Privacy Policy

Last Updated: January 20, 2017

Welcome, and thank you for your interest in Virta Health Corp. ("Virta", “we,” or “us”), and the Site.

This Privacy Policy (this “Policy”) describes the information that we gather from you on the Site, how we use and disclose such information, and the steps we take to protect such information. By using the Site, you acknowledge the privacy practices described in this Policy This Policy applies only to information you provide through the Site. Virta has a number of other websites that may or may not be accessed through the Site, through which individuals may participate in Virta programs or services. Any other websites and/or any participation in Virta programs or services, including any application for enrollment to participate in such programs or services, will be governed by separate Privacy Policies that you will be required to read and acknowledge to prior to such participation.

Capitalized terms used but not defined in this Policy have the meaning given to them in the Virta Terms of Use applicable to the Site (the “Terms”).

The information we collect on the Site:

  • User-provided Information. When you use the Site, you may provide and we may collect what is generally called “personally identifiable information,” or “personal information,” which is information that specifically identifies an individual. You may provide us with personal information of various types and in various ways on the Site. Examples of personal information include name, email address, mailing address, phone number, username, and password. Personal information also includes other information linked to information that identifies a specific individual, such as date of birth, gender, age, geographic area, preferences, payment information, and insurance information.
  • “Cookies" Information. When you use the Site, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Please review your web browser “Help" file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Site, you may not be able to utilize the features of the Site to their fullest potential.
  • “Automatically Collected" Information. When you use the Site, we may automatically record certain information from your device by using various types of technology, including “clear gifs" or “web beacons.” This “automatically collected" information may include your IP address or other device address or identifier, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Site, the pages or other content you view or otherwise interact with on the Site, and the dates and times that you visit, access, or use the Site, and your language preferences. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users.
  • Third Party Web Beacons and Third Party Buttons. We may also implement third-party content or advertising on the Site that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third party content on the Site. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow third parties to collect information about you through such third parties’ browser cookies, even when you do not interact with the button. Information collected through web beacons and buttons is collected directly by these third parties, and Virta does not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
  • Do Not Track Signals. Your device operating system or browser may include settings, options, or add-on components to control the placement and presence of cookies and access to location information. We do not track our users over time and across third party websites to provide targeted advertising and do not specifically respond to Do Not Track (“DNT”) signals. However, some third party websites do keep track of your browsing activities, including across other websites on the Internet, which enables these websites to tailor what they present to you. If you are visiting such websites, your browser may allow you to set a DNT signal on your browser so that third parties know you do not want to be tracked.
  • Information from Other Sources . We may obtain information, including personal information, from third parties and sources other than the Site, such as our partners or advertisers. If we combine or associate information from other sources with personal information that we collect through the Site, we will treat the combined information as personal information in accordance with this Policy. We and our third party service providers may obtain information regarding your location or the location of your device through which you access our the Site. Information regarding your location may be obtained directly from you when you provide us with information as part of the registration process. In addition, we may use Google Analytics, a web analytics tool that helps operators (like Virta) understand how users (like you) engage with their applications. Google Analytics uses cookies to track your interactions with the Site and to collect information about how you use the Site. We then use the information to compile reports that help us improve the Site. Google Analytics collects, processes and creates reports about website trends without identifying individual users. For more information regarding Google Analytics visit “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners.

How we use the information we collect. We use information we collect on the Site in a variety of ways in providing the Site and operating our business, including the following:

  • We may use the information that we collect on the Site (i) to operate, maintain, enhance and provide all features of the Site or any other Virta website or services, (ii) to provide services and information that you request, (iii) to respond to comments and questions, communicate with you about the Site, (iv) to verify your identity, (v) to detect, prevent, investigate and respond to fraud, intellectual property infringement, violations of our Terms, or other misuse of the Site or any other Virta websites or services, (vi) otherwise to provide support to users, and (vii) for any other use permitted by applicable law.
  • We may use the information that we collect on the Site to understand and analyze the usage trends and preferences of our users, to improve the Site or other Virta websites or services , and to develop new products, services, features, and functionality.
  • We may use your email address or other information we collect on the Site (i) to contact you for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to your User Content or (ii) to send communications, including updates on promotions and events, relating to products and services offered by us, by the Providers, and by third parties we work with. Generally, you have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
  • We may use “cookies” information and “automatically collected” information we collect on the Site to: (i) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Site; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of the Site and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Site.
  • We may access or store your information if it is necessary to detect, prevent or address fraud and other illegal activity or to protect the safety, property or rights of Virta or others.
  • We may use information regarding your location or the location of your device through which you access the Site for a number of purposes, including without limitation to confirm you are located in a jurisdiction in which the Site is offered and identifying an appropriate Provider.
  • We may de-identify your information and use, create and sell such de-identified information for any business or other purpose not prohibited by applicable law.

