Privacy Policy

PRIVACY POLICY

The International WELL Building Institute pbc and its subsidiaries including IWBI (UK) Limited (“IWBI,” “we,” “us,” or “our”) is committed to protecting your privacy and the data on the wellcertified.com website and the WELL digital platform (ataccount.wellcertified.com), (together with all microsites or subdomains hosted thereunder) (collectively, the “Site”). To demonstrate this commitment, we have adopted this privacy policy (this “Policy”). The Policy is designed to help you understand generally how the Site collects, uses or discloses information about you. Your visit to the Site is subject to this Policy and our Terms of Use; by accessing the Site you acknowledge and agree to accept the Policy, which we may amend at any time. If we update this Policy, we will post the updated Policy here. Any such changes will be effective upon posting. You should consult the “Privacy Policy” bar on the Site each time you visit the Site. If you do not agree with this Policy, you should not use the Site.

I. NOTICE OF OUR POLICY
This Policy tells you, among other things, what information we gather from you and how we may use or disclose that information. Please read this Policy carefully, and feel free to contact us at privacy@wellcertified.com or via any of the methods contained on https://www.wellcertified.com/contact if you have questions about this Policy or if you would like to update or remove information you have provided to us. Please note that this Policy applies only to the Site, and not to any other website linked to ours, including any social media websites linked to the Site. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them. This Policy does not concern your interaction with IWBI in any matter other than your use of, and does not address our privacy practices except with respect to, the Site.

II. WHAT TYPES OF INFORMATION ARE COLLECTED AND HOW WE MAY USE IT
We may collect personally identifiable information or non-personally identifiable information. Personally identifiable information (or personal information) is information that personally identifies you, such as your name, telephone number, postal address and email address (or other information that is associated by us with such information), and non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregated data about visitors to and usage of the Site. Information can be collected if you submit it to us or it may be collected through technology.

We process personal data consistent with our disclosures in this Policy, based on at least one of the following legal grounds: (1) with your consent; (2) as necessary to perform our obligations under any agreement we may have with you or to respond to your requests; (3) as necessary to help protect the security of the Site and protect against harm to the Site and its users, to fulfill obligations under applicable laws, regulations, industry standards, and government requests, and (4) as necessary for purposes of our legitimate interests, including to provide services related to the Site, so long as such interests do not override the fundamental rights and freedoms of data subjects which require protection of personal data.

We rely on the following legal basis whenever we send you electronic communications that contain information about our products and services that we believe may interest you (“Marketing Materials”): your explicit consent which you may withdraw at any time by following the instructions on our unsubscribe tool contained within the body of the Marketing Communications or on our Site; or (where we have not obtained your explicit consent and you have an existing relationship with us in relation to our products and services) it is necessary for our legitimate interest of marketing our products and services.

When relying on our legitimate interest we will always provide you with an opportunity to opt out of receiving Marketing Materials.

a. Information submitted by you
At times, we may ask you to provide information about yourself in order to better serve you, or you may choose to provide information in order to take advantage of certain features on the Site, and you may submit information via the WELL digital platform in connection with your application for WELL Certification, WELL Rating or WELL Score or other IWBI license pursuant to your WELL Certification, WELL Rating or WELL at scale agreements, Works with WELL, IWBI membership or other agreement with IWBI. Personal information you may submit may include your name, email address, job title and contact information.

We may use certain personal information we collect about you when you visit and browse the Site as part of our normal business operations, to provide services to you, to fulfill obligations to you under agreements, or to send you administrative communications either about your interactions with us or about features of the Site, including any future changes to this Policy. We may use your email address to contact you directly regarding services or products that we believe may be of interest to you. You may also submit your information to us when you use certain features on the Site such as your name, job title, company and/or industry, email address, phone number, mailing address, or whether you have an active project seeking certification or when you register to take the WELL Accredited Professional exam. For instance, you may provide information if you use any of the following features available on the Site:

To Join Our Mailing List, Submit a Question through our Contact page, View a Report or other Resource, Register for a Webcast, or Request a Speaker:

If you sign up on the Site to join our mailing list and receive updates, if you request that one of our team members speak at your event, to register for a webcast, or if you submit a question or request additional information about our programs or view or download a report, we will collect, store and use your email address to send you such information and to keep you updated on products and services that may be of interest to you. We will also collect and store your name, as well as other personal information you may choose to provide to us, such as your postal address and telephone number, and professional and employment information. We may use this information to provide you with additional information that may be of interest to you.

If you submit project or portfolio information via the WELL digital platform:
If you submit an application on the WELL digital platform, you may provide information about your project or portfolio including, for example, project location; construction information; number of occupants; project owner, and personal information may include business contact information of project team members such as their email addresses and/or telephone number. We will collect, store and use this information to process and assess your application and provide services to you. You are advised to keep your log-in information confidential when using the Site or any other website to which you are disclosing personal information.

