Privacy Policy
Effective Date: October 30, 2019
This Privacy Policy is incorporated by reference into Vibrent Health, Inc.’s Terms of Use. The term “Vibrent Health, Inc.,” “we,” and “us” includes Vibrent Health, Inc., and our affiliates and subsidiaries. The Privacy Policy explains how Vibrent Health, Inc. may:
·collect,
·use, and
·disclose
information we obtain through the “Vibrent Health Tools.”
Vibrent Health Tools. The “Vibrent Health Tools” mean various websites, mobile application and software that is developed and maintained by Vibrent Health. Vibrent provides technology tools for its partners and customers to conduct health research. Various use cases include and are not limited to outreach, recruitment, enrollment and engagement of individuals in health research studies. Any content such as consent language, videos, surveys, education messages, communication messages, that is distributed to individuals through Vibrent tools could be produced and authored by our partners and customers.
“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.
“Health-Related Information” means all individually identifiable health information, including demographic information and information related to an individual’s physical or mental health, the provision of health care to the individual, or the individual’s payment for the provision of health care. We treat Health-Related Information as Personal Information.
THE VIBRENT HEALTH TOOLS COLLECTS YOUR INFORMATION
We collect Personal Information when you:
·register to use the Vibrent Health Tools;
·use the Vibrent Health Tools;
·communicate with us.
We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Vibrent Health Tools.
Personal Information Collection. You must register to use the Vibrent Health Tools. To register, you may need to provide Personal Information, such as your email address, phone number, username, and password. You may also provide other optional information.
Using the Vibrent Health Tools. We collect the information, including Personal Information and Health-Related Information, you post through the Vibrent Health Tools. Vibrent Health Tools will collect the information in many of the interactions and submissions, including any Health-Related Information.
Customer Support. We may collect Personal Information through your communications with our customer-support team.
Cookies, Automatic Data Collection, and Related Technologies. The Vibrent Health Tools collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics.
When you visit the Vibrent Health Tools, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Vibrent Health Tools may not work properly. If you are using a mobile device, we may also receive your mobile device id (UDID/IMEI), or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. Additionally, when you visit the Vibrent Health, Inc. website we and any third parties we use to place ads on our site automatically receive the URL of the webpage from which you came. If you click on an ad, we and any such third party may also receive the URL of the page you were on when you clicked the ad and the URL of the site associated with the ad that you clicked.
By using the Vibrent Health Tools, you are authorizing us to gather, parse, and retain data related to the provision of the Vibrent Health Tools.
HOW VIBRENT HEALTH, INC. USES YOUR INFORMATION
We use Personal Information to
·facilitate and improve our services; and
·communicate with you.
Internal and Service-Related Usage. We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Vibrent Health Tools. We may share Personal Information with vendors who perform services on behalf of Vibrent Health, Inc., including without limitation vendors who provide email services, demographic information, or geo-location information, vendors who process credit card payments, vendors who send SMS messages to mobile phone numbers and partners who offer content services or health research programs. We may use and retain any data we collect to provide and improve our services. We may access, analyze, decompile and mine the data entered by you.
Communications. We may send email, SMS messages or push notifications to the email address or phone number you provide to us to verify your account, for informational and operational purposes, such as account management, customer service, or system maintenance, informing you about new opportunities to participate in health research studies that may be relevant for you or for special offers that may be relevant for you.
Marketing. We may share certain of your Personal Information, such as your name, postal address and other information we know about you such as your age and the types of services you are seeking to third parties in the business of facilitating communications, such as direct mail brokers, to enable them to send you postal mail advertisements from companies whose products we believe may be of interest to you if you choose to receive such advertisements. You may opt in to accept them by adjusting your account settings. We do not share email addresses for this purpose, and we do not allow these third parties to provide your Personal Information directly to the companies whose products are being advertised.
Aggregate Data. We may anonymize and aggregate data collected through the Vibrent Health Tools and use it for any purpose.
VIBRENT HEALTH, INC. MAY DISCLOSE YOUR INFORMATION
We may share your information:
·with our third-party service providers;
·with other Vibrent Health Tools users;
·with other Vibrent Health affiliates conducting health research studies;
·to comply with legal obligations;
·to protect and defend our rights and property; and
·with your permission.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Vibrent Health Tools.
Displaying to Other Users. At your direction, the Vibrent Health Tools may display information, including Health-Related Information, to other users, such as coaches. For example, if you permit a coach to view the contents of your monitoring history, the Vibrent Health Tools displays the information to that coach. We are not responsible for practices of the other users, including coaches, who will view and use the posted information.
Marketing. We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed, sold or transferred as part of such transaction as permitted by law and/or contract, and you acknowledge and consent to any such disclosure, sale or transfer. We cannot control how such entities may use or disclose such information following any such disclosure, sale or transfer.
Please note, this Privacy Policy does not limit our use or disclosure of any non-Personal Information, such as information passively collected from your computer via cookies, web beacons, or standard logging of website activity. If you do not wish to share this information with Vibrent Health, Inc., then you should take steps to limit the passive collection of data about your activities on our site, for example, by changing your browser settings to disable cookies. We reserve the right to use and disclose such non-Personal Information, as well as any other non-Personal Information we collect, with our advertisers and other third parties at our discretion.
SECURITY
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot guarantee, ensure, or warrant the security of any information, including any Personal Information and/or any Health-Related Information. We do not accept liability for unintentional disclosure and/or loss of any information, including any Personal Information and/or any Health-Related Information.
By using the Vibrent Health Tools or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Vibrent Health Tools. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on the Vibrent Health Tools or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at support@vibrenthealth.com.
CHILDREN’S PRIVACY
We do not knowingly collect, maintain, or use Personal Information from people under 18 years of age, and no part of the Vibrent Health Tools is directed to people under the age of 18. If you learn that anyone under the age of 18 for whom you are responsible has provided us with Personal Information without your consent, you may alert us at support@vibrenthealth.com. If we learn that we have collected any Personal Information from anyone under 18, we will promptly take steps to delete such information.
INTERNATIONAL USERS
By using the Vibrent Health Tools, you will transfer data to the United States.
By choosing to visit the Vibrent Health Tools or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the Commonwealth of Virginia and the adjudication of any disputes arising in connection with Vibrent Health, Inc. or the Vibrent Health Tools will be in accordance with the Terms of Use.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.
UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION
If you would like to update or correct any information that you have provided to us through your use of the Vibrent Health Tools or otherwise, you may use the functionality of the Vibrent Health Tools to change or delete such information. If such functionality is insufficient or if you have suggestions for improving this Privacy Policy, please send an email to support@vibrenthealth.com.
CHANGES TO OUR PRIVACY POLICY AND PRACTICES
We may revise this Privacy Policy, so review it periodically.
Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.
Contact Information