Privacy policy

Privacy policy

Woojer Privacy Policy

Last updated and effective: October 26, 2026.

Some parts of this Privacy Policy describe features of the Woojer Wellness app that are available from app version 2.3.0, including connecting wearable and health apps, Wooju, the usage analytics choice (also available from app version 1.4.0), and the health and safety notice. If You use an earlier version of the app, those features are not available to You and the sections about them do not apply until You update. Everything else in this Privacy Policy applies to all versions.

Woojer USA, Inc., and Woojer Ltd. (including our affiliates and subsidiaries, the "Company", "we", "us" or "Woojer") know that you (“You,” “Your,” or “User”) care about how Your personal information is used and shared, and we take Your privacy seriously. Please read the following to learn more about our Privacy Policy, which is incorporated into Woojer’s Terms of Service.

By visiting the Woojer managed domains (including, but not limited to, www.woojer.com) and websites, mobile apps, domain names, or any other linked pages, features, content, or application services offered from time to time by Woojer in connection therewith (collectively, the "Site"), submitting information, or using any of our services, You acknowledge that You accept the practices and policies outlined in this Privacy Policy (the "Privacy Policy").

What does this Privacy Policy cover?

This Privacy Policy covers Woojer's treatment of information that Woojer gathers when You are accessing Woojer's Site, including when You use the Woojer Wellness app for iOS and Android (the “App”) (the “Information”). The sections “The Woojer Wellness app”, “Health and wellness data”, “Wooju, our AI wellness guide” and “Service providers that process App data” describe how the App handles Information. Where those sections are more specific than the rest of this Privacy Policy, they control for Information collected through the App. This Privacy Policy does not apply to the practices of third parties that Woojer does not own or control (such as third-party websites that You may access from the Site), or to individuals that Woojer does not employ or manage.

What Information does Woojer collect?

The Information we gather from Users enables Woojer to improve our services and to allow our Users to set up accounts on the Site.

In some cases, how we treat and use information will depend on the type of information. Some of the information we collect through Your use of our Services or communications with us, such as Your name, address, phone number, e-mail address, country, profile picture, playlist, or billing information associated with Your account may personally identify You. We describe this information as “Personally Identifiable Information.” We will also treat as Personally Identifiable Information any non-identifiable information that is combined with Personally Identifiable Information.

Information You provide to us:

We receive and store any Information You enter on our Site or provide to us in any other way. The types of Information collected include Your full name, email address, mailing address, phone number, IP address, browser information, password, contact information, credit card or bank account information (which is also used by our third-party credit card and payment vendors), transactional information based on Your activities on the Site, and media consumed on the Site including, but not limited to, media viewed, played, downloaded, uploaded, and shared. You can choose not to provide us with certain information, but then You may not be able to take advantage of many of the Site’s special features.

Information collected automatically:

·         We receive and store certain types of Information whenever You interact with our Site or services. Woojer automatically receives and records Information on our server logs from Your browser including Your IP address, Woojer cookie information, the page You requested, and the media You have consumed (e.g., viewed, played, downloaded, uploaded, and shared).

·         Generally, our service automatically collects usage Information, such as the numbers and frequency of visitors to our Site and its components, similar to TV ratings that indicate how many people watched a particular show.

·         The Site may use customer experience analytics services. These services help us analyze how visitors use our Site. We do not collect through these services or transfer to such services any personal identifiable Information. We only use these services to record, on an anonymous basis, information such as mouse clicks, mouse movements, scrolling activity as well as non-Personally Identifiable Information text You type in this website.

What about cookies?

·         Cookies are alphanumeric identifiers that we transfer to Your computer's hard drive through Your browser to enable our systems to recognize Your browser and tell us how and when pages in our Site are visited and by how many people. Woojer cookies do not collect Information, and except as necessary to investigate claims of fraud or other misconduct or as otherwise necessary to track purchases for purposes of calculating credit under affiliate programs, we do not combine the general information collected through cookies with other personal Information to tell us who You are or what Your screen name or email address is.

·         Most browsers have an option for turning off the cookie feature, which will prevent Your browser from accepting new cookies, as well as allowing You to decide on acceptance of each new cookie in a variety of ways. Cookies enable You to take advantage of some of our Site's most attractive features.

·         This Privacy Policy covers the use of cookies by Woojer and does not cover the use of cookies by any advertisers or other third parties with whom Woojer may work. Woojer does not access or control such third-party cookies; please refer to those companies' privacy policies.

The Woojer Wellness app

This section applies when You use the Woojer Wellness app for iOS and Android (the “App”). Woojer Ltd. (Israel) is responsible for the Information collected through the App. You need an account to use the App; everything else described in this section is optional or is collected automatically when You use it.

