This Privacy Policy applies to all visitors to, and users of, Viora Health, Inc.’s (“Viora Health,” the “Company,” “our,” “us,” or “we”) website www.viorahealth.com (the “Site,” or the “Website”) and related services (collectively, “Viora’s Products and Services”).
Viora Health respects the privacy of all visitors and users of Viora Health’s Products and Services and is committed to protecting privacy through our compliance with this Privacy Policy. We understand that Personal Information and Protected Health Information (both, defined below) are private, and we are dedicated to maintaining the accessibility, confidentiality and integrity of all such information. Users, subject to review and acceptance of this Privacy Policy, will have the option, using a user name and password subject to certain security criteria, to access and use Viora Health’s Products and Services.
Your Consent To This Privacy Policy
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our Privacy Policy, your choice is not to use Viora Health’s Products and Services By using our website, you agree to our Privacy Policy and our Terms of Use.
We may change this Privacy Policy and our Terms of Use from time to time, and while we will do our best to notify you of any changes it is your responsibility to review this Privacy Policy and the Terms of Use periodically. Your continued use of Viora Health’s Products and Services after we make changes is deemed to be an acceptance of those changes, so please check our Privacy Policy periodically for updates. When we do change the Privacy Policy or Terms of Use, we will also update the “Effective” date on the relevant document and may notify you or post a message via our Website.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of Viora Health’s Products and Services. This Privacy Policy describes the types of information we may collect from you or that you may provide, and our practices for collecting, using, maintaining, protecting and disclosing that information. At all times, we will only use or disclose your Personal Information and Protected Health Information (both, defined below) to the extent minimally necessary for the intended use or disclosure.
The Privacy Policy applies to information we collect:
- On our Website.
- Via e-mail, text, video and voice communications between you and us.
- Via electronic communications between you and us and between you and our Website.
- From physicians, hospitals, clinics, schools, and any other organizations or entities that you expressly authorize to share information with Viora Health.
- Through any and all of Viora Health’s Products and Services.
Personal Information
As used in this Privacy Policy, “Personal Information” means any information that may be used to identify an individual, such as your first and last name, age, gender, postal address, e-mail address, telephone number, other contact information, certain health information, or other personally identifiable information under an applicable law such as the Health Insurance Portability and Accountability Act (“HIPAA”) or an equivalent State law governing the use or disclosure of health information. When you use Viora Health’s Products and Services, we may collect, use or disclose your Personal Information but only to the extent minimally necessary and consistent with our Notice of Privacy Practices. If you so authorize, you acknowledge that we may collect this Personal Information from you directly or from third parties that you authorize to share Personal Information with Viora Health. It is entirely your choice whether or not to provide Personal Information through Viora Health’s Products and Services. If you choose not to provide requested Personal Information, you may not be able to use certain features of Viora Health’s Products and Services.
Protected Health Information
As used in this Privacy Policy, “Protected Health Information” (“PHI”) means Personal Information in conjunction with information related to physical or mental health, such as medical history, family history, medical diagnosis, health background, current health status, age, gender, sexual behavior and sexual orientation, demographic information (including race, ethnicity, marital status, salary, education, political, religious, and trade union information) and information related to the diagnosis and treatment of health conditions, over-the-counter and prescription medications, laboratory test results, payments for treatment and health insurance information or other personally identifiable information under an applicable law such as HIPAA or an equivalent State law governing the use or disclosure of Protected Health Information and as defined by HIPAA. When you use Viora Health’s Products and Services, we may collect, use or disclose Protected Health Information but only to the extent minimally necessary and consistent with our Notice of Privacy Practices.
From time to time, we may use or augment the Personal Information we have about you with information obtained from third parties (e.g., FitBit or Apple). For example, we may use such third party information to confirm contact or financial information, to verify eligibility, or to better understand your interests by associating demographic information with the information you have provided.
