“Aggregated Non-Personal Information” is information about some or all of the Users of the Products and Services, but unlike Personal Information, does not reflect or reference an individually identifiable User. Aggregated Non-Personal Information may be formed from Personal Information, but any of the Personal Information used to form the Aggregated Non-Personal Information has been processed to no longer reflect or reference an individually identifiable User.
HOW WE OBTAIN THE PERSONAL INFORMATION
Vitals may obtain, collect, retain, store or otherwise maintain Your Personal Information from the following sources:
- Your Vitals Account . This information may include, for example, information You provide to Vitals through Your creation, registration and maintenance of an account on Vitals.com and/or the Vitals mobile application.
- Purchase of Products and Services : To the extent that We offer Products and Services for purchase on the Site, we may request that You provide Personal Information, a credit card account number and/or or other payment account information in order for You to access or purchase those Products and Services.
- Other Information You Provide to Vitals : Some of the Products and Services allow You to store Personal Information, such as Your Healthcare Providers, pharmacies, insurance information, emergency contact information, personal health information and related information. Personal Information that You may store through the mobile application by means of taking a photograph with Your mobile device (for example, taking a photograph of Your health insurance card) is stored exclusively on Your mobile device and is not stored or collected by Vitals. Accordingly, the safety, security and privacy of Your mobile device and the information and photographs that You store on it are Your responsibility and not the responsibility of Vitals.
- Interactive Products and Services : Some of the Products and Services allow You to interact with Healthcare Providers through the Site. These interactive Products and Services include, but are not limited to, scheduling appointments with Healthcare Providers. Per Your request to utilize these interactive Products and Services, We may obtain Personal Information (such as the medical reasons for You scheduling the appointment) that You voluntarily provide in connection with utilizing these interactive Products and Services. You understand and agree that Vitals may use and/or disclose such Personal Information to Healthcare Providers that You have selected in connection with providing You with the requested interactive Products and Services.
- Your Responses to Communications from Vitals : From time to time, Vitals may communicate with You through postal mail, email or other forms of electronic communications regarding Your Vitals account on the Site, inquiries you may make to Vitals customer service, the Products and Services and new Products and Services. If You respond to these communications, Your responses may contain Personal Information.
You can decline to provide Your Personal Information to Us by not engaging in the activities described above, such as by not registering or creating a Vitals account on the Site. If you decline to submit Personal Information, Vitals may not be able to or may choose not to provide to You some or all of its Products and Services.
Vitals also collects non-personally identifiable server-log information relating to its users. This information may include, but is not limited to, (i) Your Vitals account activity, including storage usage, number of log-ins, data displayed or selected, including user interface elements, links, etc, and (ii) Your web or mobile application request, Internet Protocol address (“IP address”), browser type, browser language, browser programming language, computer or mobile device type, the date and time of your request, date and time of access, and one or more cookies that may uniquely identify your browser and referrer Uniform Resource Locator (“URL”). None of this information alone enables Vitals to personally identify or contact You.
HOW VITALS USES PERSONAL INFORMATION
- Providing the Products and Services to You, including but not limited to, the processing, formatting and displaying of Personal Information, customized content and the delivery of customized Products and Services to You;
- Auditing, research and analysis in order to maintain, protect and improve the Products and Services and the Site;
- Ensuring the technical functioning of Vitals’ network and the Site, including creating and maintaining backups or other archival copies of Personal Information and other related data; and/or
- Developing new Products and Services, which may include use of Personal Information by Vitals in connection with developing and offering to You customized Products and Services (e.g., postal mail, e-mail or other forms of electronic communications, such as “newsletters,” regarding specific health conditions, health education and/or disease prevention), which Products and Services may be supported by third-party advertising from Healthcare Providers and manufacturers, retailers and/or other service providers within the healthcare industry (e.g., pharmaceutical and/or medical device manufacturers, suppliers, or retailers).
Vitals restricts access to Personal Information to those employees, contractors and agents of Vitals who need to access Personal Information for the purposes specified above. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.
Aggregated Non-Personal Information provided to or collected by Vitals may be provided to, shared with and used by third parties including third-party content providers, paid advertisers and licensees of the Products and Services. Vitals permits third-party advertising companies and networks to place paid advertisements that may be visible when You visit, use or access the Site. These companies and networks include, among others, third party ad servers, ad agencies, advertising networks, advertising technology vendors, and research firms. These companies and networks may use information (not including your Personal Information) relating to Your visits to, use or access of the Site in order to provide advertisements about goods and services that may be of interest to You. In the course of serving advertisements to the Site, these companies and networks may place or recognize a unique “cookie” on your browser or within the code of the mobile application or use a “web beacon”.
