1. Tietosuojakäytännön sisältö
This notice describes how Personal Data and/or information about you may be used and disclosed and how you can obtain access to this information. Please review it carefully.
For additional information related to how we use and disclose your Personal Data, please contact our Privacy Officer at firstname.lastname@example.org.
4. Account Deletion
● Your name
● Your organization
● Your login email address; and
● A statement that you are requesting account deletion
5. Questions or Concerns
COLLECTION AND USE OF PERSONAL DATA
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7.2 Jos epäillään lain tai yleisten käyttöehtojemme rikkomista, saatamme luovuttaa henkilötietojasi lainvalvontaviranomaisille ja lainopillisille neuv
6. What Personal Data Does Vitala Collect?
We collect three types of information: (i) demographic data; (ii) support data; and(iii) technology data. Each category of data is explained in depth below.
Demographic Data: Vitala collects demographic data from organization
administrators (“Administrators”) on behalf of Provider Users (collectively,
“Users”), which may include, but not be limited to, your name, email
address, and phone number, your role within your organization (i.e.
physician, other qualified health care provider, clinical staff, or non-
reimbursable staff), the state where you are located, the level of supervision
necessary for you to provide RTM services, the state where you are licensed,
and your title within your organization. The collection of this demographic
data is primarily used to create your User Account, which you can use to
securely utilize the Services.
Technology Data: We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data from your computer or mobile device as you navigate our Provider Portal or interact with emails or other communications, we have sent you. The information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages, and files you viewed, your searches, your operating system, and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, help us provide and improve our Services, and ensure the proper functioning and security of the Provider Portal and Services.
7. How Will Vitala Use Personal Data?
Vitala processes your Personal Data based on legitimate business interests, the
More specifically, Vitala processes your Personal Data for the following legitimate
● To provide Services.
● To communicate with you about and manage your User Account.
● To properly store and track your data within our system.
● To respond to lawful requests from public and government authorities, and to
comply with applicable state/federal law, including cooperation with judicial
proceedings and court orders.
● To protect our rights, privacy, safety, or property, and/or that of you or others
by providing proper notices, pursuing available legal remedies, and acting to
limit our damages.
● To handle technical support and other requests from you.
or the terms of any other applicable services agreement we have with you.
● To manage and improve our operations and the Provider Portal, including the
development of additional functionality.
● To manage payment processing.
● To evaluate the quality of service you receive, identify usage trends, and
improve your user experience.
● To keep our Provider Portal safe and secure.
● To send you information about changes to our terms, conditions, and policies.
● To allow us to pursue available remedies or limit the damages that we may
● To enable you to connect with Patient Users and view Personal Data, which
allows you to monitor patient progress and overall condition as you deem
8. Does Vitala Use Personal Data for Analytics?
Vitala uses third-party service providers to monitor and analyze the use of theProvider Portal as part of our Services. The analytics services we use may include but are not limited to: Google Analytics, Mixpanel, behavioral remarketing, Google Ads, Bing Ads remarketing services, and Facebook.
9. Where Is Personal Data Processed?
The Personal Data we collect through the Provider Portal will be stored on secure servers in the United States. Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer your Personal Data outside of the UnitedStates.
10. With Whom Does Vitala Share Personal Data?
We may share your personal information with the following categories of individuals/entities:
Business Partners and Vendors: We share Personal Data with a limited
number of partners, service providers, and other persons/entities who help
run our business (“Business Partners”). Specifically, we may employ third-
party companies and individuals to facilitate our Services, provide Services
on our behalf, perform Service-related functions, or assist us in analyzing how
our Services are used. Our Business Partners are contractually bound to
protect your Personal Data and to use it only for the limited purpose(s) for
which it is shared. Business Partners’ use of Personal Data may include, but is
not limited to, the provision of services such as data hosting, IT services,
customer services, and payment processing.
Our Advisors: We may share your Personal Data with third parties that provide advisory services to Vitala, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively, “Advisors”). Personal Data will only be shared with Advisors if Vitala has a legitimate business interest in the sharing of such data.
Third Parties Upon Your Direction or Consent: You may direct Vitala to share your Personal Data with third parties. Upon your request and consent, we may share such Personal Data with those third parties that you identify.
Third Parties Pursuant to Business Transfers: In the event of are organization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Vitala’s corporate entity, assets, or stock(including in connection with any bankruptcy or similar proceedings), we may share your Personal Data with a third party.