We collect the following types of information:
Personal Information You Provide to Us
We receive and store any information you enter on our Site, our Mobile App or provide to us through the Services, including any third party services that you connect with our Services (e.g., FitBit or Apple). Personal Information that we collect may include things like your full name, gender, mobile phone number, credit card and/or other payment information (if applicable – i.e., self-pay participants), your email address and the email address of your contacts, home and business postal addresses, IP address, browser information, username, password, certain health information (e.g., height, weight, blood pressure, blood glucose, pre-existing medical conditions, tracking of food, sleep and/or activity and insurance information), and any other information or data that you provide when using our Site, our Mobile App and/or our Services. You can choose not to provide us with certain information, but that may result in our inability to provide you access to or use of many of our features. Viora Health’s goal is to use the Personal Information you provide for such purposes as answering questions and communicating with you about the Company’s products and services, including updates and new features.
PLEASE NOTE: By using the Services, you consent to and authorize Viora Health to disclose your eligibility for and participation in the Services (i.e., you meet the enrollment criteria for the Services, which may identify those individuals at risk for or living with diabetes type two and have elected at your own discretion to participate in the same) to the other users of the Site, the Mobile App and the Services. The users, including but not limited to administrators, health coaches and other authorized Viora Health personnel, and your support group members will have access to a range of Personal Information such as your user name and picture, linking you to your diagnosis and/or reason for program participation. Moreover, as we group participants based on certain characteristics, support group members may be co-workers or other acquaintances.
We take great efforts in protecting your privacy; however, we cannot control, and expressly disclaim any responsibility for, whether or how users will subsequently use or disclose posted or previously disclosed information. If you do not consent to the disclosure of this information, you should not access or use the Site, the Mobile App or the Services. The Services include the ability for users to share Personal Information, including information regarding your medical condition. Any information you choose to provide or upload to the group Sites or the Mobile App, including Personal Information about your medical condition, will be visible to your group, as well as health coaches, administrators, and other users. As your information will be viewable to the other users of the Site, the Mobile App and the Services, you should provide only the information you feel comfortable disclosing. There may be an opportunity to speak on the phone or via video chat in a group conference call. Participation in such opportunities is not mandatory, but should you choose to participate, you should share only as much information as you feel comfortable sharing in these additional forums.
Personal Information Collected Automatically
We receive and store certain types of information whenever you interact with the Site, the Mobile App and / or use the Services. We automatically receive and record information on our server logs from your browser, including your IP address, and the page you requested. In addition, we may use personal identifiers to recognize you when you arrive at the Site via an external link, such as a link appearing on a third party site or in an Viora Health generated email presented to you. See also our What About Tracking Technologies? section below. We will also use your information to provide customer service and support.
Generally, our Services automatically collect usage information, such as the numbers and frequency of visitors to the Site and Mobile App and its components, similar to TV ratings that indicate how many people watched a particular show. We only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would permit us to identify you personally (“De-identified Information”). This type of aggregate data enables us to figure out how often users or customers use parts of the Site, Mobile App or Services so that we can make the Site, Mobile App and Services as appealing to as many users and customers as possible and improve our Services. We may provide this de-identified, aggregate data to our partners and/or customers to identify how our users use our Site, Mobile App and/or Services. Again, we never disclose information to a partner or customer in a manner that would 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 Mobile App or the Services, diminish certain aspects of the Site’s or Mobile App’s functionality or render certain features of the Site, the Mobile App or the Services inoperable. The Site may not recognize or respond to “do not track” technologies employed by your browser.
E-mail Communications
We often receive a confirmation when you open an email from us if your computer supports this type of program. We use this confirmation to help us make emails more interesting and helpful. We also compare our customer list to lists received from other companies in an effort to avoid sending unnecessary messages to our customers. When you receive e-mail from us, you can opt out of receiving further e-mails by following the included instructions to unsubscribe. However, by opting out of further email communications after you enroll in the Services, you may limit program reminders and other valuable program content and components.
What About Tracking Technologies?
