- Viedial’s digitally-based health care programs;*
- Viedial’s mobile applications (the “Apps”);*
- the websites that Viedial operates (the “Sites”); and
- all related services and features that Viedial provides.
Personal Information – In General
Personal Health and Nutrition Information
a. your past, present, or future physical, social, or mental health or condition; or
b. your fitness and nutrition-related activity (such as body weight, blood pressure level, activity levels, exercise programs, food and water intake (please confirm and adjust));
Federal and state law afford you certain rights with respect to any access to, use of, or disclosure of your PHI.
WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect various Personal Information from you and certain devices that you may use, as further described below. This includes information collected through clinical screeners, applications, registrations, and your use of the Services. We also collect Personal Information in connection with your inquiries. Collection starts from the time that you initially access our Services.
Information that we gather enables us:
- to administer your account,
- to provide you with the Services,
- to send you communications regarding the services we offer,
- to respond to your inquiries,
- to obtain your feedback on our Services,
- to understand who is using our Services and how the Services are performing,
- to otherwise analyze user behavior and activity,
- to personalize and improve our Services,
- to conduct research activities,
- to manage the security of the Services, and
- to fulfill any requirements imposed on us by applicable laws and regulations.
From time to time, we may use or augment Personal Information about you with information obtained from third parties. For example, we may use third-party information to confirm contact or financial information, to verify your coverage eligibility for Viedial Program, or to better understand your interests by associating demographic information with the information that you have provided.
In some cases, you will provide Personal Information, including Personal Health Information, to us in connection with your use of the Services, and in other cases, we may collect this information automatically when you visit or interact with the Site, the Apps, or other aspects of the Services. We provide more detail below on the types of Personal Information that you provide and the types of Personal Information that we collect automatically:
(i) Personal Information that You Provide to Us
We receive and store any information that you enter on our Site or through one of our Apps, information that you share with us by email or phone, and any other information that you provide to us through the Services. Personal Information that you provide may include your full name, gender, username and password, contact information (e.g., your phone number, your email address and the email address of your contacts, home and business postal addresses), certain health information (e.g., weight, pre-existing medical conditions, blood glucose and blood pressure readings, information concerning your exercise, sleep, and other activities), health insurance information, credit card and/or other payment information (where applicable for participants who pay for their own participation in the services), and any other information or data that you provide when using our Services.
In connection with the Viedial Program, we may enable you to share information with us using digital devices that we provide you that assists you in tracking changes in your health or fitness and supplies that information automatically to us on the Viedial Program. Examples of Personal Information that we may receive from these devices is your weight, blood glucose readings, and blood pressure readings.
We also may enable you to share information with us from third parties who have received your information because you subscribe to or otherwise participate in their services or because you use their digital equipment. We refer to these sources as “Third-Party Data Sources.” Third-Party Data Sources may include any digital device, such as blood glucose monitors, blood pressure monitors or other wearable health monitoring devices, that you already possess or that you later acquire on your own and not from us (“Third-Party Health Devices”). We may receive your Personal Information from Third-Party Health Devices if you enter that information manually through the Apps or the Sites or if you enable the device to supply information to us automatically. In addition to Third-Party Health Devices, Third-Party Data Sources may also include other third-party sources of data that you authorize to deliver information to us. Examples of Personal Information that we may receive from Third-Party Data Sources, including Third-Party Health Devices, include your weight, blood glucose readings, blood pressure readings, and information concerning your exercise, sleep, and other activities and biomarkers that affect your wellbeing and is relevant to the care Viedial is providing to you.
We will use the Personal Information that you provide for the purposes described above (and any other purposes intrinsic to the Services that you use) and to provide you with an engaging and personalized experience in using the Services. You can choose not to provide us with certain information, but if you do make that choice, we may be unable to provide you with access to or use of many of our features.