To register for the WELL Accredited Professional (“WELL AP”) exam, purchase content, publications or any merchandise that may be available on the Site:
In order to make a purchase on the Site, you may provide your name, title, address, phone number, email address, credit card and billing information, birth date and other relevant data. We will collect, store and use such information, including via our service providers, in order to process your order or registration and, for the WELL AP exam registration, to confirm your identification when you take the exam. We do not require this information to obtain access to any area of the Site; however, you may be required to create a new account or log-in as a registered user prior to ordering any products or services on the Site. You are advised to keep your log-in information confidential when using the Site or any other website to which you are disclosing personal information.

To complete a survey or use any of the other resources available on the Site:
You may provide information if you choose to participate in an online survey or use other resources on the Site. Such information may include your job title, company, applicable industry, email address, phone number, mailing address, or whether you have an active project or portfolio seeking WELL Certification or a WELL Score, as applicable. We will collect, store and use such information to follow up with you on your survey results, provide our services to you and keep you updated about products and services that may be of interest to you.

To apply for a job:
If you apply for a job through the Site, you may provide your name, address, phone number and email address and other relevant information. We will collect, store and use information you provide to us for purposes of assessing your application.

b. Non-personal information and aggregated data

We may use non-personally identifiable information, de-identified information and aggregated data to understand better how our visitors use the Site; to measure number of visits, average time spent on the Site and pages viewed; to provide visitors with customized services and information, and to gather other relevant statistics and information. We collect this information to assess the use of the Site, provide better service to Site visitors and to improve the content of the Site. Such information, and other information we derive from individual users’ information, allows us to continue to grow and provide you with quality information through more accurate marketing and advertising of the Site. Information that has been de-identified will not be reidentified.

Information collected by technology such as cookies

We and third parties we may engage or work with use technologies such as cookies to help you use our services more easily and to provide us analytics and help us continuously improve the Site and services we provide to you. Personal and non-personal information that may be collected using such technologies may include IP addresses, time spent on pages of the Site and geolocation information, a user’s internet service provider, and other internet activity such as browsing and search history. A “cookie” is a small data file that a website can send to your browser, which may then be stored on your hard drive to help the Site “remember” information about you when you return to the Site, such as your preferences for the Site or account identifications. Cookies on the Site may be used to make your experience more efficient, personalize content, provide social media features and to analyze how visitors use the Site and services.

Types of cookies that may be used on the Site include:

• Necessary cookies, which make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
• Preference cookies, which enable a website to remember information that changes the way the website behaves or looks, such as your preferred language or the region that you are in.
• Statistics cookies, which help website owners to understand how visitors interact with a website by collecting and reporting information anonymously.
• Marketing cookies, which are used to track visitors across the Site with the intention to display content and information that is relevant and engaging for the individual user.

You may have the option of setting your browser to reject cookies; however, doing so may affect the performance of the Site or restrict the way in which we may provide our services to You. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. For more information about cookies that may be collected on the Site or to review or update your preferences regarding cookies on the Site, please refer to IWBI’s Cookie Notice.

We store the personal information we receive as described in this Privacy Policy for so long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide, develop and improve our services, resolve disputes, establish legal defenses, conduct audits and assessments, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws and industry standards.

III. HOW DOES IWBI DISCLOSE MY INFORMATION?
We may share non-personal and aggregated information we collect from the Site in a manner permitted by law including to other companies with whom we conduct business.

We may disclose your personal information to our affiliates, service providers (including entities and individuals we engage to perform functions on our behalf and to help us to operate the Site and business and deliver our services to you), or we may disclose certain information if you consent to such disclosure or based upon corporate events or legal requirements. Some of these service providers may include technology and other consultants, attorneys, accountants, clerical staff, website or database hosting companies, analytics companies, e-commerce providers and financial institutions (for the purpose of processing credit card transactions if you make a purchase on the Site), and education providers and continuing education systems (if you use or access courses on our education portal and for continuing education reporting purposes). To better provide services to you, including WELL coaching and support, we may communicate with project team members with contact information provided via the WELL digital platform, including via third party email communication tools and customer service platforms. These entities and individuals will have access to your personal information to the extent necessary to perform services on our behalf. For additional information on how we may share information for continuing education reporting purposes, please review the WELLTM education portal section of our

Terms of Use.
IWBI does not sell personal information for monetary consideration. The Site does use third party cookies as further described above and in our Cookie Notice. If you would like to review the types of cookies used on the Site and/or alter your preferences, please visit our Cookie Notice or contact us at privacy@wellcertified.com or via any of the methods contained on https://www.wellcertified.com/contact.