In addition to any Personal Information or other information that you choose to submit to us via the Site, Mobile App or Services, we and our third party service providers may use a variety of technologies that automatically (or passively) store or collect certain information when you visit or interact with the Site, Mobile App or Services (“Usage Information”). This Usage Information may be stored or accessed using technologies that may be downloaded to your Device whenever you visit or interact with the Site, Mobile App or Services. To the extent we associate Usage Information with your Personal Information that we collect directly from you, we will treat it as Personal Information. Examples of Usage Information include: your IP address or other unique device identifier (e.g., a number that is automatically assigned to your Device used to access the Site which our computers use to identify your Device), your Device’s functionality (e.g., browser, operating system, mobile network information, etc.), the areas within the Site or Services that you visit and your activities there, your Device location, your Device characteristics and certain other data regarding your Device.
We may use various methods or technologies to store or collect your Usage Information, including your visits to or interactions with our Site, Mobile App and Services (“Tracking Technologies”). We may use these Tracking Technologies for a variety of purposes, including but not limited to uses deemed to be necessary or useful to assess the performance of our Site, Mobile App and Services (including as part of our analytic practices or otherwise to improve our Site, Mobile App and Services) or uses required to offer you enhanced functionality when accessing our Site, Mobile App and Services (including identifying you when you sign in to the Site or the Mobile App or keeping track of your specified preferences).
Tracking Technologies that may include the following (and may include subsequent technologies and methods later developed which perform a similar function):
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your browser to enable our systems to recognize your browser and tell us how and when pages in our Site are visited and by how many people. We use cookies to enhance visitors’ experiences by understanding how visitors and / or users engage with and navigate our Site. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers and in some but not all instances can be blocked in the future by selecting certain settings. Each browser that you use will need to be set separately, and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to certain types of cookies (e.g., Adobe Flash or HTML5 cookies). Please be aware that if you disable or remove cookies on your Device, some parts of our Site or Services may not function properly and when you revisit our Site or Services your ability to limit cookies is subject to your browser settings and limitations.
We may choose to serve ads on the Site or the Mobile App. These ads may be delivered to users by our advertising partners, who may set cookies. These cookies allow the ad server to recognize your Device each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy refers only to the use of cookies by the Company and does not cover the use of cookies by any third parties (e.g., advertisers).
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, Mobile App and Services, such as the links that you click on. The code is temporarily downloaded onto your Device, is active only while you are connected to the Site or Mobile App, and is deactivated or deleted thereafter.
Web Beacons. Small graphic images or other web programming code called “web beacons” (also known as “1×1 GIFs” or “clear GIFs”) may be included in pages and messages of our Site, Mobile App and Services. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including to count visitors to the Site, Mobile App and Services, to monitor how users navigate the Site, the Mobile App and Services, to count how many sent e-mails were actually opened or to count how many particular articles or links were actually viewed.
There may be other Tracking Technologies now and later devised and used by us in connection with the Site, Mobile App and Services. Further, third parties may use Tracking Technologies with our Website. We do not control those Tracking Technologies, and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with your use of the Site and Services and accept that this Privacy Policy does not apply to the Tracking Technologies or practices of such third parties. In such cases, you must check the third party websites to confirm how your information is collected and used.
Upon obtaining your express authorization, you acknowledge that we may collect this Personal Information from you directly or from third parties that you may authorize to share Personal Information with Viora Health. We may ask you or authorized third parties to provide Protected Health Information about you that will enable us to enhance our ability to serve your needs and/or your use of Viora Health’s Products and Services. It is entirely your choice whether or not to provide Protected Health Information through Viora Health’s Products and Services. If you choose not to provide requested Protected Health Information, you may not be able to use certain features of Viora Health’s Products and Services.
Accessing and Correcting Your Personal and/or Protected Health Information
You can review and, subject to applicable laws, change your Personal Information by accessing Viora Health’s Products and Services via your secure user name and password.
You may also send us an e-mail at support@viorahealth.com to request access to, correct or delete any Protected Health Information, subject to applicable laws.
