Wells Enterprises Inc.

Thank you for downloading The Scoop - Wells (this “App”), which is owned by Wells Enterprises, Inc., on behalf of itself and its subsidiary, WEI Sales, LLC (collectively, “Wells,” “we,” “us,” or “our”).

Effective Date

October 10, 2017

Scope of This Policy

This online privacy policy (this “Policy”) applies only to information collected through this App. It does not apply to third-party platforms or to other platforms owned by Wells. It also does not apply to information collected through other channels. Some of the information we collect through this App may be “personal information”—information that identifies you personally, alone or in combination with other information available to us. Other information may be nonpersonally identifiable, such as information collected by cookies.

Your Consent

Please take a few minutes to review this Policy before using this App. By using this App, you are consenting to the collection, use and disclosure of your information as set forth in this Policy. If you do not agree to be bound by this Policy, you may not access or use this App.

This Policy is Part of Our Terms of Use

This Policy is part of the Terms of Use that govern your use of this App. The Terms of Use is provided in the “More” section of this App.

Types of Information We Collect

Because this App is made available to you in your capacity as a Wells employee, Wells already has personally identifiable information about you in its possession. Wells may collect additional information about you through this App, including:

• Information You Manually Provide. Wells collects the information you manually provide (using your keyboard, mouse, or touchpad) when you use this App. For example, we collect the information you provide when you respond to messages, contact us with questions, or otherwise interact with this App. Some of the information you manually provide may be personal information, such as your name and contact information.


• Information from your browser or device. Wells collects information that is sent to us automatically by your web browser or mobile device. This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. The information we receive may depend on your browser or device settings.

Wells may combine information collected through this App with other information already in its possession.

How We Use Information Collected Through This App

Wells reserves the right to use information collected through this App for any employment-related purpose and/or for any purposes explained in the Employee Handbook. Without limiting the foregoing in any way, we may also use information collected through this App for the following purposes:

• to provide the information, products and services you request;
• for security, credit or fraud prevention purposes;
• to provide you with a personalized experience when you use this App;
• to contact you with information and notices related to your use of this App;
• to contact you with information we believe will be of interest to you;
• to invite you to participate in surveys;
• to better understand your needs and interests;
• to improve the content, functionality and usability of this App;
• to improve our products and services;
• to improve our marketing and promotional efforts; and
• for any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

Please see below for information about the choices you have about the ways we use your information.

How to Access, Update or Correct Your Information

If you have created a profile on this App, you may be able to access, update or correct your information through your account settings. Otherwise, you may need our help. Please contact Wells’ Corporate Communications Department at [email protected].

Steps We Take to Safeguard your Information

We maintain reasonable administrative, physical and technological measures to protect the confidentiality and security of personal information you submit on or through this App. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your personal information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. Further, we cannot control dissemination of personal information you post on or through this App using any social networking tools we may provide, and you should have no expectation of privacy in such information.

How We Share Information With Others

Wells reserves the right to share information collected through this App in any manner described in the Employee Handbook or any other lawful purpose. In addition, we may disclose personally identifiable information collected through this App with the following types of entities:

With Third–Party Vendors. Wells shares information collected through this App with third-party vendors who act on our behalf. For example, we may use third-party vendors to design and operate this App; to conduct surveys; and to help us with our recruitment and retention efforts. These third-party vendors may need information about you to perform their obligations. Typically, they are required by contract to keep your information confidential and to use it only to provide services on our behalf.

With Other Users of this App. You may be able to submit User-Generated Content on or through this App. In this Policy, “User-Generated Content” or “UGC” refers to content that you post using the social networking tools we may make available to you and that does not constitute “Feedback” (as that term is defined in our Terms of Use). Any personal information contained in UGC can be read, collected, or used by others. In addition, we may use UGC you submit for marketing purposes. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the content for such purposes. Therefore, you should have no expectation of privacy with respect to UGC you submit on or through this App.

Within the Wells Corporate Family. The owner and operator of this App may share information collected through this App with other companies in the Wells corporate structure. These affiliate companies are permitted to use your information for their own marketing purposes and in a manner otherwise consistent with this Policy.

With Other, Carefully Selected Business Partners. From time to time, we may share your information with selected third parties for their own marketing purposes. For example, we may partner with third parties to sponsor workplace contests or other promotions, and we may share with these third parties the information you submit to us to participate in the contest or take advantage of the promotion. Before doing so, however, we may offer you the opportunity to “opt out” or “opt in,” as required by applicable law.

As Part of a Business Transfer. Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this App to another organization if we merge with or are acquired by another organization, or if we liquidate our assets. If such a transfer occurs, the successor organization‘s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.

To Comply With Laws and Protection of Our Rights and the Rights of Others. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this App; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

Links to Other Sites

This App may provide links to other websites operated by third parties, including in some cases our third-party vendors. Wells does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any personal information.

This Policy May Change

We are continually improving and adding to the features and functionality of this App and the services we offer through this App. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, without prior notice, by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of this App. Your continued use of this App after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. However, we will honor the terms that were in effect when we gathered data from you.

For your convenience, whenever this Policy is changed, we will update the “effective date” at the top of this page. Be sure you check the effective date to see if this Policy has been revised since your last visit.

You may access the current version of this Policy at any time by clicking the link marked “Privacy Policy” at the bottom of each page of this App.

Contact Us

If you have any questions regarding this Privacy Policy, please contact Wells’ Corporate Communications Department at [email protected]