Privacy Policy

Last Updated: April 18, 2024

This policy (the “Privacy Policy”)  provides information on how Vida Health collects, uses, discloses, and protects your information. This Privacy Policy is incorporated into Our Terms of Use and tells you what information we collect from visitors and Authorized Users of the Services, how we use that information, how we may disclose that information, how we protect your information, and your choices regarding your information. Capitalized terms in this Privacy Policy may be defined in the Terms of Use.

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 TO THE PRIVACY POLICY, INCLUDING ANY CHANGES THERETO, THEN YOU MUST NOT ACCESS AND USE THE SERVICES.

This Privacy Policy contains the following sections:

• Health Information
• Information We Collect From You
• What We Do With Your Information
• How We Disclose Information to Third Parties
• Online Analytics and Advertising
• Your Data Rights and Choices
• Notice to California Residents
• Information Security
• Data Retention
• International Transfers
• Children’s Privacy
• Third Party Websites
• Changes
• Contact Us

Health Information

When Vida Health collects, receives, or maintains protected health information about you in its capacity as a covered entity under Health Insurance Portability and Accountability Act of 1996, and regulations issued thereunder, as may be amended from time to time (commonly referred to as “HIPAA”), we follow Vida Health’s Notice of Privacy Practices (“NOPP”), which is incorporated herein. To the extent the terms in this Privacy Policy conflict with or are inconsistent with the NOPP, the NOPP shall control.

Information We Collect From You

When you register with the Services, we collect information about you, including your name, address, telephone number, contact information and password. Once you have registered, we may collect the following information about you, including:

• Your birthdate and certain health information, e.g., your health insurance information, any diagnoses and how long you have been having symptoms.
• Professional information, including your company and job title.
• A profile image, should you provide one.
• Information you provide to us, or grant us access to, when you access or use the Services.
• Information you provide in public forums through the Services, including using our review, comment, post or similar functionality.
• In the event you pay for the Services directly, payment information is provided directly to our payment processing partner.

We will process information collected through the Services in accordance with applicable law and with the agreements we have with your health care provider, health plan, pharmacy benefit manager or employer, and as described in the Terms of Service and this Privacy Policy. If you do not want to provide us this information, please do not utilize the Services.

Information We Collect Automatically

We may collect certain information through automated means when you use the Services, including the following:

• Device and Usage Information, which may include the type of device you are using, your operating system, your browser type, your browser language, your internet service provider, your domain name, your internet protocol (IP) address, your device and mobile ad identifiers, the website that referred you to our website, the web pages you view (including the date and time you viewed them), the services or functionality you access or use (including the date and time of your access or use), and the subject of the ads you click or scroll over.
• Location Information, which may include general information about the location of your device based on your IP address.
• Cookies and Similar Technologies. We and our service providers may use “cookies” and other technologies to collect data that enable us to better understand and improve the usability, performance and effectiveness of our Services. For instance, we may use session cookies (which expire once you close your browser) or persistent cookies (which stay on your mobile device until you delete them) to provide you with a more personal and interactive experience on our Services.
• Third-Party Analytics and Advertising. We use third parties’ analytic and tracking tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content, and to help those parties serve more targeted advertising to you across the Internet or help us serve more targeted advertising to you. Those third-party companies may use cookies, pixel tags or other technologies to collect and store information such as time of visit, pages visited, time spent using the Services, device identifiers, type of operating system used and other website(s) you may have visited. Please note that these parties do not collect data revealing any information about your health or that can be used to infer health information about you when engaging in these activities. They might combine information they collect from your interaction with the Services with information they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies. For more information about how to opt out of these third parties’ use of your information, please see “Online Analytics and Advertising” below.
• AI Technology. As described further in the Terms of Use, we may incorporate AI Technology into our Services. In our commitment to delivering personalized and intelligent interactions, we utilize a Large Language Model (LLM) through our managed service provider to support the Vida AI Assistant feature. This feature processes user data to provide tailored responses and assistance within the Service. Please be aware that when you interact with the Vida AI Assistant, your data is handled securely according to our data governance standards. The AI technology, as part of the suite of managed services from our provider, is designed to maintain confidentiality and integrity of your information. Responses generated by the AI are specifically based on the information provided during your use of the service. For the purpose of continuous service improvement and to enable you to revisit past interactions, Vida Health may retain records of your dialogues with the Vida AI Assistant.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Microsoft Edge, Google Chrome, Mozilla Firefox, or Apple Safari). By blocking any or all cookies, you may not have access to certain features or offerings of the Services.

