Effective date: October 2019
Last updated: April 2021
WE AT VIDERA VALUE YOUR PRIVACY AND ARE COMMITTED TO KEEPING YOUR PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF HELPING YOU IMPROVE YOUR HEALTH BY OFFERING A CONVENIENT AND HIGH QUALITY MOBILE APP AND WEB SITE WITH TOOLS THAT ALLOW USERS TO EASILY AND PURPOSEFULLY MANAGE COMPLEX MEDICAL CONDITIONS.
THE PERSONAL DATA WE COLLECT AND TRANSMIT MAY, IN SOME CIRCUMSTANCES, BE CONSIDERED “HEALTH DATA” (data related to a user’s physical or mental health). THEREFORE, OUR PRIVACY PRACTICES ARE INTENDED TO COMPLY WITH THE GENERAL DATA PROCESSING REGULATION (“GDPR”) PROVISIONS REGARDING SENSITIVE PERSONAL DATA. IN ADDITION, WE INTEND TO COMPLY WITH STATE LAW RELATED TO HEALTH DATA, WHERE APPLICABLE. FOR ADDITIONAL INFORMATION RELATED TO YOUR HEALTHCARE INFORMATION, PLEASE CONTACT OUR PRIVACY OFFICER AT firstname.lastname@example.org.
Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. For the purposes of Applicable Data Protection Laws including the European Economic Area data protection law, (the “Data Protection Law”), the data controller is:
Videra Health, Inc.
898 N 1200 W Ste. 201
BY SUBMITTING YOUR PERSONAL DATA THROUGH THIS APP, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE APP AND DO NOT SUBMIT ANY PERSONAL DATA TO US.
Links to Other Sites
What Personal Data do we collect?
We collect “PERSONAL DATA”, which includes any information that can be used on its own or with other information in combination to identify or contact one of our users. In some cases, this Personal Data may be or may include healthcare information or “protected health information.” The types of Personal Data we collect are described below.
We collect demographic information such as your name, email address, age, gender, phone number, postal address, and personal health information. Primarily, the collection of your Personal Data assists us in creating your User Account, which you can use to securely track, manage, and transmit to your healthcare provider your Personal Data.
Device, Telephone, and ISP 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 App or interact with emails We have sent You. The information we collect may include your Internet Protocol (IP) address (or proxy server), device and App 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, to help us provide and improve our App and to guarantee their security and continued proper functioning.
In addition to demographic information, we may collect information regarding your health conditions, medications, medical appointments, insurance provider, and your healthcare provider. We also collect physical characteristics such as natural language processing and your facial movements and expressions when you use video to communicate with your employeer via the App. We collect this information to help employers and employees track and manage the employees’ health conditions.
Third Party Data Sources
We may collect information about you from other sources, including third parties from whom we have purchased Personal Data, and combine this information with Personal Data provided by you. In particular, we collect Personal Data from the following sources:
- GitHub, to manage code check-ins and pull requests.
How will We use Your Personal Data?
We process Your Personal Data for purposes based on legitimate business interests, meeting our contractual obligations to you, complying with our legal obligations, and/or your consent. We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described herein. Where required by law, we will ask for your prior consent before doing so.
Specifically, we process Your Personal Data for the following legitimate business purposes:
- 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 or 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
- To manage and improve our operations and the App, including the development of additional functionality
- To manage payment processing
- To evaluate the quality of service You receive, identify usage trends, and thereby improve Your user experience
- To keep our App safe and secure for You and for Us
- To send You product, service and new feature information and/or information about changes to our terms, conditions, and policies (with your consent, if required by law)
- To allow us to pursue available remedies or limit the damages that we may sustain
- To provide access to a third party user (with your consent), to enable that individual to monitor your progress and overall condition and to follow up with you, as they deem appropriate (e.g., you can give access to your caregiver, parent, child, or spouse).
- To aggregate and anonymize Your data to help us conduct research and improve the App.
**You can opt-out of receiving promotional emails by changing the notification preferences in your
account settings or by unsubscribing via the “Unsubscribe” link in any Videra email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the App.
Where is your Personal Data processed?
Personal Data Videra collects through the App will be stored on secure servers in the United States, even if you are accessing the App from outside the United States. Your country’s data protection laws may not apply and may be more stringent than those to which Videra is legally subject. 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 United States.
Will we share your Personal Data with anyone else?
Yes, with third parties that help us power our App
Videra has a limited number of service providers and other third parties (“Business Partners”) that help us run various aspects of our business. These 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 service, and billing management.
Yes, with third parties and the government when legal or enforcement issues arise
We may share your Personal Data, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in
Yes, with third parties that provide advisory services
We may share Your Personal Data with Our lawyers, auditors, accountants, or banks, when We have a legitimate business interest in doing so.
Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Videra’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings)
If We share Your Personal Data with a third party other than as provided above, You will be notiﬁed at the time of data collection or transfer, and You will have the option of not permitting the transfer.
We may, from time to time, rent or sell aggregated data and/or other information that does not contain any personal identiﬁers (i.e., the information has been anonymized by stripping out identiﬁers such as name, address, phone number, etc.). The purpose of this type of disclosure is to describe the App to current and prospective business partners and other third parties. The anonymized data may also be shared or published through academic journals or media platforms for lawful purposes. Once your data is anonymized, it is no longer Personal Data, and we are not restricted in our use of that data for any purpose.
How long do we retain Personal Data?