We may not be able to accommodate a request to change Personal or Protected Health Information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Technical Information
We may collect and use technical data and related information, including but not limited to technical information about your device (e.g., manufacturer, service provider, IP address, operating system, browser type, mobile number) system and application software, peripherals and your interactions with Viora Health’s Products and Services including automatically recording the dates and times of visits to Viora Health’s Products and Services, traffic data, and your search queries (“Technical Information”). Technical Information is gathered periodically to facilitate the provision of software updates, product support, product enhancements and other services to you (if any) related to Viora Health’s Products and Services, to estimate our audience size and usage patterns, store information about your preferences (allowing us to customize our products and services according to your individual interests), speed up your searches, and recognize you when you return to our Website and/or use Viora Health’s Products and Services. We may also automatically receive and record information on our server logs from your browser or mobile device, which could include your IP address, cookie information, browser information and the pages you visit/request. Viora Health does not consider nor intend Technical Information to constitute Personal or Protected Health Information. Viora Health may use the Technical Information in any manner it deems appropriate and lawful.
Choices About How We May Use Or Disclose Your Information
We strive to provide you with choices regarding your Personal and/or Protected Health Information. We have created mechanisms to provide you with the following control over your Information. You can set your browser to refuse all or some browser cookies (described below) or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of Viora Health’s Products and Services may then be inaccessible or not function properly.
We may use your Information to contact you about our own and third-parties’ products and services that may be of interest to you. The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of Viora Health’s Products and Services. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
How We May Use or Disclose Your Information
Except as described in this Privacy Policy or in our Terms of Use, Personal Information, Protected Health Information, Technical Information, Location-Based Information and Behavior Tracking Information (collectively, “Information”) that you provide or that we collect from third parties, will be kept confidential and used or disclosed only to the extent minimally necessary to support Viora Health’s Products and Services. Viora Health’s Products and Services exist to streamline the patient consumer healthcare experience and help our partners – health plans, providers and community partners – identify qualifying regulatory benefits. Viora Health’s proprietary SaaS platform connects a nationwide network of community organizations and digital solutions for chronic disease prevention programs (including the CDC National Diabetes Prevention Program) with technology that manages service referrals, reimbursement and payment, aggregates data, and simplifies enrollment and supporting increased consumer engagement and choice. In order to provide for these types of exchanges, we need to ensure that each user that contributes Information expressly permits the uses or disclosures we envision. For this reason, we need a license from you to use or disclose Information, whether collected directly from you or, if applicable, third parties that you identify. You hereby grant Viora Health a non-exclusive, transferable, sub-licensable, royalty free license to use Information in order to enable, provide and make improvements to Viora Health’s Products and Services. The license is non-exclusive (meaning you are free to license the Information to anyone else in addition to us), fully-paid and royalty-free (meaning that we are not required to pay you for our use of the Information), sub-licensable (so that we are able to use affiliates and subcontractors), transferable (meaning that we may transfer it to a third party should we restructure our business) and irrevocable (meaning that you may not revoke or rescind such license for any reason once the Information is uploaded).
You also grant Viora Health a perpetual, non-exclusive, transferable, sub-licensable, royalty free license to use such Information and other data we collect in order to collect, develop, create, extract or otherwise generate statistics and other information and to otherwise compile, synthesize and analyze such Information and de-identified data (“Blind Data”). Notwithstanding anything to the contrary in this Privacy Policy, to the extent Viora Health collects or generates Blind Data, such Blind Data will be owned solely by Viora Health and may be used for any lawful business purpose without a duty of accounting to you, provided that such data is not personally identifiable and does not identify the source of such data.
We may use or disclose your Information only to the extent minimally necessary:
- To present and facilitate Viora Health’s Products and Services to you and/or on your behalf.
- To provide you with information, products or services that you request from us.
- To provide you with notices and to facilitate communications deemed appropriate by us and/or your physician.
- To fulfill any other purpose for which you provide the Information.
- To carry out our obligations and enforce our rights arising from any contracts we have entered into regarding you.
- To notify you about changes to Viora Health’s Privacy Policy and/or Viora Health’s Products and Services.
- To allow you to participate in interactive or educational features on our Website.