Information You give us in the App

  • Account details: Your email address and a password, which our authentication provider stores only in hashed form; or, if You sign in with Google or Apple, the name, email address and profile photo that service shares with us. If You use Apple's “Hide My Email”, we receive a relay address instead of Your email address.
  • Profile details You choose to add: a display name, a profile photo, and Your country, gender and date of birth.
  • Your choices: that You accepted our Terms of Service and this Privacy Policy, whether You want marketing emails and News & offers notifications,  the consents You give for health data and for Wooju, and, if You change it, Your choice to stop or resume sharing usage data.

  • Messages You send us, for example when You contact support or send us feedback or a request from the App. A feedback message can include one screenshot You choose to attach. With it we receive Your account, the App version, Your phone's operating system, the product type of Your Woojer, Your plan and the country Your connection comes from.

Information collected when You use the App

  • Your Woojer device: its product type, firmware version and Bluetooth identifier, the intensity You use, and the date You first paired it. The device's Bluetooth address (its stable identifier) is also saved on Your account, so we can support You and recognise the same device across firmware updates. When Your Woojer's firmware is updated, the firmware-update log records it too and is linked to Your account, so we can see how updates go on each device. If You claim a membership period included with a device purchase, we also record the device's Bluetooth address and the date, so that each device's offer is used only once.
  • How You use the App: when You open it and how long it stays open (while it is open, the App sends a short signal about once a minute), the screens and features You use, the sessions You play (which session, for how long, how far You got, the intensity, and whether Your device was connected), favorites and ratings, onboarding steps, and error reports. 

    Usage analytics are on by default. Everywhere, You can stop sharing them, and start again, in the App's settings (Profile → Account → Personal info → Usage data). While they are off, the App sends no usage or error information and saves only the session history that features You use depend on, such as Your listening history and streaks.

  • Technical information: Your phone model, operating system and version, the App version, language and time zone, and a random identifier created when the App is installed.
  • Approximate location: our hosting provider derives Your country and city from Your IP address when the App sends usage information. The App does not access Your phone's GPS or precise location. To match the Home screen to Your local weather, our content service sends the approximate location of Your IP address, without any account identifier, to the weather service Open-Meteo.
  • Purchases: if You subscribe in the App, Apple or Google processes Your payment. Our subscription service, RevenueCat, tells us which plan You have and when it renews or ends. We never receive Your payment card details, and we never send Health Data to RevenueCat.
  • Notifications: if You allow notifications, the App gives us a notification token for Your phone (a random code issued by Apple or Google through our notification provider), together with Your phone type (iPhone or Android), time zone, App version and language, so we can send the notifications You have chosen. We also record which notifications we sent to Your phone, whether they were delivered and whether You opened them. We keep the wording neutral because notifications can appear on Your lock screen.

How we use this Information

We use it to create and secure Your account; to connect to, control and update Your Woojer device; to deliver sessions and other content; to manage subscriptions and included membership periods; to send account emails and the notifications You allow; to answer Your support requests; to read and act on the feedback and requests You send; to understand how the App is used so we can fix problems and improve it; and to keep the App and its users safe. Authorized Woojer staff can see account, device and subscription details when they need them to support You or to run the App.

What we do not do in the App

We do not use advertising identifiers, do not track You across other companies' apps or websites, and do not include third-party advertising or analytics tools in the App.

Reminders

The App sends notifications only if You allow them. Before the phone asks, the App explains what we would send. Some reminders are scheduled on Your phone. Others are sent from our servers: Your weekly recap, announcements about new content, and notices about Your account or subscription, such as a payment problem or the end of complimentary access. “News & offers” about products and offers is separate: it is off by default and we send it only if You choose it. Some reminders mention Your sleep score from the night before, and all notifications can appear on Your lock screen. You can switch each kind on or off in the App under You → Notifications, or turn all of them off in Your phone's settings. The App works fully without notifications.

Health and wellness data

The App can turn data from a wearable device or health app You choose to connect into a daily wellbeing score, and use it to suggest sessions. Connecting a source is optional, and the rest of the App works without it. You must be 18 or older to connect a source.

Sources You can connect

Apple Health (HealthKit) on iPhone; Health Connect on Android; and Your Garmin Connect, Oura, Polar, Fitbit, WHOOP, Ultrahuman or Zepp account. Before we read anything from a source, we ask for Your explicit consent to that source, and we keep a record of it.

What we read (“Health Data”)

Sleep (duration, stages, efficiency and the source's own sleep score), heart rate, heart rate variability (HRV), resting heart rate, blood oxygen, respiratory rate, steps, calories, active and exercise time, and readiness or recovery scores where Your source provides them. The App only reads this data. It never writes to Apple Health or Health Connect.

