How we collect, use, and protect your personal information.
This Privacy Policy (“Privacy Policy”) describes the data protection
practices of Vytora Health LLC and its affiliates, including, but not
limited to, Vytora Health (collectively, “Vytora Health”, “we”, “our”,
or “us”), including when you visit any Vytora Health website that links
to this Privacy Policy, use any affiliated mobile applications (the
“Apps”), or otherwise provide data to Vytora Health. We refer to the
Websites, Apps, and other services provided by Vytora Health together in
this Privacy Policy as the “Services.” This Privacy Policy is
incorporated into our Terms of Use. All capitalized terms used in this
Privacy Policy but not defined herein have the meanings assigned to them
in the Terms of Use.
YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO
NOT USE THE SERVICES.
The Information We Collect and the Sources of Such Information
Purposes for How We Use Your Information
Online Analytics and Advertising
How We Share and Disclose Your Information
Your Marketing Choices
Third Party Services and Notice About Health Information
How We Protect Your Information
Privacy Information for California Residents
Privacy Information for Nevada Residents
Retention of Your Information
Revisions to Our Privacy Policy
Contacting Us
We obtain information about you through the means discussed below when
you use the Services. Please note that we need certain types of
information so that we can provide the Services to you. If you do not
provide us with such information, or ask us to delete it, you may no
longer be able to access or use part or all of our Services.
1. Information You Provide to Us
We collect a variety of information that you provide directly to us. For
example, we collect information from you through: Account and product
registration and administration of your account Processing your orders
and requests for treatment Questions, communications, or feedback you
submit to us via forms or email Your participation in research and
surveys Requests for customer support and technical assistance,
including through online chat functionalities Uploads or posts to the
Services Employment applications you submit The specific types of
information we collect will depend upon the Services you use, how you
use them, and the information you choose to provide. The types of data
we collect directly from you includes: Name, address, telephone number,
date of birth, and email address Information about your medical
conditions, treatment options, physician referrals, prescriptions, and
lab results or other related health information, such as your physical
and emotional characteristics Log-in credentials, if you create an
account Billing information, such as shipping address, credit or debit
card number, verification number, expiration date, and identity
verification information, collected by our payment processors on our
behalf Information about purchases or other transactions with us
Information about your customer service and maintenance interactions
with us Demographic information such as your gender and age
User-generated content you post in public online forums on our Services
Any other information you choose to directly provide to us in connection
with your use of the Services.
2. Information We Collect Through Automated Means
We collect certain information about your use of the Services and the
devices you use to access the Services, as described in this Section. As
discussed further below, we and our service providers (which are third
party companies that work on our behalf), may use a variety of
technologies, including cookies and similar tools, to assist in
collecting this information. Our Websites. When you use our Websites, we
collect and analyze information such as your IP address, browser types,
browser language, operating system, the state or country from which you
accessed the Services, software and hardware attributes (including
device IDs) referring and exit pages and URLs, platform type, the number
of clicks, files you download, domain names, landing pages, pages viewed
and the order of those pages, the amount of time spent on particular
pages, the terms you use in searches on our sites, the date and time you
used the Services, error logs, and other similar information. Our Apps.
When you use our Apps, we automatically receive certain information
about the mobile phone, tablet, or computer used to access the Apps,
including a mobile device identifier, IP address, operating system,
version, Internet service provider, browser type, domain name and other
similar information, whether and when you update the Apps, date and time
of use, and how you use the Apps, including time spent in different
portions of the Apps. Location Information. When you use the Services,
we and our service providers may automatically collect general location
information (e.g., IP address, city/state and or postal code associated
with an IP address) from your computer or mobile device. This
information allows us to enable access to content that varies based on a
user’s general location (e.g., to provide you with accurate sales tax
information and to deliver content customized to your location). We will
ask your permission before collecting your precise GPS location
information. In such instances, we will use your precise geo-location
information to provide customized services, content, promotional offers
and other information that may be of interest to you. If you no longer
wish for us and our service providers to collect and use GPS location
information, you may disable the location features on your device.