We will retain your Personal Data for as long as you maintain a User Account and up to 7 years after the account is closed. The exact period of retention will depend on the type of Personal Data, our contractual obligation to you, and applicable law. We keep your Personal Data for as long as necessary to fulfill the purpose for which it was collected, unless otherwise required or necessary pursuant to a legitimate business purpose outlined herein. At the end of the applicable retention period, we will remove your Personal Data from our databases and will request that our Business Partners remove your Personal Data from their databases. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing of such data. We retain anonymized data indeﬁnitely. Contact Us at email@example.com regarding the applicable data retention period for your Personal Data.
NOTE: Once we disclose your Personal Data to third parties, we may not be able to access that Personal Data any longer and cannot force the deletion or modiﬁcation of any such information by the parties to whom we have made those disclosures. Written requests for deletion of Personal Data other than as described should be directed to firstname.lastname@example.org.
We may also collect information using pixel tags, web beacons, clear GIFs or other similar technologies. These may be used in connection with some Site pages and HTML formatted email messages to, among other things, track the actions of Site users and email recipients, and compile statistics about Site usage and response rates.
|Cookie Name, Who Controls It, and Duration||Purpose||Information Collected||How to Withdraw Consent|
While you are logged in or up to 15 minutes of inactivity
|To authenticate you when you sign into the service.||A generated token that allows the server to identify you.||Do not use our Service if you do not want to receive this cookie.|
|Cookie Name, Who Controls It, and Duration||Purpose||Information Collected||How to Withdraw Consent|
While you are logged in or up to 15 minutes of inactivity
|To determine whether your data will be used in a sample of user experience data.||Randomly generated code. No information is collected.||Click here|
|For correlating your experience with your past experiences on the App.||No information is collected or stored.||Click here|
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
How can You “Opt Out” of Cookies
Videra Health does not respond to “Do Not Track” signals or other related mechanisms at this time.
You may opt-out from the collection of non-essential device and usage data on your web by managing your cookies at the individual browser level. Click here for ways to erase cookies from your computer and to prevent cookies from being created on your browser. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, You may not be able to take full advantage of the websites.
How do we protect your Personal Data?
Videra is committed to protecting the security and conﬁdentiality of your Personal Data. We use a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot absolutely ensure the security of information you transmit to us. By using the App, you are assuming this risk.
The information collected by Videra and stored on secure servers is protected by a combination of technical, administrative, and physical security safeguards, such as authentication, encryption, backups, and access controls. If Videra learns of a security concern, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by an in app notiﬁcation. Depending on where you live, you may have a legal right to receive such notices in writing.
You are solely responsible for protecting information entered or generated via the App that is stored on your device and/or removable device storage. Videra has no access to or control over your device’s security settings, and it is up to you to implement any device level security features and protections you feel are appropriate (e.g., password protection, encryption, remote wipe capability, etc.). We recommend that you take any and all appropriate steps to secure any device that you use to access our App.
NOTWITHSTANDING ANY STEPS THAT WE TAKE, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US, AND YOU TRANSMIT SUCH PERSONAL DATA AT YOUR OWN RISK.
How can you protect your Personal Data?
Please be advised that we will NEVER send you an email requesting conﬁdential information such as account numbers, usernames, passwords, or social security numbers, and you should NEVER respond to any email requesting such information. If you receive such an email purportedly from Videra, DO NOT RESPOND to the email, DO NOT CLICK ON ANY LINKS AND/OR OPEN ANY ATTACHMENTS in the email, and NOTIFY VIDERA SUPPORT at email@example.com.
You are responsible for taking reasonable precautions to protect your user ID, password, and other User Account information from disclosure to third parties, and You are not permitted to circumvent the use of required encryption technologies. You should immediately notify Videra at firstname.lastname@example.org if you know of or suspect any unauthorized use or disclosure of your user ID, password, and/or other User Account information, or any other security concern.
You have certain rights relating to your Personal Data, subject to local data protection laws. These rights may include the right to:
- access your Personal Data held by us
- erase/delete your Personal Data, to the extent permitted by applicable data protection laws
- receive communications related to the processing of your personal data that are concise, transparent, intelligible and easily accessible;
- restrict the processing of your Personal Data to the extent permitted by law (while we verify or investigate your concerns with this information, for example);
- 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
- lodge a complaint with a supervisory authority
- rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete
- not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”); and
- withdraw your consent at any time (to the extent we base the collection, processing and sharing of your Personal Data on your consent) without affecting the lawfulness of the processing based on such consent before its withdrawal.
You can exercise the rights listed above at any time by contacting us at email@example.com.
How do you update, correct, or delete Personal Data?
You may change your email address and other contact information by contacting your healthcare provider. If you need to make changes or corrections to other information, you may contact your healthcare provider or firstname.lastname@example.org. Please note that in order to comply with certain requests to limit use of your Personal Data, we may need to terminate your account and your ability to access and use the Services, and you agree that we will not be liable to you for such termination or for any refunds of prepaid fees paid by you. You may deactivate your account by contacting your healthcare provider or email@example.com.
Although we will use reasonable efforts to do so, you understand that it may not be technologically possible to remove from our systems every record of 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.
Can You “OPT-OUT” of receiving communications from Us?
Information submission by minors
We do not knowingly collect Personal Data from individuals under the age of 18 without parental consent and the App is not directed to individuals under the age of 13. We request that these individuals not provide Personal Data to Us. If we learn that Personal Data from users less than 18 years of age, without parental consent, has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you are aware of a user under the age of 13 using the App, please contact us at firstname.lastname@example.org.
If you are a resident of California under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our websites.
California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their Personal Data for direct marketing purposes during the preceding calendar year and the categories of Personal Data shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email at email@example.com with “California Privacy Rights” in the subject line.
Videra Health, Inc.
898 N 1200 W, Ste. 201
Orem, UT 84057
Please note that email communications are not always secure; so please do not include sensitive information in your emails to us.