How Health Data reaches us

We use Terra (tryterra.co), a health-data integration service, to connect Your sources. Woojer is responsible for Your Health Data (the controller), and Terra processes it on our behalf as our service provider. For Apple Health and Health Connect, the App sends the data types listed above from Your phone to Terra. For Garmin, Oura, Polar, Fitbit, WHOOP, Ultrahuman and Zepp, You sign in to that company and authorize the connection, and that company sends Your data to Terra. When the App refreshes, our servers request Your recent data from Terra and pass it to the App on Your phone. Terra's End User Privacy Policy (https://tryterra.co/end-user-privacy) also applies, and You are asked to accept it when You connect a source. Terra processes data mainly in the United Kingdom and the Netherlands, may transfer it to the United States, and keeps it only briefly, as its policy describes.

What we keep

For each day, the App calculates Your wellbeing results: the score and its parts, and that day's HRV, resting heart rate, sleep quality and steps, with the source each came from. We store these daily results so that You can see Your trends, together with a record of which sources You have connected. We do not store the raw data from Your sources on our servers.

How we use Health Data

Only to calculate and show Your wellbeing score, trends and insights, and to choose which sessions to suggest to You. We never:

  • sell, rent or trade Health Data, even with Your consent;
  • use Health Data for advertising or marketing, or share it with advertising networks, data brokers or social networks;
  • use Health Data to create, develop, test, train, fine-tune or improve any artificial intelligence model, application or system;
  • include Health Data in our usage analytics;
  • use Health Data to make decisions about credit, insurance or employment.

We disclose Health Data only to the service providers that run this feature for us (Terra and our hosting provider), to others only with Your explicit consent, or where the law requires it. Only a small number of authorized staff can access it, and only when they need to in order to support You or keep the service running.

Your controls

You can disconnect any source in the App at any time. We then stop reading from it and end the connection at Terra, and Terra deletes the data it received from that source as its policy describes. “Delete my health data” in the App disconnects every source and deletes all Health Data we hold, including Your daily wellbeing results. Deleting Your account does the same. You can also withdraw access from the source itself, for example in the Health app on iPhone, in Health Connect, or in Your Garmin Connect or WHOOP account. Withdrawing consent does not affect processing that took place before.

Commitments for specific sources

  • Apple Health (HealthKit): We use HealthKit data only to provide the features in this section. We never use it for advertising, marketing or data mining, never disclose it to third parties other than Terra as our service provider, and never store it in iCloud.
  • Health Connect: The App's use of information received from Health Connect adheres to the Health Connect Permissions policy, including its Limited Use requirements.
  • Garmin: When You connect Your Garmin Connect account, Garmin shares the data types listed above with us through Terra. We use Garmin data only as described in this section, never sell it, and show Garmin as the source wherever it appears in the App. Garmin's handling of Your data is described in Garmin's privacy policy. Data from Garmin is not shared with or processed by any external AI provider.
  • WHOOP: When You connect Your WHOOP account, WHOOP shares Your sleep, recovery, workout and related data with us through Terra. We never sell WHOOP data, even with Your consent; we never use it to create, develop, test, train, fine-tune or improve any artificial intelligence model, application or system; and we never expose it to other users or third parties without Your explicit opt-in consent. We keep WHOOP data only as long as WHOOP's terms allow. WHOOP's handling of Your data is described in WHOOP's privacy policy.
  • Oura, Polar, Fitbit, Ultrahuman and Zepp: The same commitments apply. Each company's privacy policy describes how it handles Your data.

Wooju, our AI wellness guide (AI transparency statement)

Wooju is an artificial intelligence (AI) guide in the App. When You chat with Wooju, You are communicating with an AI system, not a person. Using Wooju is optional, You must be 18 or older to use it, and we ask for Your permission before Your first conversation.

What Wooju processes

The messages You send; Your recent conversation; what Wooju remembers about You (goals, preferences, favorite sessions, boundaries You set, and short summaries of earlier conversations); and the time of day and time zone on Your phone, so that it can suggest a fitting session.

Why

To reply to You, suggest sessions, and personalize later conversations.

Who processes it

Wooju's replies are generated by AI models from Anthropic, PBC, in the United States, which processes Your messages on our behalf. Anthropic's commercial terms do not permit it to train its models on this data, and Anthropic deletes it within 30 days, unless it must keep it longer to enforce its usage policies or by law. The Wooju service runs on servers operated by Fly.io in the Netherlands and stores Wooju data with our hosting provider in Germany. We do not collect, use or sell personal data, including Wooju conversations, to train large language models or other AI models.