Please see your device manufacturer settings. Our Use of Cookies and
Similar Online Tools. To collect the information discussed in this
Section, we and our service providers use web server logs, cookies,
tags, SDKs, tracking pixels, and other similar tracking technologies. We
use these technologies to offer you a more tailored experience. A web
server log is a file where website activity is stored. An SDK is a set
of tools and/or code that we embed in our Apps and software to allow
third parties to collect information about how users interact with the
Services. A cookie is a small text file that is placed on your computer
or mobile device when you visit a site, that enables us to: (i)
recognize your computer/device; (ii) store your preferences and
settings; (iii) understand the parts of the Services you have visited
and used; (iv), enhance your user experience by delivering and measuring
the effectiveness of content and advertising tailored to your interests;
(v) perform searches and analytics; and (vi) assist with security and
administrative functions. Tracking pixels (sometimes referred to as web
beacons or clear GIFs) are tiny electronic tags with a unique identifier
embedded in websites, online ads and/or email that are designed to: (1)
collect usage information like ad impressions or clicks and email open
rates; (2) measure popularity of the Services and associated
advertising; and (3) access user cookies. As we adopt additional
technologies, we may also gather information through other methods.
Please note that you can change your settings to notify you when a
cookie is being set or updated, or to block cookies altogether. Please
consult the “Help” section of your browser for more information (e.g.,
Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari).
Please note that by blocking, disabling, or managing any or all cookies,
you may not have access to certain features or offerings of the
Services.
3. Information We Collect From Social Media and Other Content Platforms
When you “like” or “follow” us on Facebook, Instagram, Twitter, or other
social media sites, we may collect some information from you including
your name, email address, and any comments or content you post relevant
to us. We also collect your information if you sign up for one of our
promotions or submit information to us through social media sites.
4. Information We Receive From Other Sources
We work closely with third parties (including, for example, third party
intermediaries, such as the physicians, medical professionals, and
pharmacies with whom we partner to provide you with the Services and
their health care services, sub-contractors in technical, advertising
networks, analytics providers, and search information providers). Such
third parties will sometimes provide us with additional information
about you.
PURPOSES FOR HOW WE USE YOUR INFORMATION In connection with providing
you with the Services, we may use your information for our business
purposes to: Carry out, improve, and manage the Services and, as
applicable, facilitate the provision of health care services to you by
physicians or other health care providers and ensure that the physicians
or health care providers have the services and support necessary for
health care operations. Engage in internal research to understand the
effectiveness of our Services, improve our Services, and better
understand our user base. If we publish or provide the results of this
research to others, such research will be presented in a de-identified
and aggregate form such that individual users cannot be identified.
Communicate with you about the Services, your use of the Services, or
your inquiries related to the Services and send you communications on
behalf of physicians or other health care providers utilizing the
Services to meet your needs. Communicate with you by email, postal mail,
or phone about surveys, promotions, special events or our products and
Services and those of our subsidiaries, affiliates, and parent companies
and any of their related businesses and those of our third-party
partners. Provide you with technical support and customer service.
Verify your identity and administer your account, including processing
your payments and fulfilling your orders. Ensure that content from our
Services is presented in the most effective manner for you and for your
computer or device, allow you to participate in interactive features of
our Services (when you choose to do so), and as part of our efforts to
keep our Services safe and secure. Measure or understand the
effectiveness of advertising and content we serve to you and others, and
to deliver and customize relevant advertising and content to you. Help
us better understand your interests and needs, such as by engaging in
analysis and research regarding use of the Services. Comply in good
faith with any procedures, laws, and regulations which apply to us where
it is necessary for our legitimate interests or the legitimate interests
of others. Establish, exercise, or defend our legal rights where it is
necessary for our legitimate interests or the legitimate interests of
others. Combined Information. For the purposes discussed in this Privacy
Policy, we may combine the information that we collect through the
Services with information that we receive from other sources, both
online and offline, and use and share such combined information in
accordance with this Privacy Policy. Aggregate/De-Identified Data. We
may aggregate and/or de-identify any information collected through the
Services so that such information can no longer be linked to you or your
device (“Aggregate/De-Identified Information”). We may use
Aggregate/De-Identified Information for any purpose, including for
research and marketing purposes, and may also share such data with any
third parties, including advertisers, promotional partners, and
sponsors.
1. Online Analytics We may use third-party web analytics services (such
as those of Google Analytics (including Google Signals, Google User-ID,
and other Google Analytics features) and MixPanel) on our Services to
collect and analyze usage information through cookies and similar tools;
engage in auditing, research, or reporting; assist with fraud
prevention; try to locate the same unique users across multiple browsers
or devices to better tailor services and features; and provide certain
features to you. If you have a Google account with personalized
advertising enabled, through Google Signals, Google will also be able to
gather for us analytics and engagement information from across the
various devices you use to access the Services. To prevent Google from
using your information for analytics (including cross-device tracking
for personalization purposes), you may install the Google Analytics
Opt-out Browser Add-on by clicking here. And to opt out of Google
Signals, please open your “Settings” app, locate and tap “Google,”
select “Ads,” and turn ON “Opt out of Ads Personalization.” You may also
be able to disable cross-device tracking through your Android or Apple
device-based settings. If you receive email from us, we may use certain
analytics tools, such as clear GIFs to capture data such as when you
open our message or click on any links or banners our email contains.