(ii) Personal Information Collected Automatically
In addition to any information that you provide to us through the Services, we and our third-party service providers may use a variety of technologies that store or collect certain information from you automatically (or passively) when you visit or interact with the Site, the Apps, or other aspects of the Services (“Usage Information”). This Usage Information may be stored or accessed using technologies downloaded to your device whenever you visit or interact with the Services. Examples of Usage Information include: your IP address, other unique device identifiers assigned to your device that allow our computers to recognize you, details of your device’s characteristics and functionality (e.g., browser, operating system, mobile network information), the areas within the Site, the Apps, or other aspects of the Services that you visit and your activities there, your device’s location, and certain other data regarding your device. To the extent we associate Usage Information with your Personal Information that we collect directly from you, we will treat it as Personal Information.
Information from Your Browser or Device
We automatically receive and record Usage Information from your browser on our server logs whenever you interact with the Site, the Apps, or other aspects of the Services. We may use this Usage Information to provide you with customer service and support. We also may use this Usage Information to recognize you when you arrive at the Site from an external link, such as a link appearing on a third-party site or in an email generated by us. We discuss this type of technology in more detail under “Tracking Technologies” below.
Our Services also collect Usage Information to determine how often visitors use parts of the Site, the Apps, or other aspects of the Services so that we can improve our Services and strive to ensure that the Services appeal to as many users and customers as possible. Our Services collect this data in a manner similar to how TV ratings may indicate the number of people that watched a particular show. We may provide this de-identified, aggregate data to our partners and/or customers to identify how our users use our Services, but we only use this data in aggregate form as a statistical measure to monitor how the Services function and not in a manner that would permit us to identify you personally.
You may set your browser to refuse or disable these data collection methods but doing so may change your experience with the Site, the Apps, or other aspects of the Services, diminish certain aspects of the Services’ functionality, or render certain features inoperable. For example, the Site may not recognize or respond to your browser with “do not track” technologies employed.
We may use various tracking methods or technologies (“Tracking Technologies”) to store or collect your Usage Information, including information about your visits to or interactions with our Site, the Apps, and other aspects of the Services. We use Tracking Technologies for a variety of purposes we believe to be necessary or helpful in improving or assessing the performance of the Services (for example, as part of our analytic practices) or in offering you enhanced functionality (for example, to identify you when you sign in, to keep track of your specified preferences, or to help ensure that the security of your account has not been compromised).
Tracking Technologies may include the following technologies and methods as well as any subsequent technologies and methods later developed to perform similar functions:
An embedded script is programming code designed to collect information about your interactions with the Site, the Apps, and other aspects of our Services, such as a link that you may click on. Embedded scripts are temporarily downloaded onto your device. Embedded scripts remain active only while you are connected to the Services and are then deactivated or deleted.
The Services may also include small graphic images or other web programming code called “web beacons” (also known as “1×1 GIFs” or “clear GIFs”). Any electronic image or other web programming code inserted into a page or email can act as a web beacon, and web beacons may be invisible to you. Web beacons and similar technologies may be used for several purposes, including to count visitors to the Services, to count how many sent emails were opened, to count how many articles or links were viewed, or to monitor how users navigate the Services.
WHO OWNS THE PERSONAL INFORMATION YOU DISCLOSE TO VIEDIAL?
You retain all ownership of your personal health information.
WHAT PERSONAL INFORMATION DO WE SHARE?
The following sections describe certain circumstances when we may share your Personal Information:
Information Shared with Other Users
. Your permission would be required before any information about you is shared with co-users. Please also note that your privacy would be protected if any information about you is to be shared.
If you enroll in Viedial Program, on your user profile page, you may provide information about your health, symptoms, and treatments, your feelings about your health information and/or yourself, or any other information about yourself. You may also upload pictures, videos, and stories to your user profile page. Any information that you choose to include in creating, completing, or updating your user profile page will only be accessible by you and Viedial to provide the Service.
In addition, in connection with your participation in Viedial Program, we may place you in an online peer group, and you may choose to enroll in other group-based communities that we may offer. The Site, the Apps, and other aspects of the Services may include the ability to interact with discussion boards, chat rooms, community pages, profile pages, bulletin boards, blogs, instant messaging or other messaging services, activities, polls, games, and other communication forums to which you post or otherwise make information or materials available (“Forums”). Please note that any information, text, and images that you post or disclose on or through the Forums may be visible to the present and future users in those groups or communities. However, Your name, User ID and user photo are not viewable to other peer group members when you send messages or when you disclose information on or through the Forums generally.
