DESCRIPTION OF USERS AND ACCEPTANCE OF TERMS
Attn: Senior VP, Legal and Compliance
160 Chubb Avenue
Lyndhurst, NJ 07071
WHAT INFORMATION DO WE COLLECT/RECEIVE
In the course of operating the Platform, Vitals will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.
1. Personal Information
Vitals may obtain, collect, retain, store or otherwise maintain Your Personal Information from the following sources:
- Your SmartShopper Account: This information may include, for example, information You provide to Vitals through Your creation, registration, account activity, email address and maintenance of a user account on the Platform (“Registration Information”).
- Other Information You Provide to Vitals: Some of the Products and Services allow or require You to provide Personal Information, such as Your Healthcare Providers, pharmacies, insurance information, emergency contact information, personal health information, member number, group number and related information. Personal Information that You may store through the App by means of taking a photograph with Your mobile device (for example, taking a photograph of Your health insurance card) may be stored on Your mobile device. 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 Platform. These interactive Products and Services include, but are not limited to, scheduling appointments with Healthcare Providers. In order to provide you with these interactive Products and Services, We may ask you to provide Personal Information (such as the medical reasons for You scheduling the appointment). 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 From time to time, Vitals may communicate with You through postal mail, email, fax, telephone, or other forms of electronic communications regarding Your Smartshopper Account on the Platform, your activity on the Platform, inquiries you may make to Vitals customer service, the Products and Services, new Products and Services or certain tailored messages based on PHI or Personal Information. If You respond to these communications, Your responses may also 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 SmartShopper Account on the Platform or by not using the Products and Services. 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. Accordingly, You can determine to a large extent what Personal Information You wish to provide to Us. If you do not want your Health Plan to provide Personal Information to Vitals, you must make a request to your Health Plan.
2. Other Information
In addition to the Personal Information, we may collect and/or receive additional Information (collectively, the “Other Information”). Such Other Information may include:
a. From Your Activity. Vitals also collects non-personally identifiable server-log information relating to its Users. This information may include, but is not limited to, (i) Your SmartShopper account activity, including storage usage, number of log-ins, data displayed or selected, including user interface elements, links, etc; (ii) Your web or mobile application request, Internet Protocol address (“IP address”), the location of your computer (through the 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 WE USE AND SHARE THE INFORMATION
- Providing the Platform and the Products and Services to You, including but not limited to, the processing, formatting and displaying of Your Information, customized content and the delivery of customized Products and Services to You;
- Auditing, research and analysis in order to troubleshoot, maintain, protect and improve the Products and Services and the Platform;
- Ensuring the technical functioning of Vitals’ network and the Platform, including creating and maintaining backups or other archival copies of Personal Information and other related data;
- Developing and offering Products and Services, which may include use of Your Information by Vitals in connection with developing and offering to You Products and Services included but not limited to customized and tailored messaging regarding specific health conditions, health services, health education and/or disease prevention). Vitals will communicate about these Products and Services to You through postal mail, email, fax, telephone, text message, or other forms of electronic communications;
- For any purpose to which provided consent to your Health Plan;
- For any other purposes disclosed at the time the information is collected or to which you consent; creating aggregate data records (“Aggregate Data”), which Aggregate Data will not identify You or any other individual or include any personally identifiable information; and use and/or share Aggregate Data to improve Vitals’ products and services, understand usage, demand trends and general industry trends, develop white papers, reports, databases summarizing the foregoing, and generally for any purpose related to Vitals’ business;
You also authorize us to use and/or share Information as described below:
We may share Your Information with employees, contractors and agents of Vitals who need to know such Information for performing their duties with respect to the purposes set forth in this section. These individuals and/ or entities are bound by confidentiality obligations similar to those set forth herein.
We may disclose Your Registration Information to certain third parties in connection with the various programs, tools and services that are provided through the Platform.
We may employ third parties to perform services on Our behalf. Examples may include services to improve our Platform, marketing, advertising, compliance and promotional efforts and to facilitate transactions. These third parties will have access to Your Information only as necessary to perform their services, and they may not use Your Information for any other purpose.
We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
We may disclose Your Information, including Personal Information, to government authorities, and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We also may disclose Your Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other Users of the Platform, or anyone else that could be harmed by such activities.
Aggregated Non-Personal Information
We take reasonable and appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of Your Information, including Personal Information stored or maintained on our 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.
However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, We cannot guaranty the security of Your Information, including Personal Information.
ACCESSING AND UPDATING PERSONAL INFORMATION
Information You Provide When Registering For a SmartShopper Account
You may change or update the e-mail address and password that You provided when You registered for Your SmartShopper Account via the “settings” or “account settings” section of such account. If You registered separately for an account on both the Website and the App, changes or updates to registration information should be made separately on each account. You may terminate Your SmartShopper 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, We make 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 SmartShopper Account via the section of Your account where the information is located. Where applicable, We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and We 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 We provide information access and correction, We provide 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
All deletions, changes or updates that you make to Your Personal Information and account termination requests will take effect after We receive and process Your e-mail termination request. Except for deleted information that was stored exclusively on Your mobile device, residual copies of the deleted information, may remain in perpetuity in backup systems.
Deleting the App from Your mobile device will not terminate Your SmartShopper Account but will delete any information that You stored through the App by means of taking a photograph with Your mobile device (“Stored Photographic Information”). Terminating Your SmartShopper Account will not delete Stored Photographic Information unless You also delete the App from Your mobile device.
Attn: Senior VP, Legal and Compliance
160 Chubb Avenue
Lyndhurst, NJ 07071
Email address email@example.com
When Vitals receives formal written complaints at this address, its policy is to contact the complaining User regarding his or her concerns. Vitals will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Information that cannot be resolved between an individual and Vitals.
IMPORTANT NOTICE TO NON-U.S. RESIDENTS
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