This data allows us to gauge the effectiveness of our communications and
marketing campaigns.
2. Online Advertising The Services may integrate third-party advertising
technologies (e.g., ad networks and ad servers such as Facebook, Google
Ad Words, Criteo and others) that use cookies and other technologies to
deliver relevant content and advertising for Vytora Health products on
the Services, as well as on other websites you visit and other
applications you use. The ads may be based on various factors such as
the content of the page you are visiting, information you enter such as
your searches, demographic data, and other information we collect from
you. These ads may be based on your current activity or your activity
over time and across other websites and online services. We sometimes
provide our customer information (such as email addresses) to service
providers, who may “match” this information in de-identified form to
cookies (or mobile ad identifiers) and other proprietary IDs, in order
to provide you with more relevant ads when you visit other websites and
mobile applications. We neither have access to, nor does this Privacy
Policy govern, the use of cookies or other tracking technologies that
may be placed on your device you use to access the Services by
non-affiliated third party advertising network services. If you are
interested in more information about tailored browser advertising and
how you can generally control cookies from being put on your computer to
deliver tailored advertising, you may visit the Network Advertising
Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s
Consumer Opt-Out link, or Your Online Choices to opt-out of receiving
tailored advertising from companies that participate in those programs.
If you are interested in more information about Criteo’s privacy
practices or opting-out of Criteo’s advertising services, you may view
their Privacy Policy. To opt out of Google Analytics for display
advertising or customize Google display network ads, visit the Google
Ads Settings page. We do not control these opt-out links or whether any
particular company chooses to participate in these opt-out programs. We
are not responsible for any choices you make using these mechanisms or
the continued availability or accuracy of these mechanisms. Please note
that if you exercise the opt out choices above, you will still see
advertising when you use the Services, but it will not be tailored to
you based on your online behavior over time.
3. Mobile Advertising When using mobile applications from us or others,
you may also receive tailored in-application advertisements. We may use
third-party service providers to deliver advertisements on mobile
applications or for mobile application analytics. Each operating system,
iOS for Apple phones, Android for Android devices, and Windows for
Microsoft devices provides its own instructions on how to prevent the
delivery of tailored in-application advertisements. We do not control
how the applicable platform operator allows you to control receiving
personalized in-application advertisements; thus, you should contact the
platform provider for further details on opting out of tailored
in-application advertisements. You may review the support materials
and/or the device settings for the respective operating systems to
opt-out of tailored in-app advertisements.
4. Notice Concerning Do Not Track Do Not Track (“DNT”) is a privacy
preference that users can set in certain web browsers. We are committed
to providing you with meaningful choices about the information collected
on our website for third party purposes, and that is why we provide the
variety of opt-out mechanisms listed above. However, we do not currently
recognize or respond to browser-initiated DNT signals. To learn more
about Do Not Track, you can do so here.
We may share your information for our business purposes in the following
ways:
Affiliates and Subsidiaries.
We may share information we collect within any Vytora Health member or
group (i.e., our subsidiaries and affiliates, including our ultimate
holding company and its subsidiaries) to deliver products and services
to you, ensure a consistent level of service across our products and
services, and enhance our products, services, and your customer
experience.
Health Care Providers and Services.
We share your information with health care providers: (i) to schedule
and fulfill appointments and provide health care services as part of the
Services, (ii) to whom you send messages through our Services, and (iii)
for other treatment, payment or health care operations purposes,
including pharmacy services, upon your request. Service Providers. We
provide access to or share your information with select third parties
who use the information to perform services on our behalf. They provide
a variety of services to us, including billing, sales, marketing,
advertising, analytics, research, customer service, shipping and
fulfillment, data storage, IT and security, fraud prevention, payment
processing, and auditing and legal services. These entities may also
include health care organizations, pharmacies, and other third parties
we use to support our business or in connection with the administration
and support of the Services.
Protection of Vytora Health and Others.
By using the Services, you acknowledge and agree that we may access,
retain and disclose the information we collect and maintain about you if
required to do so by law or in a good faith belief that such access,
retention or disclosure is reasonably necessary to: (a) comply with
legal process (e.g. a subpoena or court order); (b) enforce our Terms of
Use, this Privacy Policy, or other contracts with you, including
investigation of potential violations thereof; (c) respond to claims
that any content violates the rights of third parties; (d) respond to
your requests for customer service; and/or (e) protect the rights,
property or personal safety of Vytora Health, its agents and affiliates,
its users and/or the public. This includes exchanging information with
other companies and organizations for fraud protection, and spam/malware
prevention, and similar purposes.