We take great care to protect your privacy, but please remember that we cannot control how other subscribers will use or disclose any information that is shared or disclosed to Forums. We urge you to exercise discretion and caution when deciding to disclose information through a Forum, or otherwise through the Services.
WE EXPRESSLY DISCLAIM ANY RESPONSIBILITY FOR THE USE BY OTHERS OF ANY INFORMATION, INCLUDING PERSONAL INFORMATION, THAT IS DISCLOSED BY YOU OR ON YOUR BEHALF OR YOUR USER PROFILE PAGE TO GROUPS OR OTHER PUBLIC-FACING FEATURES OF THE SERVICES, INCLUDING DISCUSSION BOARDS, CHAT ROOMS, MESSAGING SERVICES, OR OTHER FORUMS DESCRIBED ABOVE. BY DISCLOSING ANY OF YOUR INFORMATION THROUGH THESE FEATURES, YOU ACKNOWLEDGE AND ACCEPT ANY RISK AND DAMAGE ARISING FROM THE DISCLOSURE OF THAT INFORMATION.
Communications in Response to User Submissions
As part of the Services, you will receive from us email and other communications relating to your User Submissions. By posting User Submissions, you acknowledge and agree that we may send you email, text messages, phone calls, and other communications that we determine in our sole discretion relate to your User Submissions.
Information Shared with Our Agents and Service Providers
We employ other people and companies to perform tasks on our behalf, and we must share your information with them to provide products and/or services to you. By accessing or using the Services, you consent to and authorize Viedial to disclose Personal Information about you to our authorized personnel and administrators, including, for users that enroll in Viedial Program, our health coaches. Unless we have your authorization or consent, we limit these agents’ rights to use any Personal Information that we share with them to what is minimally necessary to assist us. We require these agents to keep your Personal Information that they receive from us confidential and to comply with applicable laws .
Reporting to Sponsors and Third-Party Administrators
We may, in our sole discretion, share, transfer, or otherwise disclose certain of your Protected Health and Nutrition Information to entities that are authorized or have your consent to receive that information for legally permitted purposes. We only share your Personal Information in accordance with applicable laws. per
Information Available to App Providers
By downloading any of the Apps from an App Provider, such as the Apple App Store or Google Play, please note that the App Provider and its agents may be able to identify you as a user of our Services.
Information Shared with Other Affiliated Businesses We Do Not Control
In order to provide you with the optimal user experience, we anticipate that we may work with a variety of third-party businesses. In certain situations, we may enable you to buy products or services of third-party businesses through the Services. In other situations, we may provide services or sell products jointly with affiliated businesses. You should be able to recognize when an affiliated business is associated with your transactions. Throughout the course of those transactions, we will share Personal Information that is related to those transactions with those affiliated businesses.
Referrals to Family, Colleagues, and Friends
From time to time, we may ask or invite you to refer our Services to family members, colleagues, or friends. We ask you to limit your invitations to people in your inner circle that may have an interest in our Services. In these cases, it is your responsibility to ensure that these persons are indeed family members (by marriage, common-law partnership, or parent-child relationship) or people with whom you have a personal relationship (based on frequency of communication, sharing of interests or opinions, etc.). If we refer one of these persons to the Services, we may inform them that you have suggested that they may be interested in trying our Services. If they request that we do not contact them again, we will not contact them again.
