Refresh Wellness Platform Privacy Policy

Updated Dec 11, 2024

What is the Privacy Policy and what does it cover?

Highlights

• At Refresh, honesty and transparency are important to us. We want you to understand how we collect, use, and protect your information. That’s why we encourage you to read our Privacy Policy.
• This Policy is divided into easy-to-read sections with Highlights to summarize what’s included.
• If you have any further questions, find the Contact Us page on our website and send us a note, we’ll be happy to answer as soon as we can.

Why is this Privacy Policy important?

Our core values at Refresh include participating in effective communication, which we want to extend to you and everyone who interacts with Refresh. Our two other core values are cultivating the unique genius and finding the right answer, not the easy answer.

We value personal privacy at Refresh. This Privacy Policy is designed to protect your data and maintain confidentiality while being as clear as possible.

What services does this Privacy Policy cover?

This Privacy Policy covers the Refresh Wellness Platform (also called the Platform) on iOS and Google Play app stores, as well as the browser-based version of the platform.

What do you need to know about data collection?

Highlights

• We don’t share or sell your individual information, and we never will.
• We do use and share some information and aggregated data with organizations and other partners.
• Learn how we protect your personal data through aggregation by reading this section.

What if you don’t let us collect certain information?

You do not have to complete your profile information to enjoy the platform, although we recommend sharing as much as you’re comfortable with for the best experience.

On the Refresh Wellness Platform, we aim to provide a healthy balance of personalized recommendations alongside a wide variety of activity and resource options. We use data mainly to provide information for our algorithms that suggest resources you might like, as well as to create your insights on your reporting dashboard.

What is aggregated data?

We use the term “aggregated data” in our Privacy Policy to refer to anonymous collective data that we use throughout the platform. Aggregated data is information that has been collected and summarized from multiple sources or places. It’s best used to help researchers find patterns and trends.

Refresh uses aggregated data to create your insights on your reporting dashboard through calculations and algorithms. Your personal data, algorithms, and information is not available ot anyone other than you.

Anonymous aggregated data is also shared with organizational accounts if you have agreed to be part of the organization or team. Refresh has safeguards in place so the data provided to organization accounts will never be traceable back to an individual person or account. To learn more about what organization accounts have access to, see the section called What do we collect, why do we collect it, and how is it used?.

How do we use your information generally?

Highlights

• At Refresh, we use anonymized information to give you the best experience possible.
• We share anonymous information with employers to provide valuable insights.
• For details on what we do with your data, see the next section called What do we collect, why do we collect it, and how is it used?.

How we use your information

Here are the ways we use your information:

To provide measurement, analyses, and business services:

We use the information we collect to bring you a personalized experience on the Refresh Wellness Platform. We use your activity data to:

• Provide journal and mood insights for you
• Provide journal, mood, and aggregated insights for your team or organization

To communicate with you:

We want to provide clear and transparent information. Occasionally we will send emails or communications on the platform to update you. We also use your account and associated email to:

• Communicate security updates or support
• Communicate clear and transparent updates
• Provide account support (e.g. password reset)

To provide personalized recommendations:

We want to give you the best experience possible with Refresh Wellness. To bring you a personalized experience, we use your profile data and activity to:

• Suggest personalized resources on topics you are interested in
• Provide the most relevant resources for your location

To research and innovate for better wellness:

Refresh Wellness is always trying to find better ways to support mental wellness. We use your account activity to develop new features and functions. We use your profile information and activity to:

• Discover more resources you may like
• Research how to best serve people similar to you
• Develop better algorithms to offer better search results

What do we collect, why do we collect it, and how is it used?

What we’re collecting, why we’re collecting it, and how it’s used:

1.   Registration and profile

After you register for your account on the Platform, you can add additional information in your profile, including your profile photo. Personal information like your profile is only stored as necessary. You can delete all identifying data at any time by deleting your Refresh account.

We collect:

• Your registration information in order to:
  • Create and save your account
  • Send you security-related emails (e.g. create new password, reset password)

• Your profile information in order to:
  • Anonymize data to use in demographic research
  • Suggest resources you might like

• Your profile image in order to:
  • Show you which profile you are using each time you use the Platform

We may share some anonymized or aggregated data with business partnerships:

• Businesses we partner with in order to:
  • Understand how different demographics access different activities and modules

2.   Platform activity (resources and modules)

When you interact with the platform, you can access educational resources, support resources, and activity modules. All of the things you do on the platform is collectively called “activity”.

We collect activity information so we can provide the best user experience. We do not share personal information, including images, unless required by law or with consent.

We use the information we collect to bring you a personalized experience on the Refresh Wellness Platform.

• The resources and modules you access
  • To suggest similar resources you might like
  • To track your wellness habit streak score, based on the modules you use

For some of this personalization, we use the data shared from your use of the platform and data from your device or devices. Information is automatically processed by our systems but in some cases we do manual reviews in order to solve issues and fix bugs.