When we disclose information. Except as described in this Policy, we will not disclose your information that we collect on the Site to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

  • Any information that you voluntarily choose to include in a publicly accessible area of the Site, such as a public profile page, will be available to anyone who has access to that content, including other users.
  • We may disclose your information to Providers for treatment, or payment or operational purposes;
  • We work with third party service providers to provide website, application development, hosting, maintenance, analytics and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions.
  • We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties or users of the Site for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Site.
  • We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
  • We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Site and any facilities or equipment used to make the Site available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
  • Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
  • We may de-identify your information and disclose such de-identified information for any business or other purpose not prohibited by applicable law.

Your Choices

You may, of course, decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of the Site. You may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page on the Site. You may request that we provide to you the information we hold about you, update your information, or request that we delete your information or correct any inaccuracies by emailing us at privacy@virtahealth.com with the subject heading “personal information request”. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

You may ask us to contact you at a specific phone number or to send mail or notices to a specific mailing address or email address. If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by email at privacy@virtahealth.com or by writing to us at the address given at the end of this policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Site.

Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Site.

Residents of the State of California have the right to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To obtain this information, you should send a written request to privacy@virtahealth.com with the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.

Other Services

The Site may contain features or links to Web sites and services provided by Virta or third parties, and the Site may allow you to display, use or make available content, data, information, applications or materials from third parties. Any information you provide on any other sites or services is provided directly to the operators of such services (including Virta) and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Site. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Site. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Children’s Privacy

Protecting the privacy of young children is especially important. The Site is not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Site at any time or in any manner. If we learn that a person under 13 years of age has used or accessed the Site or any personally identifiable information has been collected on the Site from persons under 13 years of age, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on or otherwise accessed the Site, then you may alert us at privacy@virtahealth.com and request that we delete that child’s personally identifiable information from our systems.

Data Security

We use certain physical, technical, and administrative measures in an effort to protect the integrity and security of personal information that we collect and maintain. We cannot, however, ensure or warrant the security of any information you transmit to us or store on the Site, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or administrative measures.

Privacy Settings

Although we may allow you to adjust your privacy settings to limit access to certain personal information, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Site. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Site is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Site. We cannot and do not guarantee that information you post on or transmit to the Site will not be viewed by unauthorized persons.

Jurisdictional Issues

The Site may only be used within certain jurisdictions within the United States as set forth in the Terms. Accordingly, this Policy, and our collection, use, and disclosure of your information, is governed by U.S. law, and by using the Site, you acknowledge that the Site will be governed by U.S. law. Using the Site from outside the United States is prohibited under our Terms and may subject you to termination under such Terms. In no event will Virta or any of its officers, directors, employees, consultants, subsidiaries, agents, and affiliated entities, including Provider Group or any Provider, be liable for any losses or damages arising from your use of the Site outside of the United States, and you waive any claims that may arise under the laws of your location outside the United States. Notwithstanding the foregoing, we do not represent or warrant that the Site is appropriate or available for use in any particular jurisdiction. If you choose to use the Site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Site. By providing any information, including PHI, on or to the Site, you consent to such transfer, storage, and processing.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Site, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Site for the first time after such material changes are made. Your continued use of the Site after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.

Our Contact Information

Please contact us with any questions or comments about this Policy, your personal information, our use and disclosure practices, or your consent choices by email at privacy@virtahealth.com.

Virta Health Corp.
535 Mission Street 14th Floor
San Francisco, CA 94105

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