Business Transfers.
As we continue to develop our business, we may buy, merge, or partner
with other companies. In such transactions, (including in contemplation
of such transactions) user information may be among the transferred
assets. If a portion or all of our assets are sold or transferred to a
third-party, customer information (including your email address) would
likely be one of the transferred business assets. If such transfer is
subject to additional mandatory restrictions under applicable laws, we
will comply with such restrictions.
Public Forums.
Certain features of our Services make it possible for you to share
comments publicly with other users. Any information that you submit
through such features is not confidential, and we may use it for any
purpose (including in testimonials or other marketing materials). For
example, if you submit a product review on one of our sites, we may
display your review (along with the name provided, if any) on other
Vytora Health websites and on third-party websites. Any information you
post openly in these ways will be available to the public at large and
potentially accessible through third-party search engines. Accordingly,
please take care when using these features. Consent. We may also
disclose your information in other ways you direct us to and when we
have your consent. Aggregate/De-Identified Information. We reserve the
right to create Aggregate/De-Identified Data from the information we
collect through the Services and our sharing of such
Aggregate/De-Identified Data is in our discretion.
You may instruct us not to use your contact information to contact you
by email, postal mail, or phone regarding products, services, promotions
and special events that might appeal to your interests by contacting us
using the information below. In commercial email messages, you can also
opt out by following the instructions located at the bottom of such
emails. Please note that, regardless of your request, we may still use
and share certain information as permitted by this Privacy Policy or as
required by applicable law. For example, you may not opt out of certain
operational emails, such as those reflecting our relationship or
transactions with you.
This Privacy Policy does not address, and we are not responsible for,
the privacy, information, or other practices, including data privacy and
security process and standards of any third parties, including
physicians and other health care providers using the Services, the
manufacturer of your mobile device and other IT hardware and software,
and any other third party mobile application, website, or service to
which our Services may contain a link. These third parties may at times
gather information from or about you. We have no control over the
privacy practices of these third parties. The collection, use, and
disclosure of your information will be subject to the privacy policies
of the third-party websites or services, and not this Privacy Policy. We
urge you to read the privacy and security policies of these third
parties.
Vytora Health takes a variety of technical and organizational security
measures to protect your information against accidental or unlawful
destruction or accidental loss, alteration, unauthorized disclosure or
access. However, no method of transmission over the Internet, and no
means of electronic or physical storage, is absolutely secure. As such,
you acknowledge and accept that we cannot guarantee the security of your
information transmitted to, through, or on our Services or via the
Internet and that any such transmission is at your own risk. Where we
have given you (or where you have chosen) a password that enables you to
access the Services, you are responsible for keeping this password
confidential. We ask you not to share your password with anyone. The
information you share in public areas may be viewed by any user of the
Services.
PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS If you are a California
resident, California law requires us to provide you with some additional
information regarding how we collect, use, and share your “personal
information” (as defined in the California Consumer Privacy Act
(“CCPA”)). Categories of personal information we collect and disclose.
