DATA PROCESSING AMENDMENT (DPA)
Last Updated: November 14, 2025
This Data Processing Amendment (“DPA”) forms part of the agreement between your Program Sponsor (“Controller”) and Wellness360 Technologies, Inc. (“Processor” or “Wellness360”), relating to Wellness360’s provision of wellness program services.
1. Data Processing & Instructions
Wellness360 only processes Personal Data on behalf of your Program Sponsor as necessary to provide agreed wellness solutions, per documented instructions, and in compliance with applicable data protection laws, including GDPR.
2. Subject Matter, Duration, Categories
- Subject matter \& duration: As specified in the Master Agreement/Service Order—typically user information and program participation data, processed for the term of your service contract.
- Categories: Employees, spouses, dependents (if included by program design)
- Types: Identity, contact info, engagement, biometrics, device data, claims, and communications, as described in our Privacy Policy
3. Subprocessors
4. Data Subject Rights
Wellness360 will assist Controllers as reasonably requested in responding to Data Subject rights or regulatory inquiries.
5. Confidentiality & Security
All employees and vendors are bound by confidentiality. We maintain technical and organizational measures as outlined in our Security Overview ([see section in Terms or Privacy Policy]).
6. International Transfers
Transfers outside the EEA/UK/Switzerland are covered by SCCs or equivalent mechanisms.
7. Data Breach
Wellness360 will promptly notify the Controller of any breach affecting Personal Data and cooperate fully in mitigation and reporting as required.
8. Deletion or Return of Data
At contract termination or upon written request, Wellness360 will delete or return Personal Data, except where retention is required by law.
9. Audit
Controllers may audit Wellness360’s compliance with this DPA as outlined in the Master Agreement.
10. Contact
For questions, please contact privacy@wellness360.co.