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UC San Diego Health - Willo Mobile Application

Privacy Policy

(Español)

Last Updated: October 1, 2024

Welcome to the UC San Diego Willo App Statement of Privacy Practices.

I. SCOPE OF THIS PRIVACY STATEMENT

This Statement of Privacy Practices explains how the UC San Diego collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our Willo Mobile Application (“Willo App”), and the related content, platform, services, products, and other functionality offered on or through the Willo App. 

When we collect personal information that is part of a UC San Diego student educational record ("Student Data"), we collect, use, store, and otherwise process such information in accordance with the Family Educational Rights and Privacy Act (FERPA). Personal information collected from non-students is governed by the California Information Practices Act (Cal. Civ. Code §1798 et seq).

II. WHO WE ARE AND WHAT WILLO IS

University of California, San Diego is a research university in San Diego, California (collectively, “UC San Diego”, "we", "us" or "our"). UC San Diego has developed the Willo App, which is a personalized self-care app designed to meet the wellness needs of enrolled UC San Diego students. 

UC San Diego is the controller of the personal information we hold about you in connection with your use of the Mobile App. This means that we determine and are responsible for how your personal information is used.

III. WHAT IS PERSONAL INFORMATION?

When we use the term "personal information" in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes "personal data", "personal information," or "personally identifiable information."

IV. OUR COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information in a variety of ways. For example, you may provide us your personal information when you contact us. We may link or combine your activities and information collected from you on the Willo App with information we receive from third parties. This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You

We may collect the following categories personal information submitted to us by individuals through the Services:

  • Login information. The following information is collected when you log in using your UCSD AD credentials: Email address, student or employee ID, year, and major.
    • Biometric Data (Face ID/Touch ID): For your convenience, you may opt to log in to the app using biometric authentication, such as Face ID or Touch ID, provided by your device. The app does not collect, store, or process any biometric data. All biometric information is securely stored on your device by the device’s operating system and is not transmitted to or accessible by us. 
  • If you choose to enable biometric login, your device’s operating system will confirm your identity using the biometric data already stored on the device. We advise that you only allow your own biometric data to be registered on your device to prevent unauthorized access to your account.
  • Inquiry and Communications Information, including information provided in custom messages sent through the forms, to one of our email addresses, or via phone. We use this information to investigate and respond to your inquiries, to communicate with you, to enhance the Willo App, and to manage and grow our organization.
  • Survey Information, including information provided in any questions submitted through surveys. We use this information to administer and facilitate the Willo App, to respond to your submission, and to communicate with you.
  • Events and Conferences Registration Information, including any information provided though the registration form.
  • Feedback Information. We may collect feedback you provide relating to the Willo App. We use this information to communicate with you, inform our design and development activities, and improve the Willo App.

Information Automatically Collected; Information received from other parts of UC San Diego

As is true of many digital properties, we and our third-party partners may automatically collect information you provide to us and information about how you access and use the Willo App:

  • Log Data, including internet protocol (IP) address, location derived from IP address, operating system, device type and version, date/time of visit, other user agent string data, the time spent on our app, how frequently you access the app, and any errors that may occur during the visit to our app. Log data may overlap with the other categories of data below.
  • UC San Diego Registrar:  We receive the following FERPA information about students from the UC San Diego Registrar: Student IDs, year at UC San Diego, and major. 

Through the provision of the Willo App, we may also process de-identified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular user. UC San Diego commits to maintain and use the information in de-identified form and will not attempt to re-identify the information, except in instances where necessary for determining whether the de-identification process used by UC San Diego satisfies the requirements under applicable law.

Additional Uses of Personal Information

We may use personal information we collect to:

  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested;
  • Manage our organization and its day-to-day operations;
  • Register you for and provide you access to events and conferences;
  • Communicate with you, including via email, and/or telephone calls;
  • Request that you complete surveys about our organization, organizations we partner with, and the Willo App;
  • Administer, improve and personalize the Willo App, including by recognizing an individual and remembering their information when they return to the App;
  • Personalize the Willo App by developing, training, and utilizing Willo App’s artificial intelligence (AI) system, which analyzes user interests and needs to provide customized information to users. There are two types of personalization within the Willo App - personalization based on tags and personalization based on usage and behaviors on the App. Personalization based on tags is not used to train the AI system. Personalization based on usage and behaviors on the App will be used to develop and train the Willo App.
  • Identify and analyze how individuals use the Willo App and services provided through the app, and to improve and customize the App to address the needs and interests of our user base and other individuals we interact with;
  • Test, enhance, update and monitor the Willo App, or diagnose or fix technology problems;
  • Help maintain the safety, security and integrity of our property and Willo App, technology assets and business;
  • To enforce our agreements, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • To fulfill any other purpose for which you provide personal information and or any other lawful purpose, or other purpose that you consent to.
  • To identify users who may be interested in participating in an IRB research study.

Any information acquired by UC San Diego through the Willo App  is subject to the limitations set forth in Family Educational Rights and Privacy Act (FERPA) for students and the California Information Practices Act of 1977 (Civil Code Section 1798, et seq.) for non-students.

V. OUR DISCLOSURE OF PERSONAL INFORMATION

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

  • Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as calendering.
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
  • Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws or to respond to lawful requests and legal process;
    • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
    • to detect, suppress, or prevent fraud;
    • to protect the health and safety of us and others; or
    • as otherwise required by applicable law.
  • With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with your consent or direction. For example, with an individual's consent or direction we may post your testimonial on our sites or service-related publications.

VI. HOW WE SAFEGUARD YOUR INFORMATION

Willo App will not distribute or share "electronically collected personal information" (as defined in subdivision (d) of California Government Code Section 11015.5) about users to any third party without the permission of the user, except in narrow circumstances as set forth in this Privacy Statement, such as instances when authorized under law (including but not limited to the Information Practices Act and FERPA), or to assist another state agency or public law enforcement organization in any case where the security of a network operated by a state agency has been, or is suspected of having been, breached. Willo App will not sell any electronically collected personal information to any third party. Such electronically collected personal information is exempt from requests made pursuant to the California Public Records Act (Chapter 3.5 (commencing with Section 6250) of Division 7 of Title 1).

VII. YOUR RIGHTS AND CHOICES OVER YOUR INFORMATION

You may control your information in the following ways:

  • Willo uses your information in development, training, and utilization of AI systems based on your usage and behaviors on the Willo App. If you do not want your information used in this manner, you may choose not to use the Willo App.
  • Modifying or Deleting Your Information. You may delete the information collected and used by the App by selecting “Delete Account” in the App settings. If you have any questions about reviewing, modifying, deleting or exercising your option of having your personal information discarded without reuse or distribution (pursuant to California Government Code section 11015.5), you can contact us directly by sending a written request to the postal or email address set out in the Contact Us section, below and in the app. We may not be able to modify or delete your information in all circumstances.

VIII. CHILDREN'S PERSONAL INFORMATION

The Willo App is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use the Willo App or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

IX. LINKS TO THIRD-PARTY WEBSITES OR SERVICES

The Willo App may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Statement, this Statement does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

X. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Statement from time to time. When we make changes to this Statement, we will change the date at the beginning of this Privacy Statement. If we make material changes to this Privacy Statement, we may notify individuals by email to their registered email address, by prominent posting on the Willo App, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided. We encourage you to review this Privacy Statement frequently to be informed of how we are processing your information.

CONTACT US

If you have any questions or requests in connection with this Privacy Statement or other privacy-related matters, please contact us by using one of the following methods:

Website: Willo.ucsd.edu

E-mail: willoapp@ucsd.edu

 

Deactivating Your Account

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