Garmin and WHOOP data and AI

Data we receive from Garmin Connect, and data we receive from WHOOP, is never shared with, processed by or made available to Anthropic or any other external artificial intelligence (AI) provider, and is never used to train AI models. Wooju does not receive this data.

Memory

Wooju may remember things You tell it, to personalize later conversations. If You mention something about Your health or body, such as a medication, a pregnancy or an implant, Wooju holds it and asks You to confirm before remembering it. Your confirmation is Your explicit consent to Wooju keeping that fact, and You can withdraw it at any time by telling Wooju to forget it. You can review, forget or clear everything Wooju remembers at any time.

Safety

If a message suggests You may be in crisis, Wooju shows crisis resources instead of an AI reply. That message is not sent to the AI model, and we keep a record that a crisis response was shown.

Staff access

Authorized Woojer staff can read Wooju conversations and what Wooju remembers. They do so to monitor Wooju for safety and misuse, to review the quality of its replies, to improve how Wooju works (for example its instructions and the sessions it suggests), and to answer support requests You make. This review does not involve training AI models. Access is limited to a small number of trained staff.

How long we keep it

Until You delete it, or 12 months after Your last conversation, whichever comes first.

Your choices

You can delete a conversation, forget or clear what Wooju remembers, export what Wooju remembers, or use “Delete everything” in Wooju to erase all Your Wooju data. Deleting Your account also deletes all Your Wooju data.

Service providers that process App data

We use the service providers below to run the App. Each processes personal data only on our instructions and under a contract that requires it to protect that data at least as well as this Privacy Policy does.

  • Supabase, Inc.: hosts the App's database, sign-in and file storage. Frankfurt, Germany.
  • Terra: connects wearables and health apps, and receives and briefly holds Health Data. United Kingdom and the Netherlands, with possible transfers to the United States.
  • Anthropic, PBC: generates Wooju's replies. United States.
  • Fly.io, Inc.: runs the Wooju service. Amsterdam, the Netherlands.
  • RevenueCat, Inc.: manages in-App subscriptions. United States.
  • Resend: sends account and service emails, and the internal email that tells our team about new feedback. United States.
    Telegram: delivers a short internal message to our team when You send feedback (Your message, Your display name, and basic App and device details, but not Your email address). 
  • Cloudflare, Inc.: delivers App content, protects our services and App usage information and the feedback You send. Global network.
  • 650 Industries, Inc. (Expo): delivers App updates and passes notifications to Apple and Google for delivery to Your phone, so it receives the notification token and the notification text. United States.
  • Open-Meteo: provides local weather for the Home screen and receives only an approximate location, with no account identifier. Switzerland.

Apple and Google provide the app stores, payments, sign-in with Apple or Google, HealthKit and Health Connect, and the push-notification services that deliver notifications to Your phone, under their own privacy policies. Garmin, Oura, Polar, Fitbit (Google), WHOOP, Ultrahuman and Zepp handle Your data on their own services under their own privacy policies.

How does Woojer use my Information?

The Information You provide is used for purposes such as responding to Your requests for certain products and services, customizing the content You see, and communicating with You.

Woojer may use all of the Information that we collect from our Users to understand usage trends and consumer and customer preferences, to improve the way the Site works and looks, to improve our marketing and promotional efforts, and to create new features and functionalities.

Woojer may use automatically collected information and cookies information to: (a) remember Your Information so that You will not have to re-enter it during Your visit or the next time You visit the Site; (b) provide custom, personalized advertisements, content, and information; (c) monitor the effectiveness of our marketing campaigns; (d) provide You with newsletters and updates regarding new product launches or ways to improve Your user experience; (e) provide You with notifications regarding products in your online shopping cart or incomplete order placing; and (f) monitor aggregate usage metrics such as total number of visitors and pages viewed. Items (b) and (c) above never apply to Health Data or to Wooju conversations. We never use either for advertising or marketing, and we never combine them with cookie or advertising data.

Woojer may use Your email address or other Personally Identifiable Information provided by You for promotional and marketing purposes or to communicate with You with information about a specific program or feature You have elected to participate in or receive information about.

Will Woojer share any of the Information it receives?

We will not sell Your Personally Identifiable Information or share Your Personally Identifiable Information with third parties, except with:

  • Our service providers and subcontractors to the extent reasonably necessary to enable us to operate and provide our Services to You;
  • A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personally Identifiable Information held by us about our Users is among the assets transferred;
  • You, upon Your written request;
  • Other third parties with Your express consent.

Health Data and Wooju conversations are never sold, rented or traded, even with Your consent, and are never shared with advertising networks, data brokers or social networks. We disclose them only to the service providers described in “Service providers that process App data”, to others only with Your explicit consent, or where the law requires it. The last item in the next list (“For any other purpose disclosed by us when You provide the information”) does not apply to them.