Information We Collect From Third Parties

You or your health care provider, health plan, pharmacy benefit manager or employer group plan will provide us with information so that we can provide our Services to you. In some cases, we may receive information from one of these third parties in a capacity of a business associate under HIPAA; in that situation, we follow the terms of the third-party covered entity’s notice of privacy practices if they conflict or are inconsistent with the terms herein.

When you interact with our social media pages, such as by “liking” our page or posting comments or replies to our content, we may collect certain information about you, consistent with your privacy settings on that platform. We also may collect publicly available data, such as from social media sites. If you do not wish for us to collect information from these third parties, please do not interact with us via third-party platforms. We may also collect information about you that you have posted publicly, such as on business networking websites. For a description on how these third parties handle and disclose your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. We may combine information that we collect from or about you with information about you that we obtain from such social media and other content platforms.

What We Do With Your Information.

We may use your information:

• To provide, operate, administer, and troubleshoot the Services to you, including to create your account, match you with a provider, and facilitate the delivery of our Services.
• To process a payment for a service or product that you purchased.
• To identify representatives and providers in your area.
• To respond to your inquiries, including through third-party platforms.
• To provide information on products and services you request or have a representative contact you regarding our products or services.
• To review customer feedback that you requested or asked us to review.
• To analyze usage patterns and performance of our Services and to improve our Services.
• To market our products and services to you, including, but not limited to, contacting you about new product lines, product updates, details of current and future projects, and quality and technical issues.
• To administer surveys and special promotions.
• In accordance with applicable legal requirements, to allow us and our advertising partners to personalize your experience when using the Services and on third-party platforms, including through targeted offers and ads on our websites, third-party sites, and via email or text message
• To conduct internal research, reporting, and data analytics.
• To enable third parties or agents to help Vida maintain the Services, analyze how users use the Services, or provide other administrative services to Vida.
• To comply with applicable laws and regulations.
• To protect or defend Vida’s legal rights or property.
• To enforce the legal or contractual terms that govern your use of the Services and our products and services.
• For other disclosed purposes to which you consent.
• As required or permitted by law.

We may also combine information that we collect from you with information we obtain about you from third parties. We may aggregate and/or de-identify any information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes and to improve users’ experience on the Services, and may also disclose such data to any third parties.

How We Disclose Information to Third Parties.

If you invite family, friends or other third parties to be part of your team or join your chat sessions with your health coach, they will have access to the information disclosed during that session. You should also be aware that certain features within the Services allow for group chat sessions or public forums. By inviting any third parties to join your chat sessions or participate in group session or public forums, you consent to the disclosure of your information, including information about your health and any health conditions to the other participants. We cannot control whether or how these participants will use your information or if they will subsequently disclose it. If you do not consent to the disclosure of this information to these third parties, you should not invite them to join your team or participate in the group sessions or other public forums.

From time to time, we may use third parties to provide products, services or otherwise support our business or collaborate with third parties with respect to development, promotion or other business activities related to a particular product or service. These third parties may include service providers of a sponsoring employer or employer-provided health plan. As a result, we may disclose information that we collect or you provide to contractors, Business Associates (as defined under HIPAA), service providers and other third parties for the purposes of providing the services as outlined above in “What We Do With Your Information,” provided such third parties have agreed to comply with this Privacy Policy or substantially equivalent terms. We may also we disclose your information to our subsidiaries and affiliates; to a third party in connection with a merger, divestiture, restructuring, reorganization, dissolution, sale or transfer of some or all of our assets or other similar corporate transactions or in connection with a bankruptcy, liquidation or similar proceeding.

We may also release your information to third parties as required by law, when we have a good faith belief that disclosure is necessary to comply with a legal or regulatory requirements, judicial proceeding, court order or legal process served on us, to protect the safety, rights or property of patients, customers, the public or the Company or defend the Company and its officers, directors, employees, attorneys, agents, contractors and partners, in connection with any legal action, claim, or dispute.

Please note that if your access to the Services is sponsored by your employer and/or provided for under your health plan, at the request of your employer group plan or health plan, we may disclose information that you provide to us, or that we otherwise collect, through the Services with your employer group plan, health plan and/or third party service providers of your employer group plan or health plan. Any such information will be provided in accordance with applicable laws, including without limitation HIPAA.

If you consent, we may disclose your information publicly or to third parties, such as if you agree to provide a product or service review and have that content attributed to you.

Online Analytics and Advertising

Online Analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics. These vendors use the sort of technology previously described in the “Information We Collect From You” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Tailored Online Advertising

Our third party advertising partners may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads as you browse the web based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs. You may also opt out of these activities using the opt out mechanisms described in the “Your Data Rights and Choices” section below.