In order to protect your information, in most cases we anonymize or aggregate data so that it no longer identifies you.

3.   Your Journals

We use the information we collect to bring you a personalized experience on the Refresh Wellness Platform.

• Your mood journals
  • We never save your journals with identifying information
  • Your journal data is used to create your insights on your reporting dashboard through mathematical algorithms – they’re never shared with a human person.
  • Your journal entry is used to recommend resources based on how you’re feeling about your workplace
  • We share anonymized, aggregated data from your journals with your organization if you are part of a team. Please see the What is Aggregated Data? Section to learn more

• You written journal entries
  • We never save written journals in any of our databases
  • Your written journal data is used to create resource recommendations on the platform based on the keywords you use
  • This data is never shared with any Refresh employee or organizational account holder

4.   Your Insights

We use the information we collect to bring you a personalized experience on the Refresh Wellness Platform.

• Your insights
  • We never save your insights with identifying information
  • We share anonymized, aggregated data from your insights with your organization if you are part of a team. To learn more, see the section titled What is Aggregated Data?
  • Your personal insights include:
    • Your overall emotions
    • Emotions on each day of the week

• Organization insights
  • Organizations see insights based on anonymous aggregated data
  • These insights include:
    • Overall emotions of team
    • Emotions of team on each day of the week
    • Average organization satisfaction score
  • Organizations cannot access individual journals or receive notifications about specific entries
  • Organizations in the Enterprise account are able to see insights organized by departments while keeping individual journals anonymous

5.   Your Emergency Contact

We use the information we collect to bring you a personalized experience on the Refresh Wellness Platform. We only save your emergency contact number so you can access it within the Platform. Refresh team members do not have authorization to access your saved Emergency Contact.

6.   Feedback

In order to address your feedback, we save the text and image(s) you share with us along with your device information in order to determine the best solution to the problem or suggestion.

Feedback submissions currently capture and send to our development team:

• Feedback category
• Text feedback
• Image(s) attached
• Email
• Username
• Platform information
• Device information
• Platform version

7.   Device Information

In order to fix bugs, provide you with the best resources, and improve your experience on the Refresh Platform, we collect certain information from your device. This includes:

• Your device make and model
• Your Platform version code
• Your location
• Your browser information (if you access Refresh Wellness from a web browser)

All data is anonymized and protected for your safety and security. To learn more about how we protect data, see the How do we protect your information? section.

We never share any information collected via your device with anyone other than our developers. Our developers are required to sign non-disclosure forms in order to protect your safety.

You can also turn off location permissions at any time using your device settings and the Platform will continue to work.

8.   Your Organization

If your Refresh Wellness account is part of an organization account such as a Professional or Enterprise Account, some limited aggregated data will be shared with your employer. If you are part of an organization, we collect and aggregate some additional information including:

• Your organization
  • To provide aggregated data about your journals and activity.

• Your role in the team account
  • To provide aggregated data to your organization, the Platform remembers which team you’re a part of.

• Organization accounts
  • To learn about their team and team departments.

After accepting your name and email as a team member, the main organization account will only ever see aggregated data in relation to their team, which can not be traced back to a single person or account.

9.   Surveys

As a wellness platform, we occasionally partner with researchers in order to innovate, advance technology, and improve people’s wellness. You may see a new Survey section on the Platform if you qualify to participate in a survey. If you would like to participate in the survey, ONLY the information you share in the Survey module is shared with researchers. This data is completely anonymized for your privacy and security.

How do we share information?

Highlights

• Organizations only receive aggregated data, never individual data
• Data is aggregated from Professional journal entries
• Personal journal data is not shared with organizations
• All written journal text is private and not shared

Sharing with your organization

Organization account holders will never have access to individual information from any single member or account holder. They will only see aggregated data gathered from numerous team members within the organization. Refresh takes all necessary precautions to ensure data cannot be traced back to any individual.

Aggregated data shared with organizations includes mood entries from journals. The organization account holder receives this aggregated group data about team member moods over a variety of date ranges. Organizations have the ability compare aggregated moods across different days of the week.

Our algorithms aggregate all data from Professional journal entries and excludes any written journal text. Any individual can opt-out of sharing any data with their organization by entering Personal journals only.

How we share wellness insights with employers and organizational account holders

To provide organizational insights, the platform stores journal dates and times to aggregate data into anonymous collective insights.

We take extensive measures to ensure the security of your journal entries. Organizations cannot access individual journals or receive notifications about specific entries. Our platform does not offer tools for organizations to view or search through your personal journals.

How we share with Refresh team

The only time data is shared with the Refresh team is when we are reviewing feedback and platform bugs. We do this in order to quickly identify issues and solve problems as fast as possible.

Data always remains encrypted using standard HTTPS protocols, which means no one other than Refresh team members can access your data.

