To ensure a better experience, your information is managed as described in this Privacy Policy. Using the Service means you agree.
Interpretation and Key Terms
Interpretation
Words with capital letters have specific meanings listed below. These meanings apply whether used in singular or plural.
Key Terms
Affiliate: A company related by ownership or shared control (50% or more voting rights).
Application: Refers to WellMe, the mobile app provided by Urbanwall Mobile Limited.
CCPA / CPRA: California privacy laws that protect residents' personal data.
Company: Refers to Urbanwall Mobile Limited, also called "We," "Us," or "Our." Acts as the Data Controller under GDPR.
Consumer: A California resident as defined by CCPA/CPRA.
Data Controller: The organization that decides how and why your personal data is used (here, the Company).
Device: Any tool used to access the app, such as a smartphone or tablet.
GDPR: The EU's data protection law.
Personal Data: Any information that can identify you or be linked to you (e.g., name, ID, location, online ID).
Service: The app and its related features.
Service Provider: A person or company helping us operate or analyze the app. Also known as a Data Processor under GDPR.
Usage Data: Info automatically recorded when you use the app (e.g., screen time, button clicks).
You: The person using the app, or the person you act on behalf of.
Collection and Use of Personal Information
Types of Information We Handle
Personal Information
To use certain features of the Service, you may be asked to provide details that can identify or contact you—such as your email address or usage data.
Usage Data
We automatically gather technical data during your use of the Service. This may include:
IP address
Browser type and version
Pages viewed and time spent
Access dates and times
Device identifiers
Diagnostic data
If you use a mobile device, we may also receive:
Device model
Unique mobile ID
Mobile IP address
Mobile OS and browser type
Other technical identifiers
Your browser or device may also send us data automatically while you interact with the Service.
Information from Application Use
Some data may be used to personalize your experience. Depending on how you use the Service, it may be stored on your device or sent to our servers or those of third-party providers. You can adjust data access permissions anytime via your device settings.
How We Use Your Personal Information
We may process your data to:
To operate and maintain the Service, including monitoring user activity
To fulfill contractual obligations and support ongoing service agreements
To contact you via email or notifications about updates, features, or security matters
To respond to and manage your support requests
To handle business changes like mergers, asset sales, or restructuring involving user data
To analyze data, understand trends, and improve our Service and overall experience
When We Share Your Information
Your data may be shared:
During business transactions such as mergers or restructuring
With affiliates under common ownership
With partners helping deliver parts of the Service
In public areas, if you post or share content there
With your consent, for other specific purposes
Data Retention
We keep your Personal Data only as long as needed for the purposes outlined in this Privacy Policy. In some cases, we may retain it longer to meet legal requirements, resolve disputes, or enforce our agreements.
Usage Data is generally kept for shorter periods unless needed for security, functionality, or compliance.
Transfer of Personal Information
Your information may be processed in locations outside your state or country, including places with different data protection laws. By using the Service and sharing your data, you agree to these transfers.
We take reasonable steps to ensure your data is handled securely and in accordance with this Privacy Policy. We will not transfer your data to any country or organization without appropriate safeguards in place.
Deleting Your Personal Information
You have the right to request deletion of your Personal Data. We support this right and offer tools within the Service to help you remove certain information directly.
You may also update, correct, or delete your data through your account settings. Alternatively, you can contact us to request access, changes, or deletion.
Some data may be retained if required by law or for valid legal reasons.
Disclosure of Personal Information
We may share your Personal Data in these situations:
Business changes: If the Company is sold, merged, or reorganized
Legal requests: When required by law or government authorities
Protection purposes: To enforce our rights, prevent misuse, ensure safety, or respond to legal claims
You'll be notified if a new Privacy Policy applies after a transfer.
Data Security
We take reasonable steps to protect your Personal Data. However, no online system or storage method is completely secure. While we work to safeguard your information, we cannot guarantee absolute protection.
How Your Data Is Processed
Some third-party providers may access or process your data to support our Service. Their handling of your data follows their own privacy policies.
Analytics Services
To understand and improve how the Service is used, we may use third-party analytics services:
Google Analytics
Tracks how users interact with the Service. Google may use this data for reporting and ad personalization. You can manage tracking through your device settings or Google's privacy tools:
https://policies.google.com/privacy
https://support.google.com/analytics/answer/6004245
Firebase
Helps us monitor usage and performance. You can limit data use through device ad settings or Google's guidance:
https://policies.google.com/privacy
https://policies.google.com/technologies/partner-sites
GDPR Privacy Compliance
Legal Basis for Processing
We may process your Personal Data based on the following legal grounds:
Consent: You've agreed to specific uses of your data
Contract: Processing is needed to fulfill or prepare a contract with you
Legal obligation: Required by applicable law
Vital interests: To protect your or another person's vital interests
Public interest: For tasks carried out under official authority
Legitimate interests: For purposes we consider justified, unless overridden by your rights
We'll clarify the legal basis if needed, including whether providing data is mandatory by law or contract.
