In providing the Service, we collect and obtain information about individual consumers (“End Users”) to, among other things, provide End Users access to an intelligent Health Management System that connects wellness professionals involved in the End User’s care. In providing the Service, we at times act as a service provider to health care providers and/or wellness professionals (collectively, “Providers”).
YOUR HEALTH PRIVACY RIGHTS
HOW WE COLLECT YOUR INFORMATION
Information You Provide
We collect any information that you provide us when you use the Service.
Through the Service. We collect any information that you provide when you use the Service. For example, we may request that the End User submit responses to physical assessment questionnaires to help us assess their physical health. For example, End Users are required to complete a Physical Activity Readiness Questionnaire (“PARQ”) during the onboarding process. The PARQ allows us to identify conditions which may affect the End User’s ability to conduct physical training.
Connected Devices. We collect any information that you provide from approved third party applications and/or devices you connect to the Service. These third party applications and/or devices use or share your information in accordance with their own privacy policies. We strongly suggest you review their privacy policies to make yourself aware of their privacy practices.
Communications and other Interactions. We may collect information through your communications with our customer-support team and through other communications with us.
Information Provided by Third Party Partners
We collect any information provided by third party applications that we have partnered with to provide the Service. For example, enrolled End Users are provided a VitaBot account to assist with meal planning. To the extent an End User uses the VitaBot service, VitaBot will transmit nutritional information about the End User’s diet to us. These third party partners use or share your information in accordance with their own privacy policies. We strongly suggest you review their privacy policies to make yourself aware of their privacy practices.
Provider Submitted Information about End Users
Providers may provide us information, including protected health information, about End Users they enroll in the Service. For example, when a Provider enrolls an End User to the Service the Provider provides the End Users’ name, date of birth, sex, address, phone number, and email address.
Information We Collect When You Use Our Service
We may automatically collect certain technical information from your computer or mobile device when you use the Service.
Information and Content from Your Device. We automatically collect information about your device, such as a device ID, IP address, and browser type, so that we can provide and customize functionality.
Cookies and Related Technologies. We may collect certain information by automated means, such as cookies, web beacons and web server logs. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Service. We may use this information, for example, to determine how many users have visited certain pages or opened messages or newsletters, or to prevent fraud. We may link this data to your profile. You may be able to change browser settings to block and delete cookies when you access the Service through a web browser. However, if you do that, the Service may not work properly.
HOW WE USE YOUR INFORMATION
Internal and Service-Related Usage. We use the information we collect about and from you for a number of purposes, including: providing, supporting, and improving the services we offer, analyzing how you use the Service, and better tailoring features.
Communications. We may send email to the email address you provide to us and push notifications, lessons, questionnaires, videos, animations, etc. to your mobile device to provide the Services and for informational and operational purposes, such as account management, customer service, system maintenance, and other Service-related purposes.
Aggregate Data. To the extent permitted by applicable law, we may de-identify your information and process it in an anonymous and/or aggregated form for other purposes than described above.
HOW WE MAY DISCLOSE YOUR INFORMATION
Providers and Approved Persons. If you are an End User that was enrolled by a Provider, we share information collected from you through the Service with your Provider. In addition, to the extent permitted by applicable law, the Service may allow End Users to share information collected with explicitly designated third-parties.
Vendors and Service Providers. We may share any information we receive with vendors and service providers we use to help us provide and improve the Service. For example, we may provide your collected information to our database hosting provider. In addition, we may use third party analytics vendors to evaluate and provide us with information about your use of the Service. We do not share your information with these third parties, but these analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Service and they may otherwise collect or have access to information about you which they may collect over time and across different websites. On our website, we use Google Analytics to collect and process certain analytics data; Google provides some additional privacy options described at www.google.com/policies/privacy/partners.
Marketing. We do not rent, sell, or share information that we collect from you on the Service with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission and only to the extent permitted by applicable law.
Comply with Legal Requirements. We may disclose your information as we believe to be necessary or appropriate to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce our Terms of Service; (iv) protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain.
Corporate Transactions. We reserve the right to transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
With Your Permission. We may also disclose your collected information with your permission.
We do not knowingly collect, maintain, or use information collected from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with information without your consent, you may alert us at email@example.com. If we learn that we have collected any information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.
If you choose to access the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that the Service is hosted in the United States and thus, you may be transferring your information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information on or to the Service, you consent to such transfer, storage, and processing.
UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION
Effective Date: 1/1/2019