Please note that you may still receive advertisements even if you opt out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Your Data Rights and Choices

Marketing Communications

In accordance with applicable law, Vida may send you marketing and promotional emails. If you would like to opt out of email marketing, notify us at support@vida.com or follow the unsubscribe instructions in the email. Please note that even though you may opt-out of receiving marketing-related communications from us, we may still send you important administrative and transactional messages (e.g., notifications regarding updates to our legal terms).

Rights Regarding Your Information

Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about the financial incentives that we offer to you, if any.
• Restrict or object to certain uses of your information.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, location at time of consult and email address. If we are unable to verify your identity, we may be unable to respond to your requests. To exercise any of these rights, you can email us at support@vida.com or directly mail us at Vida Health, 20500 Belshaw Ave, DPT# EXCA1377, Carson, CA 90746-3506 with your name and type of request you are making. We will not discriminate against you for exercising these rights.
You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes

Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”
As explained in the “Online Analytics and Advertising” section above, we provide information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.

If you would like to opt out of the disclosure of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” or processing for purposes of targeted advertising, please visit the link available in the footer of our Services: “Your Privacy Choices.” Note that you will need to opt out on each device you use to access the Services.

Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Notice to California Residents

If you are a California resident, the California Consumer Privacy Act, as amended (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information.

Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Our use of third-party analytics services and online advertising services may result in the sharing of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” under the CCPA. The following chart details our practices in this regard.

For more information about each category, purpose of use, and the third parties to which we disclose or share information, please see the “Information We Collect From You,” “What We Do With Your Information,” and “How We Disclose Information to Third Parties” sections of this Privacy Policy.

Your Choices Regarding “Sharing” and “Selling”

You have the right to opt out of our sale/sharing of your personal information for purposes of certain online analytics and advertising by visiting the link available in the footer of our Services: “Your Privacy Choices.” If you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

Additional Privacy Rights

In addition to the rights set forth in the section above on “Your Choices Regarding ‘Sharing’ and ‘Selling,’” California residents may make certain requests about their personal information under the CCPA as set forth in the section above on “Rights Regarding Your Information.”

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note, in the circumstances that we process sensitive personal information (such as health-related information to provide the Services to you), we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

Shine the Light

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Except as otherwise described herein with respect to legally required browser based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. To learn more about Do Not Track, you can do so here. Please note that Do Not Track is a different mechanism that the legally-recognized browser-based opt out preference signal mentioned above.

Information Security. We seek to safeguard your information and have implemented appropriate security measures consistent with accepted practices in the healthcare industry to protect the confidentiality of your information and limit access to it.
However, despite our efforts to protect your information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet will be intercepted. Unfortunately, we cannot guarantee the absolute security of your information, nor can we guarantee that information that you provide will not be intercepted while being transmitted to us over the Internet. Therefore, we urge you to also take every precaution to protect your information when you are on the Internet or using the Services.

Data Retention. We will retain your information in for as long as needed for the purposes described in this Privacy Policy. There may be laws that require us to keep your information for specific time periods. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

International Transfers. Personal Information collected from you may be stored and processed in the United States or any other country in which Vida Health or its affiliates, subsidiaries, agents or contractors maintain facilities. The data protection laws and regulations applicable to your information transferred to the United States or these other countries may be different from the laws in your country of residence. We take appropriate steps to protect, process, and transfer your information only in accordance with this Privacy Policy and applicable law, which may include using standard contractual clauses or other transfer mechanisms.

Children’s Privacy. We are committed to protecting the privacy of children. This Services is not designed or intended for children and we do not intentionally collect information about children under 18 years old. If a parent or guardian becomes aware that a child under 18 years old has provided information to us without their consent, please contact us at support@vida.com.

Third Party Websites. Please be aware that our website or Services may have links to third-party websites that may collect information about you. When you click on one of these third-party links, you are entering another website for which we have no responsibility. This Privacy Policy does not cover the information practices or policies of such third-party websites. We encourage you to read the privacy policies of all such websites since their privacy policies may be materially different than our Privacy Policy.

Changes. We may modify the terms of this Privacy Policy. When the Privacy Policy is changed, modified, and/or amended, the revised Privacy Policy will reflect the updated effective date. If we make a material change to the Privacy Policy, we will provide you with appropriate notice in accordance with legal requirements.

You should visit this web page periodically to review the Privacy Policy. By continuing to access and use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

Contact Us. If you have any questions or concerns about your privacy, you may contact us at privacy@vida.com.