11. How Long Does Vitala Retain Personal Data?
Vitala retains your Personal Data only if necessary and as required for our business operations, the provision of Services, archival purposes, and/or to satisfy legal requirements. The exact period of retention will depend on: (i) the amount, nature, and sensitivity of the Personal Data; (ii) the personal risk of harm for unauthorized use or disclosure; (iii) the purposes for which we process your Personal Data, including whether those purposes can be achieved through other means; and (iv)business operations and legal requirements. In general, Vitala strives to retain your data for no longer than required by applicable state and/or federal law after yourUser Account is closed (the “Retention Period”); however, the above factors may extend or decrease this Retention Period.
At the end of the applicable Retention Period, we will remove your Personal Data from our databases and will require that our Business Partners remove any identifiable Personal Data from their databases. If there is any data that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing of such data. Please note that once we disclose your Personal Data to third parties, we may not be able to access that Personal Data and we cannot force the deletion or modification of such information by third parties.
Vitala and its Business Partners reserve the right to continue using de-identified data indefinitely, even after Personal Data has been removed from Vitala’s databases. We may continue to disclose de-identified data to third parties in a manner that does not reveal personal information, as described in this PrivacyPolicy. Our continued use of de-identified data will comport with applicable law.
12. What Happens to Personal Data Submitted by Minors?
Vitala does not knowingly collect Personal Data from individuals under the age of 18. Additionally, our Services are not directed to individuals under the age of 18. We request that these individuals not provide Personal Data to us. If we learn thatPersonal Data from users under the age of 18 has been collected, we will deactivate the User Account associated with that data and take reasonable measures to promptly delete such data from our records. If you are aware of a user under the age of 18 accessing the Services or Provider Portal, please contact us at email@example.com.
If you are a resident of California under the age of 18 and have registered for a User Account with us, you may ask us to remove content or information that you have posted to our Provider Portal.
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13. What Rights Do Users Have Concerning Their Personal Data?
As a user of Vitala’s Services and Provider Portal, you have certain rights relating to your Personal Data. These rights are subject to local data protection and privacy laws, and may include the right to:
● Access Personal Data held by Vitala
● Erase/delete your Personal Data, to the extent permitted by applicable data
protection and privacy laws and to the extent technologically feasible
● Receive communications related to the processing of your Personal Data
● Restrict the processing of your Personal Data to the extent permitted by law
● Object to the further processing of your Personal Data, including the right to
object to marketing
● Request that your Personal Data be transferred to a third party, if possible
● Receive your Personal Data in a structured, commonly used, and machine-
readable format; and/or
● Rectify inaccurate personal information and, considering the purpose of
processing the Personal Data, ensure it is complete.
Where the processing of your Personal Data by Vitala is based on consent, you have the right to withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the above rights, please contact us at firstname.lastname@example.org.
14. How Can Users Update, Correct, or Delete Personal Data or Their UserAccount?
You have the right to request restrictions on the uses and disclosures of your Personal Data. While we are not required to agree to all restriction requests, we will attempt to accommodate reasonable requests when appropriate.
You may change your phone number by accessing your Vitala User Account. If you need to make changes or corrections to other information, you may contact us at email@example.com. To comply with certain requests to limit the use of your PersonalData, we may need to terminate your ability to access and/or use some or all theServices. BY REQUESTING TO LIMIT THE USE OF YOUR PERSONAL DATA OR DELETE PERSONAL DATA, YOU ACKNOWLEDGE AND AGREE THAT VITALA WILL NOT BE LIABLE TO YOU FOR ANY CORRESPONDING LIMITATION IN THE SCOPE OF SERVICES OR TERMINATION OF SERVICES AS NECESSARY TO COMPLY WITH YOUR REQUEST.
You have the right to request the deletion of any Personal Data from your UserAccount or the Provider Portal. To request deletion of your Personal Data, please email us at firstname.lastname@example.org and include a description of the Personal Data you would like removed. We will respond to all requests for data deletion as soon as reasonably possible.
Should you decide to delete your User Account entirely, you may do so by emailing email@example.com. By terminating your User Account, you agree that you will not be able to access any information previously contained in your User Account. You further understand that it may not be technologically possible to remove all yourPersonal Data from our systems. While we will use reasonable efforts to remove your Personal Data, the need to back up our systems to protect information from inadvertent loss means a copy of your Personal Data may exist in a non-erasable form that will be difficult or impossible for us to locate or remove.