Your GDPR Rights
If you are in the EU or EEA, you may:
Access your data
Correct inaccurate or incomplete details
Object to processing based on legitimate interests
Delete data where no lawful reason remains
Request portability of data provided by consent or contract
Withdraw consent at any time (some features may then become unavailable)
How to Exercise Your Rights
Contact us to make a request. We may verify your identity before responding. You also have the right to lodge a complaint with your local Data Protection Authority.
CCPA/CPRA Privacy Notice (California Residents)
This section applies only to California residents and supplements our general Privacy Policy.
Categories of Personal Information We May Collect
In the past 12 months, we may have collected the following categories of personal data:
A. Identifiers (e.g., name, email, IP address) – Yes
B. Customer Records (e.g., contact info, ID numbers) – Yes
C. Protected Class Info (e.g., age, gender) – No
D. Biometric Data – No
E. Internet Activity (e.g., Service interactions) – Yes
F. Geolocation – No
G. Sensory Data – No
H. Employment Info – No
I. Education Records – No
J. Inferred Profiles – No
K. Sensitive Info (e.g., login credentials) – Yes
Exclusions
We do not include:
Public government records
Deidentified or aggregated data
Data covered by laws like HIPAA, GLBA, or FERPA
Sources of Information
We collect data:
Directly from you (e.g., forms, preferences)
Through usage (e.g., feature interactions)
Via automated tools (e.g., cookies)
How We Use Personal Information (California Residents)
In line with CCPA/CPRA "business purposes," we may use or disclose your personal data to:
Provide and improve our Service
Offer customer support and respond to requests
Comply with legal obligations
Perform audits and internal operations
Detect and prevent fraud or security issues
Fulfill one-time operational needs
Any other use disclosed at the time of collection or permitted by law
If we begin using your data for new or unrelated purposes, we will update this Privacy Policy.
Disclosure of Personal Information
In the past 12 months, we have used or disclosed the following categories for business purposes:
A. Identifiers
B. Customer Records (Cal. Civ. Code §1798.80)
E. Internet Activity
This does not mean all data types listed were disclosed—only that some information from each category may have been shared.
We require recipients to keep your data confidential and use it only as agreed.
Sharing Personal Information
We may have shared your personal data with:
Service Providers
Affiliates
Business Partners
Third parties you or your representative authorized
Sale of Personal Information
Under CCPA/CPRA, "sale" includes any exchange of personal data for value, including non-monetary benefit.
In the past 12 months, we may have sold personal data from these categories:
A. Identifiers
B. Customer Records
E. Internet Activity
Listing a category does not mean all types of data were sold—only that some may have been.
Sale of Personal Information of Minors Under 16
We do not knowingly collect or sell data from users under 16.
For users aged 13–16, we require opt-in consent.
For users under 13, consent must come from a parent or guardian.
Consent can be withdrawn at any time. To report a concern, please contact us.
Your CCPA/CPRA Rights
As a California resident, you have the right to:
Notice – Know what data we collect and why
Access – Request details or a copy of your personal data
Opt-Out – Stop the sale or sharing of your data
Correct – Fix inaccurate personal information
Limit – Restrict how sensitive data is used
Delete – Ask us to remove your data (with legal exceptions)
Non-Discrimination – Exercise your rights without being treated unfairly
To exercise these rights, use the provided contact methods or visit relevant opt-out sections.
Exercising Your CCPA/CPRA Rights
California residents may exercise their rights by contacting us:
Requests must come from you or an authorized representative. We will:
Verify your identity or authority
Require enough detail to process your request
If verified, we'll respond within 45 days at no cost. An extension of up to another 45 days may apply with notice. Responses cover the 12 months prior and, if applicable, will be provided in a portable format.
Do Not Sell My Personal Information
Under CCPA/CPRA, "sale" includes sharing data for value (not always monetary). You can opt out at any time.
Some analytics or third-party tools may qualify as "sales"
Opt-out is browser-specific and requires repeating on each browser
Use site options like "Privacy Preferences" or "Do Not Sell My Info" to update choices
An opt-out cookie will store your preference; clearing cookies resets it
Limit Use of Sensitive Personal Information
You may request that we limit how your sensitive personal data is used—only to deliver the expected service.
We do not use or disclose this data beyond what's necessary for Service operation. Contact us for more.
Children's Privacy
We do not knowingly collect data from children under 13. If you believe a child has submitted personal data, contact us.
We will delete such data unless verified parental consent is provided where legally required.
External Links
Our Service may contain links to third-party sites we do not operate. We recommend reviewing their Privacy Policies. We are not responsible for their content or data practices.
Privacy Policy Updates
We may update this Privacy Policy from time to time. Changes will appear on this page, with a revised "Last Updated" date.
We may also notify you by email or through the Service. Please review this policy regularly. Updates take effect upon posting.
Contact Us
For any questions about this Privacy Policy, contact us: