We realize that asking you to share information about your health is asking a lot. In order to begin to earn your trust, we provide this Privacy Policy explaining our online information practices and the choices you can make about the way your information may be collected and used. We promise to protect information that personally identifies you (“Personal Information”) with the same vigor we would employ to protect our own. We are a company conceived, developed, and managed by HIV+ women and those who have spent their lives and careers caring for them. We understand how important your privacy is. To make the Privacy Policy easy to find, we make a link to it available on our homepage and at every point where Personal Information may be requested.

The Well Project, Inc A Not For Profit Corporation, is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site www.thewellproject.org. Because we want to demonstrate our commitment to our users’ privacy, we have agreed to disclose our privacy practices and have them reviewed for compliance by TRUSTe. 

If users have questions or concerns regarding this statement, you should first contact customerservice@thewellproject.org. If you do not receive acknowledgment of your inquiry or it is not satisfactorily addressed, you should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process at https://www.truste.org/pvr.php?page=complaint. TRUSTe will serve as a liaison with the Web site to resolve users concerns.

We will inform you of the following in this Privacy Policy:

• What information The Well Project collects
• Who is collecting the information
• How The Well Project will use the information we collect
• With whom the information may be shared
• What choices you have regarding collection, use and distribution of your information
• What kind of security procedures The Well Project has in place to protect the loss, misuse or alteration of information under our control
• How you can correct any inaccuracies in the information

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The Well Project is the sole owner of the information collected on www.thewellproject.org. We collect information from our users at several different points on our website as described below. The Well Project does not share, sell, rent, or trade Personal Information with third parties for promotional purposes.

You may use much of The Well Project website without registering or submitting any Personal Information. In that case, the only information we collect will be non-personal information collected through the use of cookies (see details below).

We have provided certain services and features of the site which, by their very nature, require registration. In order to become a member of The Well Project through registration, we require that you provide us with a valid e-mail address and a password of your own choosing, a Discussion group nickname, a “Forgot Password Answer” in order to automate the recovery of a forgotten password, and a generic reason for using the site. This information is stored securely in our user profile database.

We use the information that you provide through registration to respond to questions from you and/or inform you of significant changes to this Privacy Policy, to help manage your registration, and to protect the rights of all users of this site from inappropriate use by another user. We may also use this information to send you e-mails of newsletters or site updates with content that you may elect to receive.

You can always opt-out of receiving such e-mails or unsubscribe to newsletters at the time you register or at any time thereafter from the Sign Up Information and Change Password links on the My Well Home page.

The very first time you log in as a registered member of The Well Project, you will be directed to a page that expressly requests that you share information about yourself, your current health, and your historical experience living as, or caring for, a woman with HIV disease. This information is critical to our mission and we hope that by demonstrating our commitment to your privacy, security, and anonymity, you will feel secure and willing to share this information about yourself. This information is entirely optional and will not in any way limit your ability to utilize the site or any of its features whatsoever. Like registration information, this optional personal information will be stored in our user profile database. You will also be able to change or update this personal information at any time from the Personal Information and HIV-related Information links on the My Well Home page.

By sharing your personal information, we have the best opportunity to learn about our community of women living with HIV disease and begin to understand how we might influence the development of education programs and research initiatives to improve the lives of all women living with HIV and AIDS. We ask you to share as much information as you possibly can to help us all achieve our end goal.

Your information is secure and encrypted and will never be shared with any third party in association with any means to personally identify you unless you expressly request The Well Project do so in order to involve you in an offline initiative you elect to participate in.

A cookie is a piece of data stored on the user’s computer tied to information about the user. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions.

Every computer is assigned a different cookie by The Well Project. The information collected by cookies helps us to statistically monitor usage patterns on our site and selected partners' sites. We may use cookie information to target certain information to your browser or to determine the popularity of certain content.  However, cookies are not tied to your personally identifiable information.

Your browser software can be set to reject all cookies. Most browsers offer instructions on how to reset the browser to reject cookies in the "Help" section of the toolbar. If you reject our cookie, certain functions and conveniences of our site may not work the way they were intended but you do not have to accept our cookie in order to productively use our site. If you accept our cookie, we will link your user id to site usage patterns.

When you use The Well Project's "E-mail a Friend" application, The Well Project e-mails the article or other content you designate to your friend's e-mail address and lists what you supply as your e-mail address as the sender. The Well Project uses the friend's e-mail address only for the purpose of sending your friend the e-mail you requested and for no other purpose.

Collectively, all of the information we have described that we collect through cookies, log files, and databases create a profile of our users. A profile is stored information that we keep on individual users that detail their usage patterns and their required and voluntary information shared through the Registration and Share Information process. Consequently, collected site usage information is tied to the user’s user id to provide tailored content for the user and to develop a more robust and meaningful understanding of our community.

Personally identifiable information collected by The Well Project through the online donation process is voluntary information. We ask you to provide us with your name and e-mail address. Wel also give you the opportunity to make your donation ‘in honor of’ or ‘in memory of’ an individual or group. If you choose to provide this information it will be stored in our database and used only for the purposes of (a) sending you an electronic receipt for your donation, and (b) listing your name on our web page titled “Supporters of The Well Project.” Please note you may choose to be listed by your name or as an anonymous supporter.

When you make an online donation to The Well Project additional personally identifiable information is collected by the third party vendor PayPal. The Well Project does not have access to the credit card or bank account information you enter on the PayPal web site. The Well Project contracts with PayPal because we believe PayPal to be a trusted, reliable, secure source for online donations. We encourage you to read the PayPal Privacy Policy to learn how PayPal uses and stores your personally identifiable information. When you make an online donation to The Well Project via PayPal, PayPal will notify The Well Project of your donation and provide us with your e-mail address. We will only use this e-mail address to send you an electronic receipt for your donation.

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We do not share your personal profile information with other third parties.  However, collective trends including your profile will be shared in aggregate form, allowing The Well Project to analyze data from our user population to generate research and program agendas to better serve our users. By sharing your personal information and experiences, you contribute to the collection of valuable data about women living with HIV disease. It is our fundamental belief that by sharing the collective voices of women living with HIV disease as well as the people who care for us, we can influence how the millions of dollars invested every year into treatment research, clinical trials, and education are spent. By becoming the most comprehensive and reliable resource for information about women with HIV and AIDS we also ensure our sustainability in the market so that we may continue to provide the education and community resources that serve our core mission: to improve the lives of women living with HIV and AIDS and those who care for them.

The Well Project may provide to third parties non-personal information about you that does not allow you to be identified or contacted and that is combined with the non-personal information of other users. This is what we describe as Aggregate Information. For example, we will produce reports for third parties regarding the number of users of our site and the activities they conduct while on our site. We might also inform a pharmaceutical company (that may or may not be partner on our site) that "25 percent of our users are women below the age of 25 or that 76 percent of our users are women infected with HIV." We may charge third parties for this Aggregate Information as a primary funding mechanism of our business plan.

All information that is received, used, or disclosed in connection with “My Well” is encrypted. This means that when the information is transmitted over the telephone or other communication wires, it is transmitted as a series of symbols and characters that are not readable by normal circumstances but which are later de-scrambled by a computer system that allows you to read the information and us to store the information within the safe confines of our respective computer environments.

The Well Project collects the Personal Information you voluntarily store in My Well. The Well Project does not use the Personal Information stored in My Well for any purpose except to provide members with a readily accessible, easy-to-update means of collecting and storing information, articles, slides, and data sets that are of particular interest to you. The only entities that will have access to My Well are The Well Project itself and any third parties hired by The Well Project to assist us in operating, maintaining, and improving the site. These third parties are required by us to hold your information in the strictest of confidence and may not use or disclose it except to fulfill the service we hired them to perform. The Well Project will not share any of the information that is stored in My Well with any other third parties without your express permission.

The Well Project will not disclose any Personal Information it gathers from you on our Website except as we have set forth in this Privacy Policy or as requested in writing by you. We may release Personal Information to third parties to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or in special cases, such as a physical threat to you or others. In the event that we are legally compelled to disclose your Personal Information to a third party, we will notify you unless doing so would violate the law or court order.

The Well Project employs third party contractors who sometimes have limited access to your Personal Information in the course of providing products or services to The Well Project. These contractors include technology specialists and analysts that provide us with services, and/or analysis related to improving the operation and managing the maintenance of our Website. Unless you have opted out of receiving e-mails and newsletters from The Well Project, these contractors also may have access to your e-mail address to send newsletters to you on our behalf or to send e-mails to you for purposes such as conducting market research on our behalf.

Access to your Personal Information by these contractors is limited to the information the contractor will require to perform this limited function for The Well Project. The Well Project requires that all third party contractors who have access to such Personal Information sign a contract agreeing to protect the privacy of your Personal Information under the guidelines of this Privacy Policy, and not to use or disclose your Personal Information for any purpose other than providing us with the services for which we have contracted them.

For your convenience we provide links to websites operated by companies other than The Well Project ("Third Party Websites"). These links may be referenced within content, or placed beside the names or logos of sponsors. The Well Project does not disclose your Personal Information to these Third Party Websites without first obtaining your consent. The Well Project does not endorse and is not responsible for the privacy practices of these sites. If you choose to link to one of these Third party Websites, you should review the privacy policy posted on the linked site to understand how that Third Party Website collects and uses your Personal Information and to decide whether or not you will agree to the terms of use of Third Party Website.

When you become a member of The Well Project, you are indicating your consent to permit The Well Project to store your username (e-mail address) and password in our database.

We provide a regular e-mail Newsletter that will inform you of new content on our site and special programs available through the web or otherwise, that may be of interest to you. You are automatically included to receive this Newsletter. You will have the opportunity during registration to opt out of this service by de-selecting the box associated with our e-mailing services. If we find information that may meet your profile, we will send you an e-mail notification of the new information. You may also elect to receive regular e-mails relating to new content on the site and/or news related to HIV and AIDS.

The Well Project will contact you if you notify us that you have lost or forgotten your password. We will contact you using the preferred method reported in your profile.

The Well Project will contact you periodically, but no more than once in a one-month period, when we have provided significantly new or different functionality to our Web site, so that you are aware of the new services and can decide whether to take advantage of them.

We will contact you in response to any inquiry you make to our support or service staff in regards to any question, suggestion, or comment you may have about this policy or about the site in general. Please use one of the e-mail addresses listed in our Contact Us section to submit any questions, suggestions, or concerns you may have.

Occasionally, we will e-mail you surveys or questionnaires to request feedback that can be used to enhance our site to better serve your needs.

You may indicate to The Well Project that you wish to receive no communications from The Well Project during registration or by editing your profile in the "My Well" section of “The Well Project” web site. If you so indicate, The Well Project will not contact you under any circumstances except to respond to a later communication initiated by you or to provide you with an activation e-mail upon joining or any change in your profile or user status.

On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance, we might send users an e-mail. Generally, users may not opt-out of these communications, though they can deactivate their account in order to stop these communications. However, these communications are not promotional in nature.

The Well Project will regularly review the Privacy Policy to ensure that it provides an appropriate level of protection for your Personal Information. From time to time, we may make changes to the Privacy Policy to keep it current with industry standards and to ensure it complies with the practices we employ on our site. We will post the date of the most recent revisions on this privacy policy page. We will also post a notice on our Home page of any substantial or significant changes to this policy which would materially affect your rights as described herein. Please check this page from time to time to make sure that you are current and up-to-date on our Privacy Policy. Please keep in mind that your use of our website means that you accept our Privacy Policy and Terms of Use as they may be amended at any time, excluding any substantial or materially significant changes which will otherwise be treated according to this policy.

The Well Project does not host or receive funding from advertising.

We are committed to protecting the privacy of children. This website is not designed or intended to attract children under the age of 13. We do not knowingly or purposefully collect Personal Information from any person under the age of 13.

This Privacy Policy does not protect you from third parties when you use The Well Project Discussion Boards. The Well Project features discussion boards and bulletin boards where users with similar topics for discussion can share information and support one another or where users can post questions for experts to answer. You should be aware that any information shared in a discussion thread, chat room, bulletin board, or other online dialog is public information and may be seen, disclosed to or collected by third parties that do not adhere to our Privacy Policy. You should think carefully before disclosing any personal information in any public forum.

This Privacy Policy does not protect you when you send business information, ideas, concepts or inventions to The Well Project by e-mail to the various The Well Project departments listed on the "Contact Us" link on our Website. If you want to keep business information, ideas, concepts or inventions private or proprietary, do not send them in an e-mail to The Well Project. We try to answer every e-mail in a timely manner, but are not always able to do so.