We may also disclose Your Personally Identifiable Information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request;
  • To investigate potential unauthorized access or misuse of our Services or otherwise enforce our Terms, or other agreements;
  • To protect our assets or rights, including for billing and collection purposes;
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Woojer, our Users or others, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; and
  • For any other purpose disclosed by us when You provide the information.

Is Information about me secure?

Your Woojer account Information is protected by a password for Your privacy and security. You need to protect unauthorized access to Your account and Information by selecting and protecting Your password appropriately and limiting access to Your computer and browser by signing off after You have finished accessing Your account.

Woojer attempts to ensure that User Information is kept private; however, Woojer cannot guarantee or ensure the security of User Information. Unauthorized entry or use by third parties, hardware or software failure, and other factors may compromise the security of User Information at any time, including Your Information.

How long do we keep Your Information?

We keep Your personal information to enable Your continued use of Woojer, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to You. For example, we retain Your transaction history so that You can review past purchases (and repeat orders if desired) and what addresses You have shipped orders to, and to improve the relevancy of products and content we recommend.

For the App, we keep:

  • account and profile details until You delete Your account;
  • Health Data until You disconnect the source, use “Delete my health data” or delete Your account. Terra keeps the data it receives only briefly, as described in “Health and wellness data”;
  • Wooju conversations and what Wooju remembers until You delete them or Your account, or 12 months after Your last conversation, whichever comes first;
  • App usage information (app activity, diagnostics, firmware-update logs, and the usage copies of Your metronome, recovery and wake-up sessions) for 13 months, then we delete it. Your listening, breath and nap history is kept until You delete Your account. When You delete Your account, we delete all of it;
  • purchase records: when You delete Your account, we delete Your customer record at our subscription provider and remove everything that identifies You from our own records. We keep only an anonymous record of each purchase (what was bought, the amount, the date and the store's transaction number) for up to 7 years, as tax and accounting laws require, and then delete it;
  • temporary sign-in data for 7 days; notification tokens until You sign out, delete Your account, or Apple or Google tell us the token no longer works; records of the notifications we sent to Your phone for 30 days; and Your notification settings until You delete Your account;
  • a record that a device's included membership period was used (the device's Bluetooth address and the date), for as long as the offer applies to that device, without a link to Your account after You delete it.

  • Feedback and requests You send, including any screenshot within 13 months. If You delete Your account they are kept but no longer linked to You.

Deleted data can remain in encrypted backups for up to 8 days until those backups are overwritten. Our service providers delete their copies on their own schedules, usually within 30 days (see “Service providers that process App data”).

What Information can I access?

Woojer may allow You to access certain Information about You through the member dashboard and/or customer accounts, for the purpose of viewing, and in certain situations, updating that Information.

What are my choices?

You may have the opportunity to receive certain communications from us related to our Services. If You provide us with Your e-mail address in order to receive communications, You can opt out of marketing e-mails at any time by following the instructions at the bottom of our e-mails and adjusting Your e-mail preferences. Please note that certain e-mails may be necessary for the operation of our Services. You will continue to receive these e-mails, if appropriate, even if You unsubscribe from our optional communications.

Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that You do not wish to be tracked across different websites You visit. Our Services do not currently change the way they operate based upon detection of a Do Not Track or similar signal.

Please note that we cannot control how third-party websites or online services You visit through our Services respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

The accuracy of the information we have about You is very important. Users may update their information at any time on the account registration page. Otherwise, to review or correct Your Personally Identifiable Information, You may contact us at privacy@woojer.com.

In the App, You can:

  • allow or refuse Bluetooth, Health and notification access in Your phone's settings;
  • connect or disconnect each wearable or health app, and delete Your health data;
  • review, export and delete what Wooju remembers, and delete Your Wooju conversations;
  • turn reminders and marketing emails on or off;
  • switch usage analytics on or off;
  • delete Your account under You → Delete account.

Deleting Your account deletes the information described in “How long do we keep Your Information?” and asks our service providers to delete their copies. It does not cancel a subscription bought through the App Store or Google Play; cancel that in Your store account. You can also ask us to delete Your account and data at www.woojer.com/pages/delete-account or by emailing privacy@woojer.com from the email address on Your account.

How do we secure Your Information?

The security of Your information is important to Woojer, and we have established reasonable administrative, technical, and physical safeguards designed to protect Personally Identifiable Information against loss, alteration, unauthorized access, theft, misuse, or disclosure. We evaluate these safeguards on an ongoing basis to help minimize risks from new security threats as they become known. Unfortunately, no system can guarantee complete security of Your information. As a result, Woojer cannot ensure or warrant that Your information, including Your Personally Identifiable Information, is secure from unauthorized third parties. Thus, Your use of the Services and communication with us about them is at Your own risk.

