We collect only the information necessary to operate and improve our Services. This may include:

A. Information You Provide

If you create an account or are provided one by your school or organization, we may collect:

• Name (optional)
• School or organization name
• Email address (may be a school-issued email)
• Password or authentication credential (encrypted)

B. Automatically Collected Data

When you use our Services, we may automatically collect:

• General usage data (screens viewed, time spent, device type, browser type)
• IP address (used only for security and analytics purposes)
• Aggregated location data (to display relevant local wellness content)

C. Analytics

We use Google Analytics or similar tools to help us understand how users engage with the content.
These analytics are aggregated and anonymized — they do not identify individual users.
Data insights are shared only with the participating school or community organization for educational and wellness improvement purposes.

How We Use Information

We use collected data to:

• Provide, operate, and maintain the Services
• Customize wellness content by location or organization
• Improve usability and engagement
• Communicate updates, new content, or technical support information
• Generate anonymized insights for schools or organizations

We do not sell or rent personal information!

Legal Basis for Processing (if applicable)

Depending on your location, our legal bases for collecting and processing data include:

• Consent (when you create an account or agree to terms)
• Legitimate interest (for analytics and service improvement)
• Contractual necessity (for account-based access and functionality)
• Legal obligation (when required to comply with applicable laws)

Data Sharing and Disclosure

We may share data only under these conditions:

• With your school or organization, to support wellness reporting and program evaluation
• With service providers (e.g., analytics or hosting vendors) who process data on our behalf under confidentiality agreements
• As required by law, such as to comply with legal obligations or respond to lawful requests
• In aggregated, de-identified form, for research or reporting that cannot identify individuals

We never sell personal information to third parties.

Data Retention

We retain personal information only as long as necessary for the purposes stated in this Policy or as required by law.
Analytics and aggregated data may be retained longer for reporting purposes, but they do not identify individuals.

Children’s Privacy (COPPA Compliance)

We comply with the Children’s Online Privacy Protection Act (COPPA).

• Users under 13 may use the app without creating an account, and no personal information is collected from them.

• We do not knowingly collect or store personal data from anyone under 13.
  If you believe a child under 13 has provided personal data, please contact us immediately at support@wellhubs.app so we can delete the information.

Student Privacy (FERPA Considerations)

If you are using the Services through a school or educational organization, data may be protected under the Family Educational Rights and Privacy Act (FERPA).
In such cases, the school or organization controls access to educational records and acts as the primary custodian of any personally identifiable student information.

Your Rights

Depending on your state or jurisdiction, you may have the right to:

• Access, correct, or delete your personal information
• Opt out of certain data uses or analytics
• Receive a copy of your data (data portability)
• Request information about how your data is shared

Requests can be made by contacting us at robert@wellhubs.app
We may verify your identity before fulfilling requests.

State Privacy Law Compliance

We strive to comply with all applicable U.S. state privacy laws, including but not limited to:

• California Consumer Privacy Act (CCPA) / CPRA
• Virginia Consumer Data Protection Act (VCDPA)
• Colorado Privacy Act (CPA)
• Connecticut Data Privacy Act (CTDPA)
• Utah Consumer Privacy Act (UCPA)

Where these laws require specific disclosures or rights, we will honor them as applicable.
If a provision of this Policy conflicts with a state law, that state’s law shall govern for users in that jurisdiction.

Data Security

We use industry-standard security measures to protect your information, including:

• Encrypted transmission (HTTPS)
• Secure cloud storage
• Access controls and authentication protocols
• Regular data backups and monitoring

While we take reasonable precautions, no online system is completely secure. Users are encouraged to keep their credentials confidential.

Data Storage and Transfer

Your data may be processed or stored on servers located in the United States.
If you access the Services from another country, you consent to the transfer and storage of your information in the U.S. where privacy laws may differ.

Third-Party Links

Our Services may include links to external websites or content providers.
We are not responsible for the privacy practices or content of third-party sites. Please review their policies before interacting with them.

Policy Updates

We may update this Policy from time to time to reflect new legal requirements or changes in our practices.
When updated, we will revise the “Effective Date” above and notify users by posting a notice within the app.

Contact Us

For questions, concerns, or privacy requests, contact us at:
Email: support@dynamicinfluence.com