We take every precaution to protect your Personal Information. When you provide us with Personal Information, it is protected both online and off-line.

The first line of protection is your encrypted password, selected by you, which along with your user-id forms the basis for authentication to the site. Your user name, which is based on your e-mail address is unique to you, and is only effective for protected site access in combination with your password. No one can access any of the secure areas of our site without a proper user name and password combination.

To minimize the chance that someone can guess your password, we require passwords of at least 6 characters with at least one letter and at least one number. If a user of our site enters an invalid password a certain number of times, that user will be blocked from entering the site for a period of time thereafter.

Since Personal Information will only be displayed or entered in a secure area, the combination of the unique user id and the non-trivial password provides considerable protection.

In addition to the password protection, any personal information you provide is encrypted (using 128-bit encryption) and must be accessed using the SSL (Secure Socket Layer) encryption standard. You can tell that you are on a secure, encrypted page while browsing our site by looking at the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer. If the page is secure, the lock is closed; when the page is unencrypted (as it is during standard surfing), the lock becomes un-locked.

To protect against hackers entering our server environment, we have put in place appropriate firewalls. Data contained on our servers is visible only to proprietary middleware applications. Log-in passwords are required by internal staff and are changed on a periodic basis. All internal activity is logged.

While we use SSL encryption to protect Personal Information online, we also work very hard to protect Personal Information off-line. Any information we receive, whether defined as Personal Information or not, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our database administrators) are granted access to your Personal Information. ALL of our employees are kept up-to-date on our security and privacy practices. Every quarter, as well as any time new policies are added; our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our users' information is protected.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site.

We also protect and secure the physical environment in which data is stored. We store Personal Information on servers kept in a secure environment, within locked, environmentally controlled server rooms.

At various locations on the “The Well Project” web site, you will be given the option of receiving recurring informational newsletters and surveys or other communication via e-mail from The Well Project and/or directly from third parties.

You can unsubscribe from the newsletters at any time by simply clicking on the "unsubscribe" link at the bottom of any e-mail newsletter. An e-mail to our automated unsubscribe service will be created on your machine. Click the "send" button. You will then be unsubscribed from that newsletter within two to three business days. If you are experiencing difficulties with our automated unsubscribe service, you can e-mail us at customerservice@thewellproject.org. The Well Project Customer Service will unsubscribe you from that newsletter in two to three business days.

At Registration and at various times as you use the site, you may have the option of receiving e-mails or newsletters directly from third parties, participating in research or marketing surveys and participating in other activities. You may exercise these options by placing a check mark beside a statement that expresses a preference for receiving these communications or participating in these activities. You may change your decision at any time by changing your preferences within your Member Profile or by following other directions provided in association with the individual communication or activity.

The Health Insurance Portability and Accountability Act ("HIPAA") controls the collection, use, and distribution of individually identifiable health information by certain health care providers, called "covered entities" under the statute. 

The Well Project is not a covered entity as that term is defined under HIPAA. As a result, and because you (instead of a third party) have willingly and knowingly provided the information we collect, HIPAA does not apply to our services.

You can always contact us in order to delete your Personal Information from our systems, update the Personal Information that you have provided to us, and change your preferences by e-mailing us at customerservice@thewellproject.org. Such changes will not have any effect on other information that The Well Project maintains. If you have a complaint or problem you may e-mail us at customerservice@thewellproject.org and the customer service department will forward your complaint to the appropriate internal The Well Project department for a response or resolution. We try to answer every e-mail in a timely manner but are not always able to do so. If you do not receive adequate resolution of a privacy related problem, you may write to The Well Project's Privacy Help Desk at:

The Well Project

Attn: Office of Privacy

112 Krog Street, NE

Suite 23

Atlanta, GA 30307

Or call (404) 474-3152

If you have contacted The Well Project about a privacy related concern and you do not believe that the problem has been addressed, you may file a complaint with TRUSTe.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to The Well Project from our servers. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Personal Information may exist in a non-erasable form that will be difficult or impossible for us to locate. Nevertheless, we promise that upon receiving your request, all Personal Information stored in the databases we actively use for research and daily business activities, and other readily searchable media, will be deleted.

© 2003-2006 The Well Project, Inc A Not For Profit Corporation. All rights reserved.

Last updated: January 2, 2007.