You are responsible for protecting Your User credentials (username, ID, and password) and for the security of information that You transmit to us over the internet.

Changes to this Privacy Policy

Woojer may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of Your Information and will always be available at www.woojer.com/policies/privacy-policy. You and all Users are bound by any changes to the Privacy Policy when You or they use the Site after such changes have been posted.

Children

Our Site and Services are not directed to children under 13, and we do not knowingly collect Personally Identifiable Information from children under 13. You must be 16 or older to use the App, and You confirm this when You create an account. Connecting wearables or health apps and using Wooju are available only to users 18 and older. If we learn that a user is younger than these ages, we close the account or turn off the feature, and delete the related data. If You believe a child has given us personal information, contact privacy@woojer.com and we will delete it.

Note to international users

This Privacy Policy is governed by New York law. If You are a customer or client accessing the Site from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from New York laws, then please note that the collection of personal data under New York law is different from requirements in the EU and other regions.

Where the law of Your country requires a legal basis or a safeguard for using or transferring personal data, we rely on those described in “Note to users based in the European Economic Area (“EEA”)”, not on Your use of the Site.

Note to users based in the European Economic Area (“EEA”)

Woojer Ltd. (16 Hamelacha Street, Rosh Haayin, Israel, 4809139,) is the data controller for the personal data collected in connection with use of the Services in the EEA. The processing and transfer of Personally Identifiable Information of Users based in the EEA is governed by the General Data Protection Regulation (“GDPR”). As used in this section, “personal data” means any information relating to an identified or identifiable User, including Personally Identifiable Information.

Data controller

We are the data controller in connection with the Services. Our contact information can be found at the end of this Privacy Policy.

Transfer of personal data outside of the EEA

Woojer Ltd. is based in Israel, which the European Commission recognizes as providing an adequate level of protection for personal data, and Woojer USA, Inc. is based in the United States. Our websites and online stores are hosted by Shopify. The App's database is hosted in Frankfurt, Germany, and the Wooju service runs in Amsterdam, the Netherlands. Some of our service providers process personal data in the United Kingdom, which the European Commission also recognizes as adequate, or in the United States (see “Service providers that process App data”). For transfers to the United States, we rely on the recipient's certification under the EU-U.S. Data Privacy Framework and its UK Extension where it has one, and otherwise on the European Commission's Standard Contractual Clauses together with the UK International Data Transfer Addendum. You can ask for a copy of these safeguards at privacy@woojer.com.

Lawful basis for processing personal data

We process Your personal data on the following legal bases:

  • Contract (Article 6(1)(b) GDPR): to provide the Site, the App and Wooju, manage Your account and subscriptions, and respond to Your requests.
  • Explicit consent (Article 9(2)(a) GDPR): to read and use Health Data from each source You connect, and to keep health information You confirm to Wooju. We ask for these consents separately. You can withdraw each one in the App as easily as You gave it, by disconnecting the source, deleting Your health data, or telling Wooju to forget the fact. Withdrawing consent does not affect processing that took place before.
  • Consent (Article 6(1)(a) GDPR): marketing emails.
  • Legitimate interests (Article 6(1)(f) GDPR): to keep our services secure, prevent fraud and misuse, fix errors, and understand and improve how the Site and the App are used, including App usage analytics.
     You can object at any time (see “Your rights”), and You can switch App usage analytics off in the App's settings.
  • Legal obligation (Article 6(1)(c) GDPR): to keep tax and accounting records and to respond to lawful requests.

We do not make decisions about You based solely on automated processing that have legal or similarly significant effects. The App's wellbeing score is calculated automatically from Your Health Data and is used only to suggest sessions. You can stop it at any time by disconnecting Your sources.

Your rights

·         You may request to access Your personal data at any time; to have Your personal data corrected, restricted, or erased; to object to our processing of Your personal data; and to request that we provide You with a portable copy of Your personal data. To exercise any of these rights, please use the contact information found at the bottom of this Privacy Policy.

·         Right to object. Where we rely on legitimate interests, You can object at any time to our processing of Your personal data, including App usage analytics, by contacting privacy@woojer.com or by switching off usage analytics in the App's settings. You can also withdraw any consent at any time, and You can exercise many of these rights directly in the App (see “What are my choices?”).

·         In addition to the rights listed above, You have the right to lodge a complaint with Your local supervisory authority if You believe that our processing of Your personal data infringes the GDPR. To find the relevant supervisory authority, please refer to this list: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

·         If You are in the United Kingdom, please contact us first at privacy@woojer.com. We will acknowledge Your complaint within 30 days. You can also complain to the Information Commissioner's Office (ico.org.uk).