Our Business Transfers
Protection of Viedial and Others
We may release your Personal Information when we believe in good faith that releasing that information is necessary to comply with applicable law, to enforce our conditions of use and other agreements, or to protect the rights, property, or safety of Viedial, our employees, our users, or others. We may exchange information with other companies and organizations to detect, suppress, or protect against fraud and for credit risk reduction. If necessary and required by law, we will disclose any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted, electronically stored “personal information” or “medical information” (as defined by applicable laws). To the extent permitted by applicable laws, we may make these disclosures to you via email or a conspicuous posting on your private profile in the Services in the most expedient time possible and without unreasonable delay, so long as this is consistent with the legitimate needs of law enforcement and any other measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Viedial may de-identify the User Submissions that you share with us, including any Personal Information, or otherwise process them so that they are no longer attributable to you without additional information (“De-identified Data”). We may use that De-identified Data without restriction in any way allowed by law. For example, we might use De-identified Data to understand, evaluate, or modify the Services, to generate statistical information about the Services that we share with our customers and other third parties who are evaluating, analyzing, accrediting, or researching Viedial’s programs, or for our other business purposes. When an applicable law requires that we use a particular method of de-identifying data or rendering it no longer attributable to you, we will comply with that law. Otherwise, we may use a method that is appropriate under the circumstances and would not reasonably identify you.
IS MY PERSONAL INFORMATION SECURE?
We employ industry-standard administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. In addition, when we collect, maintain, use, disclose, and process your Personal Information, we will do so using systems and processes consistent with the information privacy and security requirements of applicable federal and state laws.
Your individual user account is also protected by a password for your privacy and security. To help avoid unauthorized access to your account and Personal Information, we suggest that you safeguard your password appropriately, limit access to your devices and browsers, and sign off after you have finished accessing your account.
In addition, to the extent that you use one of the Apps and your device permits that App to send you push notifications, we may send you push notifications that include Personal Information and, in limited instances, PHI that is not encrypted. Depending on your device settings, push notifications may be visible to other people who encounter your device. In most cases, you can opt out of receiving push notifications by adjusting the settings on your device. To the extent that you do not opt of receiving push notifications, you agree to receive push notifications and to be responsible for the security and confidentiality of any information displayed in push notifications on your devices.
We exercise great care to protect your Personal Information. However, we cannot ensure the security or confidentiality of any Systems or Connections that you use to transmit information to us. For example, we cannot ensure that your email or your mobile phone or any other personal device is secure. In addition, communication lines used to transmit emails and text messages do not have the same security features that are built into our Services.
Although we take great care to protect your Personal Information, we cannot guarantee that criminals or others acting unlawfully will not succeed in efforts to undermine our security measures. Unauthorized entry to, access to, or use of our systems or locations, hardware or software failure, loss, and other factors may compromise the security of your information at any time.
HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?
WHAT PERSONAL INFORMATION CAN I ACCESS AND CORRECT?
If you have an account with us to receive one of the Viedial Programs, you can access certain information about you described below through the App or otherwise through the Viedial Program in order to view, and in certain situations, update that information. This list may change as the Services change.
- First and last name
- Account and user profile information (e.g., nickname and picture)
- User email address
- User mailing address
- User phone number
- Username and password
- Communication preferences (e.g., email and push notifications)
- Weight data
- Activity tracking data
- Food tracking data
- Blood glucose measurements (if applicable to the Services you receive)
- Blood pressure measurements (if applicable to the Services you receive)
- Biomarkers that are relevant for cardiovascular disease diagnosis and care
WHAT RIGHTS AND CHOICES DO I HAVE REGARDING MY PERSONAL INFORMATION?
(i) Choosing Not to Disclose
You may choose not to disclose information to us, even though that information may be necessary to take advantage of certain features of the Services.
(ii) Requesting Information
You also have the right to request certain information from us, specifically:
- a copy of the Personal Information that we collect from you,
- a description of the specific pieces of Personal Information that we collect from you,
Unsubscribing from Communications
Deleting Your Personal Information
HOW DO WE PROTECT CHILDREN’S PERSONAL INFORMATION?
The Services are not directed to children, and we do not knowingly collect Personal Information from children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of the Services. If a parent or guardian becomes aware that a child has provided us with Personal Information, please contact us. If we become aware that a user of the Services under the age of 18 has provided us with Personal Information without verifiable parental consent, we will delete such Personal Information from our files.
Thank you for using Viedial Healthcare Limited.