We may also disclose your personal information if legally required to do so, if requested to do so by a government entity, or if we believe in good faith that such action is necessary to conform to legal requirements or comply with legal process, protect the rights or property of IWBI, prevent a crime, or protect the integrity of the Site and personal safety of our users or the public.

We may also disclose and transfer your personal information to a third party who acquires any or all of our assets, whether by way of acquisition, merger, consolidation, or purchase of all or a substantial portion of our assets. In addition, in the event IWBI becomes the subject of an insolvency proceeding, whether voluntary or involuntary, IWBI or its liquidator, administrator, receiver or administrative receiver may sell, license, or otherwise dispose of such information in a transaction approved by the court.

IV. HOW CAN I WITHDRAW CONSENT OR OPT-OUT OF RECEIVING EMAIL COMMUNICATION?
You may withdraw your consent or opt-out of receiving certain communications from the Site. We will not send certain unsolicited messages to you if you indicate that you do not wish to receive such messages. If you wish to make such a request, please contact privacy@wellcertified.com.

V. SECURITY
The security of your information is important to us, and we endeavor to protect your personal information, and international transfers of personal information will be required to be subject to appropriate safeguards. We have implemented appropriate technical and organizational security measures to protect the information we process about you. When you use any website, we encourage you to protect your information and use precautions including but not limited to using strong passwords, and not sharing your password and account information with any other person.

VI. THIRD PARTY SITES
The Site may contain links to other websites, including, for instance, social media sites, online survey administrators, the WELL AP testing provider website, and the WELL Forum hosting provider Please review the privacy policies of the WELL AP testing provider Prometric here and information about the WELL Forum hosting provider Mighty Networks’ privacy practices here. We cannot be and are not responsible for the privacy practices of such third-party sites. If you provide any information to parties who operate websites that are linked to or from the Site, use or disclosure of your personal information will be governed by those third-party website policies. We encourage you to review other websites’ policies and privacy practices before revealing personal information. Under no circumstances shall IWBI have any liability whatsoever for the activities conducted by or at any website accessed from or through the Site.

VII. INFORMATION REGARDING CHILDREN
The Site is not directed to children (persons under 13 years of age), and IWBI does not knowingly collect any personal information from children. If you are concerned about your child’s use of the Site, you may use web-filtering technology to supervise or limit access to the Site. If a child under 13 has provided personally identifiable information to us through the Site, a parent or guardian may inform us at privacy@wellcertified.com, and we will use commercially reasonable efforts to delete it from our database, subject to applicable law and this Policy.

VIII. ONLINE TRACKING
IWBI does not track its website visitors over time and across third party websites to provide targeted advertising and therefore the Site does not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. Your browser allows you to set a DNT signal to let third parties know you do not wish to be tracked. You should consult the help pages of your browser to set your preferences.

IX. CALIFORNIA RIGHTS; INFORMATION REQUESTS
Subject to applicable law and depending on where you reside, you may have the right to request access to and correct personal information we maintain about you, to request the restriction of processing of your personal information, or to object to that processing on grounds relating to your particular situation. In addition, you may have the right to request erasure of your personal information in certain circumstances provided by applicable law. Please note that if you exercise any of these rights under applicable laws, in order to verify your identity, we may request you provide us with personal information prior to accessing any records containing information about you. If you wish to receive information about how your information is used or otherwise exercise any of these rights, or if you wish to submit a complaint, please contact privacy@wellcertified.com.

California residents are entitled under California state law to request from us once per year information regarding disclosure of your personal information by International WELL Building Institute PBC or its subsidiaries to a third party for that third party’s direct marketing purposes. If you would like to request such a list please contact us at 220 Fifth Avenue,8th Floor. New York, New York 10001, privacy@wellcertified.com. California residents and residents from other jurisdictions may also have the rights under applicable privacy law including the right to know and access their personal information, right to correct personal information, the right to delete personal information subject to certain exceptions, the right to opt out of “sales” or “sharing” for cross-context behavioral advertising or targeted advertising and the right not to be discriminated against for exercising privacy rights under applicable laws.

X. INTERNATIONAL USE
This Policy is intended to meet the laws and regulations of the United States, and despite the global nature of the internet, IWBI makes no claims that the content or the Site are appropriate or may be viewed or used outside the United States. If you are visiting the Site from outside the United States, be aware that your information may be transferred to, stored and processed in the United States. By using the Site and services related to the Site, you acknowledge the transferring to and storage of this information within the United States. Those who access the Site from outside the United States do so on their own initiative and are responsible for compliance with local laws, rules and regulations.

Last Updated: September 15, 2023