy Policy was last updated on 20 October, 2020.

Privacy Policy for the use of the WeHealth Bermuda Exposure Notification App in Bermuda:

WeHealth is a Public Benefit Corporation based in California and founded in 2020 in response to the Covid-19 pandemic. The WeHealth team has very broad industry experience, and has combined their deep expertise in public health, technology, and design to bring impactful technology solutions to market, including exposure notification apps such as Covid Watch and the WeHealth Bermuda app.

Wehealth has developed an Exposure Notification application (the “App”) technology to help people notify app users if they have potentially come in contact with someone who has tested positive for COVID-19 without having to share your Personal Information. 

Their goal is to preserve your privacy, so contacts exposed to the SARS-CoV-2 virus can be notified without divulging your identity or giving up your rights. This App was built in direct collaboration with CovidWatch.org (now branded “WeHealth”) that built the App technology. 

The Bermuda Health Ministry is now making this service available in Bermuda for residents and visitors.

 This Privacy Policy explains how the App works, how data is treated, and what you can do to protect your privacy while helping slow the spread of COVID-19 and save lives. 

What Data Does the App Collect? 

When you use the App, the App does not collect any Personal Information about you. By Personal Information, we mean information that could be used to identify you. 

  • Random IDs: 
    • The App pairs with the Apple-Google Exposure Notification technology. 
    • This means you must first make an explicit choice to turn on the technology on your iPhone or Android phone for the App to work. 
    • If you have enabled the technology, your phone will generate a random sequence of numbers every 10-20 minutes. 
    • Random IDs are not tied to your location or identity. 
    • The only time Random IDs are collected is if you choose to report that you tested positive for COVID-19. 
  • Potential Exposure Data (Date, Duration, Signal Strength): 
    • Exposure checks and logs of nearby Random IDs are stored locally on your phone for 30 days for the purpose of being able to give you recommendations regarding next steps you can take if potentially exposed. 
    • Exposure notifications will remain visible on the app for 14 days 
    • To preserve privacy, the “Date” has no hour, minute or second component; the “Duration” is limited to 30 mins. 
    • This Potential Exposure Data stays on your phone unless you choose to delete and no longer use the App. 
  • Diagnosis Data (Verification Code, Symptom Start Date, Possible Infection Date, Test Date): 
    • If you test positive and receive a Verification Code from the Local or State Health Authority, the App asks for it to verify a positive test result. 
    • Verification Codes are one-time codes that the App asks for when you choose to report your results and input them into the App. 
    • The App does not receive any Personal Information from the Local Health Authority or from Licensed Health Care Professionals. 
    • The App will confirm your Verification Code with the Local Health Authority to verify a positive test result.  
  • Region Preference: 
    • Selecting a region will let you see regional healthcare resources without ever having to share your location. This can be changed at any time. 

How Does the App Collect Data? 

  • Any Random IDs that relate to you are generated from and stored locally on your phone.
  • If you are near someone else who is using the App with the Apple-Google Exposure Notification technology enabled, your phones will share a Random ID with each other through the Bluetooth signals on your phones. 
  • The Random ID is constantly changing to help prevent anyone from tracking or identifying you. For example, if you see someone on Monday morning and again Tuesday morning, your phones will share two different Random IDs. 
  • Each phone will locally store a log of the Random IDs it encounters. 
  • The only time Random IDs are collected is if you choose to report that you tested positive for COVID-19. 
  • When you enter a Verification Code, Symptom Start Date, Possible Infection Date and Test Date for the App to confirm your positive test result, the Random IDs stored in your phone for the past 14 days are sent to the App’s secure Key Server. 
  • You will then get notified based on Data, Duration, and Signal Strength of potential exposures when the app downloads Random IDs from the Key Server, performs exposure detection and determines whether your phone was nearby someone infectious, based on their Random ID(s). 

How Will the App Use or Share Data? 

  • Once the App receives Random IDs and confirms the Verification Code of a user who tested positive, other App users who have the Apple-Google Exposure Notification technology enabled may receive a notification that they have come into contact with someone who has tested positive. 
  • To make this work, each App users’ phone periodically downloads the list of Random IDs for everyone who has tested positive in their region. 
  • Then, if any Random IDs of users who tested positive match Random IDs on your phone, you receive an exposure notification. 
  • Exposure notification is only done on your device under your control. The App cannot personally identify you or anyone who tested positive through the data it collects. 
  • However, there is a chance another App user may be able to infer or guess who you are based on your contact with them. 

 

How Does the App Store Data? 

  • Random IDs are stored locally on each user’s phone. 
  • Any Random IDs the App collects after someone reports they tested positive will be stored on the App’s cloud Key Servers which are housed by CovidWatch.org in the United States. 
  • The Key Servers will only retain these Random IDs for 14 days, after which point they are permanently erased. The App deletes any Verification Codes it receives as soon as they are confirmed. 

What are Your Rights? 

  • Using the App and enabling the Apple-Google Exposure Notification technology is completely voluntary. You may stop using the App or delete it at any time. 
  • Sharing your positive SARS-Cov-2 test result is also voluntary, and you may choose not to report a positive test. 
  • Though voluntary, public health highly encourages you to report a positive result to help others stay safe, make informed decisions about their health, and help save lives. 
  • Controlling Collection of Analytics or Other Information by Your Phone’s Provider 
  • Many application stores collect analytics and usage data about the apps you use. Unfortunately, this App cannot control this, but you can. 
  • For more information on how to control the information your provider may collect, visit the Settings app on your phone. 

Your Personal Health Information 

  • The App does not receive any Personal Information from the Bermuda Health Ministry, a local health agency or Licensed Health Care Professionals. 
  • If you have any questions or concerns regarding your health information, including your ability to exercise any rights with respect to this information, please contact your local health authority or Licensed Health Care Professional. 

EU Users 

  • The App processes the data you provide based only on your consent, which is collected when you sign up and again should you choose to report that you tested positive for SARS-CoV-2. 
  • You may withdraw your consent at any time by ceasing to use the App and deleting it from your phone. 
  • However, this will not undo the fact that you may have chosen to report that you tested positive and it will not undo any notifications previously sent to others that they came into contact with someone who tested positive. 
  • Because the App does not collect Personal Information, there is no meaningful way to respond to data subject access requests. However, if you have questions or concerns about how the App treats the data, please visit help.wehealth.org
  • Disclosure to Third-Parties: This app uses Google's Cloud infrastructure to store your anonymous Random IDs if you choose to share them when submitting a positive diagnosis. Similarly, your Diagnosis Data (Verification Code, Symptom Start Date) is shared with our Verification Server deployed on Google's Cloud infrastructure in the United States. 

Data about Children 

  • The App is not intended for children under 13. The App does not knowingly collect any information from children under 13. 
  • Changes to this Privacy Policy This App will be undergoing continued development. That means this Privacy Policy may change as those developments are implemented. 
  • If any changes are made to this Privacy Policy, the BERMUDA HEALTH MINISTRY will use reasonable means to notify you. 
  • This Privacy Policy was last updated on October 31st, 2020. 
  •  Please visit the Bermuda Government Portal (www.gov.bm) for information about COVID-19 in Bermuda.

How to Contact Us

If you have questions about the the App Privacy Policy or the App, visit help.wehealth.org.

If you have questions about this Website Privacy Policy or our Site, contact us at contact@wehealth.org.