Data protection officer

You can contact our Data Protection Officer using the following contact information: privacy@woojer.com.

European Union (“EU”) and United Kingdom representative

We value Your privacy and Your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.

Prighter gives You an easy way to exercise your privacy-related rights (e.g., requests to access or erase personal data). If You want to contact us via our representative Prighter or make use of Your data subject rights, please visit the following website: https://prighter.com/q/19052319817

Processing in the context of the electronic withdrawal
When you exercise your right of withdrawal electronically via the provided function, we process personal data that is required to handle the declaration. This includes in particular your name, your contact details, and information about the relevant contract 
(e.g., order number). Processing is based on Art. 6(1)(b) GDPR for the purpose of handling the withdrawal and related communication. The data is stored only for
as long as necessary to process the withdrawal and to comply with statutory retention obligations.

Note to California users

If You are a California resident, the information below also applies to You. Certain terms used in this section have the meanings given to them in the California Consumer Privacy Act (“CCPA”).

Categories of Personally Identifiable Information Woojer has collected from or about its users in the preceding twelve (12) months:

  • Identifiers (e.g., name, mailing address, email address, phone number, credit/debit card number)
  • Characteristics of protected classifications (e.g., gender, age)
  • Commercial information (e.g., products or services purchased, purchase history)
  • Internet or other electronic network activity (e.g., browse or search history)
  • Geolocation data (e.g., latitude or longitude)
  • Audio, electronic, visual, or similar information (e.g., recording of User service calls)
  • Inferences drawn from any of the above (e.g., preferences or characteristics)
  • Sensitive personal information: account log-in details; and, if You use these features, Health Data from the sources You connect and health information You share with Wooju.

Information collected through the App, including Health Data and Wooju conversations, is never sold or shared for cross-context behavioral advertising. The “sale” of cookie and tracking data described below concerns our websites only. We use sensitive personal information only to provide the features You request and for the other purposes permitted by California's regulations (Cal. Code Regs. tit. 11, § 7027(m)), not to infer characteristics about You, so we do not offer a separate right to limit its use.

Categories of sources from which Woojer has collected Personally Identifiable Information about users (for more information, see the “How does Woojer use my Information?” section of the Privacy Policy):

  • Consumer Directly
  • Advertising Networks
  • Data analytics providers
  • Government Entities
  • Social networks
  • Woojer subsidiaries
  • Wearables and health apps You connect in the App (through our service provider Terra)
  • Apple and Google (sign-in and app stores)

Business or commercial purposes for which Woojer has collected or sold Personally Identifiable Information about users in the preceding twelve (12) months (for more information, see the “How does Woojer use my Information?” section of the Privacy Policy):

  • Performing services, including: providing customer service, processing or fulfilling orders and transactions, providing notifications regarding incomplete orders, providing personalized advertisements, content, and information, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
  • Auditing related to a current interaction with You and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
  • Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Categories of Personally Identifiable Information sold:

  • Internet or other electronic network activity (e.g., “cookies” or other tracking tags)

Categories of third parties to whom Personally Identifiable Information was sold:

  • Advertising networks
  • Payment processors

WOOJER DOES NOT KNOWINGLY SELL PERSONALLY IDENTIFIABLE INFORMATION OF MINORS UNDER THE AGE OF 16.

Categories of Personally Identifiable Information Woojer has disclosed for a business purpose:

  • Identifiers (e.g., name, mailing address, email address, phone number, credit/debit card number)
  • Characteristics of protected classifications (e.g., gender, age)
  • Commercial information (e.g., products or services purchased, purchase history)
  • Internet or other electronic network activity (e.g., browse or search history)
  • Geolocation data (e.g., latitude or longitude)
  • Audio, electronic, visual, or similar information (e.g., recording of User service calls)
  • Inferences drawn from any of the above (e.g., preferences or characteristics)

Categories of third parties to whom Personally Identifiable Information has been disclosed for a business purpose:

  • Advertising Networks
  • Internet Service Providers
  • Data Analytics Providers
  • Government Entities
  • Operating Systems and Platforms
  • Social Networks
  • Data Brokers

At Your direction or request, or when You otherwise consent, we may share Your Information with third parties (e.g., if a User provides explicit, opt-in consent to the linking and use of data with a specifically identified third-party partner, such data may be linked and may be used by Woojer and/or the third-party partner as described at the time consent is obtained, including for Woojer advertising or advertising measurement purposes).

How does Woojer protect You from discrimination?