- To comply with any court order, law or legal process, including responding to any government or regulatory request.
- To enforce or apply our Terms of Use.
- If we believe disclosure is necessary or appropriate to protect the rights, privacy, security, accessibility of Information and/or property of Viora Health.
- In any other way that we may describe when you provide the Information.
- For any other purpose with your lawful consent.
How We Secure Your Information
We have implemented reasonable and appropriate administrative, technical, and physical safeguards designed to protect the Information from unauthorized access, use or disclosure. All Information you provide to us is stored with an authorized cloud services provider. These safeguards include, without limitation, encrypting all Personal Information and Protected Health Information.
The safety and security of your Information also depends upon you. Where we have given you (or where you have selected) a user name and password to access Viora Health’s Products and Services, you are responsible for keeping this information confidential. It is in your best interest that you not share your user name or password with anyone.
Please keep in mind that whenever you voluntarily disclose Information on message boards or other public forums or features or through e-mail or group messaging, that Information can be collected and used by others to whom you may or may not have given consent. In short, by posting Information online that is publicly accessible (i.e. within message boards and the like), you may receive unsolicited messages from other parties in return or make others aware of your location. We are not responsible for the security or privacy of any Information you choose to submit outside the scope of Viora Health’s Products and Services.
Third-Party Products, Services and Technologies
We may provide links to third-party websites within Viora Health’s Products and Services. Such links may appear as a specific domain name or URL. Please be aware that other websites and services, including the websites of third parties that you connect with through Viora Health‘s Products and Services, may collect personally identifiable information about you. This Privacy Policy does not cover the information practices of those third-party websites, services or applications and cannot control and is not responsible for the information collection practices of any such websites, services or applications. We encourage you to carefully review the terms of use, privacy policies, and any other legal notifications on such websites before using or providing information through such websites, services or applications.
HIPAA
Physicians or other health care providers, to the extent they are “Covered Entities” under HIPAA (as such term is defined in HIPAA), likely have their own privacy and security obligations with respect to your Personal Information and Protected Health Information. For more information regarding your rights under HIPAA, see www.hhs.gov/ocr/privacy/.
Do Not Track Policy
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to digital services that a visitor does not want to have his/her online activity tracked. If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block the digital service from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, we and many other digital service operators do not respond to DNT signals.
Children’s Privacy Policy
Viora Health’s Products and Services are not designed or intended to be accessed by children under the age of 13. No one under age 13 may provide any information to or through Viora Health’s Products and Services. If you are under age 13, do not provide any information on or through Viora Health’s Products and Services, including, but not limited to, your name, address, telephone number, e-mail address, user name, health information or other. We do not intentionally collect Personal Information directly from children under the age of 13 through Viora Health’s Products or Services. We also do not collect any Protected Health Information from anyone under 18 unless expressly authorized under Federal and equivalent State law. No one under age 18 may provide any health-related information to or through Viora Health’s Products and Services unless Viora Health confirms that such disclosure would comply with applicable Federal or State laws.
If we learn we have collected or received Personal or Protected Health Information from a child under age 13 without verification or parental consent, we will delete that information and take other appropriate measures. If you believe that we may have collected any information, including Personal or Protected Health Information, directly from a child under age 13, please contact us immediately at support@viorahealth.com.
Changes to Our Privacy Policy
It is our policy to post any changes that we make to our Privacy Policy on this page and on our home page. If we make material changes to how we treat our users’ Personal or Protected Health Information, we will notify you by e-mail to the primary e-mail address you have provided and/or through a notice on the home page of our Website. The date our Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this Privacy Policy for changes. For any questions or comments regarding this Privacy Policy, please contact us at support@viorahealth.com.
Questions or Concerns
If you have any questions, concerns or complaints regarding privacy on our Site or Mobile App or if you want to make a request to access or correct your Personal Information, please contact our Privacy Officer at:By email: support@viorahealth.com
We will make every effort to respond to your questions, concerns complaints and requests within a reasonable time.
Effective Date: June 22, 2018