Throughout this Policy, we discuss in detail the specific pieces of
personal information we collect from and about our users. Under the
CCPA, we are also required to provide you with the “categories” of
personal information we collect and the categories of third parties to
which we disclose personal information. Please note that some of the
information we collect through the Services (e.g., medical information),
is subject to various health data privacy laws, and is therefore not
subject to the CCPA. See the following chart to understand more about
the categories of personal information we collect that are subject to
the CCPA and the third parties to which we disclose it: Category of
Personal Information Categories of Third Parties to Which we Disclose
Identifiers and contact information (e.g., name, address, email address,
account names) Service providers; our affiliates; health care providers
and services; entities for legal and fraud prevention Commercial and
transactional information (e.g., information about your purchases)
Service providers; our affiliates; health care providers and services;
entities for legal and fraud prevention Financial information (e.g.,
credit card info collected by our payment processors) Payment
processors; service providers; our affiliates; entities for legal and
fraud prevention Internet or other network or device activity (e.g., IP
address, browsing history, app usage) Service providers; our affiliates;
entities for legal and fraud prevention Geolocation information (e.g.,
general location and precise location, with your permission) Service
providers; our affiliates; entities for legal and fraud prevention
Demographic and statistical data (e.g., your gender, interests based on
products and services you use) Service providers; our affiliates;
entities for legal and fraud prevention Physical characteristics (e.g.,
photos of you) Service providers; our affiliates User-generated content
(e.g., information you choose to post in our online forums) Service
providers; our affiliates; entities for legal and fraud prevention
Customer service data (e.g., information you provide through a chat or
call with Vytora Health’s Care Team) Service providers; our affiliates;
health care providers and services; entities for legal and fraud
prevention The business purposes for which we use the personal
information we collect are: manage, facilitate, and improve the
Services; research, marketing, and analytics; communicate with users;
technical support and customer service; security and fraud prevention;
and legal compliance and defense. For more detailed information about
how we use and share your personal information, please see the “Purposes
for How We Use Your Information” and “How We Share and Disclose Your
Information” sections of this Policy above. Your California Privacy
Rights CCPA Rights Disclosure. If you are a California resident, the
CCPA allows you to make certain requests about your personal
information. Specifically, the CCPA allows you to request us to: Inform
you about the categories of personal information we collect or disclose
about you; the categories of sources of such information; the business
or commercial purpose for collecting your personal information; and the
categories of third parties with whom we share/disclose personal
information. Provide access to and/or a copy of certain information we
hold about you. Delete certain information we have about you. The CCPA
further provides you with the right to not be discriminated against (as
provided for in applicable law) for exercising your rights. Please note
that certain information may be exempt from such requests under
California law. For example, we need certain information in order to
provide the Services to you. We also will take reasonable steps to
verify your identity before responding to a request. If you are a
California resident and you would like to exercise any of your data
rights under California law, please click here to submit your request
through our webform. Alternatively, you can email us at
support@vytorahealth.com.
Please include your full name, email address and residential address
associated with your use of our Services, along with the rights you
would like to exercise, so that we can process your request in an
efficient manner. If you would like to receive a copy of your medical
record in connection with your request, please indicate that in your
email message. By requesting your medical record in this way, you are
agreeing to receive your medical record in an unencrypted email message.
Sale of Personal Information.
Vytora Health does not, and will not, sell information that identifies
you such as your name, email address, phone number, or postal address.
Like many companies with an internet presence, we do work with third
parties that provide marketing and advertising services to us, including
interest-based advertising services, and these third parties may place
tags, pixels, cookies, beacons, and other similar tracking mechanisms on
our Website and App and collect your online identifiers. Because of the
CCPA’s broad definitions of “sale” and “personal information,” making
certain online identifiers available to these companies so that they can
provide marketing and advertising services to Vytora Health may be
considered a “sale” under the CCPA . To opt out of sharing your
information with participating third parties for interest-based
advertising, please visit the Network Advertising Initiative’s Consumer
Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link,
and Your Online Choices. Please note that these opt-outs are device and
browser based, so you will need to opt out on each of your devices and
browsers. For more information, see the Online Analytics and Advertising
Section above. Shine the Light Disclosure. The California “Shine the
Light” law gives residents of California the right under certain
circumstances to request information from us regarding the manner in
which we share certain categories of personal information (as defined in
the Shine the Light law) with third parties for their direct marketing
purposes. We do not share your personal information with third parties
for their own direct marketing purposes.
Under Nevada law, certain Nevada consumers may opt out of the sale of
“personally identifiable information” for monetary consideration (as
such terms are defined under Nevada law) to a person for that person to
license or sell such information to additional persons. We do not engage
in such activity; however, if you are a Nevada resident who has
purchased services from us, you may submit a request to opt out of any
potential future sales under Nevada law by support@vytorahealth.com.
Please note we will take reasonable steps to verify your identity and
the authenticity of the request. Once verified, we will maintain your
request in the event our practices change. RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes
for which it is processed. The length of time for which we retain
information depends on the purposes for which we collected and use it
and/or as required to comply with applicable laws.
We reserve the right to change this Privacy Policy at any time to
reflect changes in the law, our data collection and use practices, the
features of our Services, or advances in technology. We will make the
revised Privacy Policy accessible through the Services, so you should
review it periodically. The date this Privacy Policy was last revised is
identified at the top of the document. You are responsible for
periodically monitoring and reviewing any updates to the Privacy Policy.
If we make a material change to the Privacy Policy, we will provide you
with appropriate notice in accordance with legal requirements. Your
continued use of our Websites or Apps after such amendments (and notice,
where applicable) will be deemed your acknowledgment of these changes to
this Privacy Policy.
If you have any questions about this Privacy Policy or Vytora Health’s
privacy practices, please contact us at:
Vytora Health LLC
support@vytorahealth.com