Encryption works by turning a message or data into a string of code through the use of a code key. No one is able to access the true message or data without this unique code key.

Refresh team members are dedicated to adhering to responsible rules of conduct and have all signed non-disclosure agreements in order to protect you to the highest possible standard.

How we share with third parties

Refresh uses third party softwares in our workflow and servers. We ensure that each of these third parties has robust privacy policies that reflect our own standards.

How can you manage or delete your information?

Highlights

• To stop all notifications and emails from Refresh, you can disable your account, after which you can log back in at any time to reactivate your account.
• To delete all your user data and information, you can delete your account at any time from the Platform. All data that can be traced back to you will be automatically removed from our databases. Since this data is deleted permanently, you won’t be able to access it again and all saved data will be lost.

How to deactivate your account

If you want to stop all Refresh notifications and emails, you can deactivate your account. You will still be able to re-access your account after disabling it.

1. Open the Main Menu within the Refresh Wellness Platform
2. Press Settings.
3. Press Accounts.
4. Press Deactivate Account.
5. Fill out the form on that screen, press the Deactivate Account button.
6. Accept the confirmation that appears. At this point, you will be logged out and your account will be deactivated.

If you want to access your account again, you can reactivate your account. To reactive your account, simply log in again with the same account information as before.

How to delete your account

Your information is in your control. You can delete your Refresh Wellness Platform account at any time. Follow the steps below to delete your account and related information:

1. Open the Main Menu in the Refresh Wellness Platform
2. Press Settings.
3. Press Accounts.
4. Press Delete Account.
5. Fill out the form on that screen, press the Delete Account button.
6. Accept the confirmation message that appears. At this point, you will be logged out and your account will be deleted.

If you have uninstalled the app already, you can request that your account and associated data be manually deleted by emailing Refresh Support at refresh.webdev@gmail.com

How long do we keep your information?

Highlights

• Data is stored in Refresh databases indefinitely in order to support research and development and adhere to legal obligations
• Data is only accessible to Refresh employees, who have signed legally binding non-disclosure agreements (NDAs) to protect your privacy.
• If you would like your data and information removed from our databases, you can delete you account in the Platform or send us a message to manually delete your account for you.

How do we decide how long to keep data

User data and information is currently stored indefinitely in Refresh databases. We decide how long to keep certain information on a case-by-case basis.

Here’s what we consider when we save data:

• Whether the information is needed to provide service on the Refresh Wellness Platform
• The feature we use the information for, and how that feature works
• Legal obligations that require saving information for a period of time
• Other purposes to prevent harm, investigate possible violations of our Policy, promote safety and security, or protect ourselves, including our rights, property, or products

In some instances and for specific reasons, we’ll keep information for an extended period of time. We may save information for a longer time if it’s required for any of the following:

• A legal request or obligation, or to comply with applicable law
• A government investigation
• An investigation of possible violations of our policy
• For safety, security and integrity purposes
• To protect ourselves, including our rights, property or products
• If it’s needed in relation to a legal claim, complaint, litigation or regulatory proceedings

If a Refresh Wellness module or section of the Platform is removed, all it’s associated data, including user data, is also deleted.

How do we protect your information?

Highlights

• Refresh server and databases are all protected using standard HTTPS encryption.
• Your personal data is also encrypted by giving you a unique identification number, a string of letters and digits that are associated with your data.
• While Refresh employees have access to our full databases, team members have signed legally binding non-disclosure agreements to ensure your privacy and security.

What we do to protect and anonymize data

To anonymize your journal data, journals and mood entries are only assigned your unique identification number, which is separate from your name, email and username.

How Refresh is committed to privacy

At RWP, we prioritize safeguarding your personal information and providing a secure and private environment for your mental wellness journey.

Our primary concern at Refresh is making sure that no other platform users can access your personal information. This is why we anonymize mood data for team accounts and prescribe minimum team numbers – so you can be sure your data can’t be traced back to you.

How will you know the policy has changed?

Your data is important to protect. We will never share or sell personal journal information with anyone.

Each time we send an update regarding our Privacy Policy, you will be notified and invited to review the updates.

Refresh has a core value of communicating effectively. We want to provide all policy and data usage information in a clear and accessible way. This includes sending updates that are simple and easy to understand.

The Refresh Wellness Platform has an in-app communication system that we use to share updates with you. This saves your inbox from unnecessary messages while keeping you up to date whenever you use the platform.

Please check back into this page frequently for updates or additions to our Privacy Policy. Updates may be adjusted based on the introduction of new features and functions of the Refresh Wellness Platform.

How to contact us if you have questions

If you have questions about this Policy or have any other questions, complaints or requests regarding your data and information, you can contact us here.

If you have suggestions or feedback to share with us regarding the Refresh Wellness Platform, please use the in-app feedback form by going to the Settings menu, then Send Feedback and fill out the form provided.