Woojer will not discriminate against You because You exercise Your rights. For example, Woojer will not deny You goods or services or charge You a different price or rate for goods or services if You make an access, deletion, or do not sell request. We may, however, offer You a financial incentive, such as a discount for joining our email list, as described in “Notice of Financial Incentive” below. Taking part is always optional.

Notice of Financial Incentive

We offer 5% off Your first order on woojer.com when You join our email list. This notice explains the terms of that offer so You can decide whether to take part.

  • What we offer: a one-time discount of 5% off Your first order placed on woojer.com.
  • Information we collect: Your email address and, if You choose to give it, Your mobile phone number so we can send You text messages. Giving a phone number is optional and is not required to receive the discount. Both fall under the “Identifiers” category listed above.
  • How to join: enter Your email address in the sign-up form on our website. Joining is optional, and You can shop on woojer.com without joining.
  • How to leave: You can leave at any time. To stop marketing emails, click the unsubscribe link in any email we send. To stop text messages, reply STOP to any text from us.
  • Value of Your data: We estimate the value of a typical subscriber's personal information to Woojer at approximately [$X per subscriber]. We calculated this estimate by [method, for example: dividing the revenue we earn from email and text marketing over a year by the average number of subscribers in that year]. We believe the 5% discount is reasonably related to this value.

What are Your rights under the CCPA?

  • Right to request Woojer disclose Personally Identifiable Information, or categories of Personally Identifiable Information, it collects, uses, discloses, and sells
  • Right to request Woojer delete Personally Identifiable Information we have collected from You
  • Right to request Woojer opt You out of the sale of Your Personally Identifiable Information

What is our process to verify access and/or deletion requests?

If You are a Woojer User, You will be required to submit sufficient information demonstrating your identity, including Your name, address, email, and phone number. Woojer will use this information to search our systems and determine if we have Information about You. If we are able to locate Information about You, we will fulfill Your access and/or Your deletion request. If we are not able to match the information You submit, we may provide You with a report that includes the categories of Personally Identifiable Information we collect, use, disclose, and sell.

Users will receive two emails when Your access report is ready. These emails will be sent to the email address You provided at the time You submitted Your request. One email will contain a link to Your report and a second email will contain a password needed to access the report.

If You are an authorized agent, You will be required to submit Your name, address, email, and phone number as well as the name, address, email, and phone number of the User You are making a request on behalf of. Woojer will use the User’s Information to search our systems and determine if we have Information about the User. If we are able to locate Information about the User, we will fulfill the access and/or deletion request. As an authorized agent, You will receive an email confirming that we have received the request along with a second email asking You to fill out a certification form confirming Your Information and certifying You have the right to make this request on behalf of the User. Once the report is ready, it will be sent to the email or physical address You have given us, depending on the delivery method You choose.

How can You submit a verifiable request? (Requests can be made no more than twice in a 12-month period)

You can submit a request using the methods listed below:

  • Access Requests: Contact us at +1 (351) 213-6246 or click here.
  • Deletion Requests: Contact us at +1 (351) 213-6246 or click here.
  • Do Not Sell My Personally Identifiable Information Requests: Click here.

All requests will receive a response within seven (7) business days.

Additional notices for certain locations

Washington, Nevada and Connecticut: our Consumer Health Data Privacy Policy (www.woojer.com/pages/consumer-health-data-privacy-policy) describes how we handle consumer health data and how residents of these states can exercise their rights. We do not collect, use or sell personal data to train large language models.

Other U.S. states: where Your state's privacy law gives You rights over Your personal data, such as the rights to access, correct, delete and receive a copy of it and to opt out of targeted advertising or sale, You can exercise them by contacting privacy@woojer.com. We collect Health Data only with Your consent. If we decline Your request, You can appeal by replying to our decision, and we will respond within the time the law requires.

Israel: Woojer Ltd., 16 Hamelacha Street, Rosh Haayin 4809139, Israel, is responsible for Your personal data. You are not legally required to give us any personal data, but without account details You cannot use the App, and without Health Data the wellbeing features do not work. The purposes for which we use Your data and the recipients who receive it are described in this Privacy Policy. You can ask to see and correct Your personal data by contacting privacy@woojer.com.

Canada: our privacy officer is the Privacy Officer of Woojer Ltd., reachable at privacy@woojer.com.

How can You contact Woojer?

Privacy requests and questions: privacy@woojer.com

Woojer Ltd. (data controller), 16 Hamelacha Street, Rosh Haayin 4809139, Israel

Woojer USA, Inc., 3060 Mercer University Dr Ste 110 # 527, Atlanta, GA 30341, USA

Phone: +1 (351) 213-6246

EU and UK representative: Prighter, https://prighter.com/q/19052319817