An example of such third-party ad networks are Google and DoubleClick. These third parties collect Aggregated Non-Personal Information about the Site’s users and provide auditing, research and reporting services and information for Vitals’ advertisers and other partners. If you would like more information about this practice and to know your choices about not having this information used by Google and/or DoubleClick, please visit http://www.google.com/policies/privacy/ads/.
If you would like more information about not having this information used by other companies, please visit http://www.networkadvertising.org/managing/opt_out.asp.
Your Ad Choices and Tracking by Third-Parties
You have options and choices about the collection and use of information by third-parties on our site:
For more information about these third-party Ad Networks and opting out of tracking, see: http://www.networkadvertising.org/managing/opt_out.asp
For more information about interest-based information tracking and opting out, see: http://www.aboutads.info/choices/
For information about disabling and controlling third-party cookies in your browser, see: http://www.aboutcookies.org/Default.aspx?page=1
COOKIES PLACED BY VITALS
On occasion, Vitals may act as a “Business Associate” of one or more Covered Entities (e.g., Healthcare Providers, such as doctors, hospitals or health plans) as defined by HIPAA. In those instances, to the extent required by law, Vitals will both comply with the obligations imposed upon Business Associates and abide by the privacy policies of the Covered Entities.
INFORMATION SHARING AND ONWARD TRANSFER
Vitals reserves the right to sell, rent or otherwise share some or all of Your Personal Information with other companies or individuals outside of Vitals if:
- You have consented to such sale, rental or sharing; and/or
Vitals reserves the right to disclose Aggregated Non-Personal Information to third parties without prior notice to You.
Vitals takes reasonable and appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of its data, including Personal Information stored or maintained on its servers and other systems. These measures include internal reviews of Vitals’ data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to servers and systems where Vitals stores personal data.
ACCESSING AND UPDATING PERSONAL INFORMATION
Information You Provide When Registering For a Vitals Account
You may change or update the e-mail address and password that You provided when You registered for Your Vitals account via the “settings” or “account settings” section of such account. If You registered separately for an account on both the Vitals website and the Vitals mobile application, changes or updates to registration information should be made separately on each account. You may terminate Your Vitals account by sending an e-mail with your account termination request to email@example.com.
Information You Store or Access When Using the Products and Services
When you use the Products and Services, Vitals makes good faith efforts to provide you with access to Your Personal Information. You may organize or delete or change certain of the information that is entered or uploaded into Your account (such as for patients, the names of Your Healthcare Providers, pharmacies, insurance information, emergency contact information, personal health information and related information, and such as for physicians, the address where Your practice is located, Your photograph and Your practice specialty) via the section of Your account where the information is located. Where applicable, Vitals asks individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and Vitals may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where Vitals provides information access and correction, Vitals provides this service free of charge, except if doing so would require a disproportionate effort. If you have any questions or want more information about accessing or updating Your Personal Information, please contact Vitals by e-mail to firstname.lastname@example.org or by telephone to (201) 842-0760.
All deletions, changes or updates that you make to Your Personal Information will take immediate effect. Account terminations will also take immediate effect after Vitals receives and processes Your e-mail termination request. Except for deleted information that was stored exclusively on Your mobile device, residual copies of the deleted information, including terminated account information, may take up to sixty (60) days to be deleted from active servers and may remain in perpetuity in backup systems.
Deleting the Vitals mobile application from Your mobile device will not terminate Your Vitals account but will delete any information that You stored through the mobile application by means of taking a photograph with Your mobile device (“Stored Photographic Information”). Terminating Your Vitals account will not delete Stored Photographic Information unless You also delete the Vitals mobile application from Your mobile device.
If you have any additional questions or concerns about this Policy, please contact us at:
Attn: Legal Department
210 Clay Avenue, Suite 140
Lyndhurst, NJ 07071
Email address email@example.com
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 allows users who are California residents to request certain information about the disclosure of their Personal Information to third parties for direct marketing purposes. To make such a request, please contact us at firstname.lastname@example.org.
Vitals adheres to the United States of America safe harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement. For more information about the Safe Harbor framework, please visit the U.S. Department of Commerce’s website or http://export.gov/safeharbor.
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