SAFEGUARDING PERSONAL DATA
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15. Is Personal Data Secure?
Vitala understands the importance of data confidentiality and security. We use a combination of reasonable physical, technical, and administrative security controls to (i) maintain the security and integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of your Personal Data; and (iii)protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm to you.
While Vitala uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT SUCH TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TOYOUR PERSONAL DATA. VITALA IS UNABLE TO GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA TRANSMITTED OVER THE INTERNET, AND THERE ISNO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED,ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CAN NOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE,HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA AT ANY TIME.
16. What Safeguards Does Vitala Have in Place to Secure My Personal Data?
Vitala stores Personal Data on secured servers and uses a combination of technical, administrative, and physical safeguards to protect your personal information. Such safeguards include, but are not limited to, authentication, encryption, backups, and access controls.
17. How Can Users Protect Their Personal Data?
You are solely responsible for preventing unauthorized access to your User Account by protecting your account credentials and limiting access to the devices you use to operate the Provider Portal. Vitala has no access to or control over your device’s security settings, and it is your responsibility to implement any device-level security features and protections you feel are appropriate (e.g., password protection, encryption, remote wipe capability). We recommend that you take all appropriate steps to secure any device that you use to access our Services and Provider Portal.
Please note that Vitala will never send you an email requesting confidential information, such as account numbers, usernames, passwords, or Social SecurityNumbers. If you receive a suspicious email from Vitala, please notify us at firstname.lastname@example.org.
Further, if you know of or suspect any unauthorized use or disclosure of your UserAccount information or any other security concern, please notify Vitala immediately.
18. What If Vitala Experiences a Data or Security Breach?
Vitala takes the security of your Personal Data seriously. In the event of a data or security breach, Vitala will take the following actions: (i) promptly investigate the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities within Vitala’s control which may have given rise to the security incident; (ii) comply with laws and regulations directly applicable to Vitala in connection with such security incident; (iii) as applicable, cooperate with any affected Vitala user or client in accordance with the terms of Vitala’s contract with such user or client, and (iv) document and record actions taken by Vitala in connection with the security incident and conduct a post-incident review of the circumstances related to the incident and actions/recommendations are taken to prevent similar security incidents in the future. Vitala will notify you of any data or security breaches as required by and in accordance with applicable law.
ADVERTISING, MARKETING, AND TRACKING
You are solely responsible for preventing unauthorized access to your User Account by protecting your account credentials and limiting access to the devices you use to operate the Provider Portal. Vitala has no access to or control over your device’s security settings, and it is your responsibility to implement any device-level security features and protections you feel are
19. Does Vitala Send Marketing or Advertisement Materials?
Vitala may use your Personal Data to contact you with newsletters, marketing, or promotional materials, and other information that may be of interest to you. You may opt-out of receiving any marketing or advertisement materials from Vitala at any time by following the unsubscribe link or by contacting us.
20. Can Users Opt-Out of Receiving Communications from Vitala?
We may send communications, including emails, to you regarding your User Account and the Services or Provider Portal. You can choose to filter any UserAccount, Services, and Provider Portal emails using your email settings, but we do not provide an option for you to opt-out of these communications.
If you consent to receive marketing or other communications not related to yourUser Account or the Services/Provider Portal, we will provide you with the option to opt-out of such marketing communications within the applicable message.
22. How Can Users Opt-Out of Cookies?
If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you enable a do not track signal or otherwise configure your browsers to prevent us from collecting cookies, you will need to reenter your login information each time you visit the login page. You may also be unable to take advantage of some of the Services.
23. Do Not Track Disclosure
Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. To date, there is no industry standard for DNT, and users cannot know how a given company responds to a DNT signal they receive from browsers. Vitala is committed to remaining apprised of DNT standards.However, Vitala does not support DNT browser settings and does not currently participate in any DNT frameworks that would allow Vitala to respond to signals or other mechanisms regarding the collection of your personal information.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, the California Consumer Privacy Act (“CCPA”) may apply to you. Please see the CCPA Attachment for an explanation of your rights.
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and obtain from us an annual list identifying the categories of personal customer information which we shared, if any, with our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will be provided free of charge. Contact information for such affiliates and/or third parties must be included. If you are a California resident and would like a copy of this notice, please submit a written request to the following address:
Vitala Health Inc.
16192 Coastal Highway, Lewes, Delaware