Effective: 20 October 2016
As used in this policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within India or internationally.
As used below, the term "Personal Information" is used to indicate any piece of information or data that can be used to identify any individual. Personal Information may relate to you as a Member, or it may relate to the individual that is the subject of any Profile that you create, if you create a Profile for a child, parent or other loved one.
THE INFORMATION WE COLLECT
Personal Information and Sensitive Personal data or Information
- You may browse the Site and download the VYTAL App without expressly providing us any Personal Information that expressly identifies you. However, in order to make full use of the VYTAL Services as made available via the Site and/or the VYTAL App, you will be required to register with us. When you register with us to create an account and become a member, we will ask you for certain Personal Information. In order to set up your account, you need to provide your email address and you will need to select a password. If you elect to add any other Personal Information to your Account we will collect that information and use it and share it as set forth below.
- As a Member, you may also set up one or more Profiles within the VYTAL Services. The Profile may be personal to you and your healthcare or the subject of the Profile may be a child, parent or other loved one. When you set up a Profile, you will be asked to provide Personal Information about the individual that is the subject of the Profile, whether yourself or your child, parent or other loved one. When you set up a Profile in the VYTAL Services, we will collect and store any Personal Information that you may elect to provide to us as part of the Profile Content, which may include but is not limited to medication information, gender, date of birth, personal contacts, photographs and files, notes on your symptoms and other journal information, medical treatment instructions, medical appointments, insurance information, your doctor's address information, advance directives, and prescription refill information. In the event you set up a Profile that relates to someone other than yourself, you are solely responsible for ensure that you have any and all consents and permissions to share that Personal Information with us and to use that information as part of the VYTAL Services.
- You may provide us with Personal Information of a third party Caregiver, as contemplated by the VYTAL Terms of Service, to access a Profile that you create. If you elect to invite any third party to access a Profile connected to your Account, we will ask you for such third party's name and email address. We will send the third party emails inviting him or her to register for the VYTAL Services. We store this information for the sole purpose of sending this one-time email. The third party may contact us at firstname.lastname@example.org request that we remove this information from our database. We cannot control whether such third party will elect to register for VYTAL.
- You give an express consent to VYTAL to usecollection, transfer, processing, storage, disclosure your Sensitive Personal data or information including the following passwords, financial information, physical, physiological and mental health condition, sexual orientation, medical records and history, biometric information.
We also collect the following information any time you visit our Site or the VYTAL App, as applicable. This information may not necessarily identify you, but if we have your Personal Information, or you otherwise set up an Account with us, we may link any of the below non-personal information with your Personal Information in our records.
- Browser Log Data. When you visit the Site, whether as a Member or a non-registered user just browsing the Site, our servers automatically record information that your browser sends whenever you visit a website ("Browser Log Data"). This Browser Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, operating system or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and for the Site's technical administration, to increase our Site's functionality and user-friendliness, and to better tailor it to our visitors' needs. For example, we use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Browser Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
- App Usage Data. When you use the VYTAL App, whether as a Member or a non-registered user, our servers automatically record information that your mobile device sends whenever you use an Internet service ("App Usage Data"). This App Usage Data may include information such as your computer's IP address, device model and version, device identifier, operating system, time zone, name of your mobile operator or ISP, application performance measurements, and error conditions. It may also include a record of when specific features of the VYTAL App or VYTAL Service are used. We use this information to monitor and analyze use of the VYTAL App and VYTAL Service and for their technical administration, to increase their functionality and user-friendliness, and to better tailor them to our visitors' needs. For example, we use this information to measure the popularity of different features and to more effectively resolve customer issues. Except in response to a customer support request, we do not treat App Usage Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
HOW WE USE YOUR INFORMATION
- We do not sell your Personal Information.
- We will use any Personal Information in your Account as well as any Profile Personal Information to provide the VYTAL Services, complete your transactions, administer your inquiries, and present you with offers for products and services that we think may be of use or interest to you.
- If you set up a medications list in a Profile by scanning or adding any existing prescription medications to a Profile, and you have elected to share your location with us, we can help you locate the contact information and/or address of the prescribing physician or practice, which you can then elect to add to the applicable Profile.
- If you add Personal Information about prescriptions into a Profile, we may use that information to present you with offers for pharmacy services, including without limitation our Pharmacy Assistance VYTAL Service. If you register to receive our Pharmacy Assistance VYTAL Service, we may need additional Personal Information for the applicable Profile, which you may not have elected to provide us previously, such as date of birth, insurance information, credit card information, driver's license copy, and contact information for any current pharmacy. If you elect to receive our Pharmacy Assistance VYTAL Service, we will use all Personal Information as necessary to provide you the Pharmacy Assistance Service, including sharing it with the applicable pharmacy as further set forth below.
- [For Members Who Register On Or After March 01, 2016 Only]: If you set up a medications list in a Profile by scanning or adding any existing prescription medications to a Profile, we may share your name and date of birth with your existing pharmacy for the purpose of registering a prescription discount card on your behalf. That information will be used solely so that your pharmacy can identify your account so that you are eligible to obtain cost saving benefits via a prescription discount card.
- We may aggregate and combine all Personal Information that we receive through your Member Accounts and your Profiles with the information of other Members and Profiles. We use this anonymous information to attempt to provide you with a better experience, to improve the quality and value of our services and to analyze and understand how our Site, VYTAL App and VYTAL Services are used.
INFORMATION SHARING AND DISCLOSURE
- Caregivers. In the event that a third party Caregiver registers for access to VYTAL pursuant to an invitation issued by your Account, we will provide them with access to all Profiles related to such Account. We cannot control how any Caregiver may use or disclose or otherwise exploit any Personal Information or other Profile Content that you may elect to make available to such third party. You expressly release VYTAL from any responsibility and liability resulting from any third party access to any Personal Information or Profile Content that you may permit. Any information you choose to provide and make available to third parties via VYTAL should reflect how much you want others to know about you and the individual(s) whose information is in your Profile.
- Pharmacies. If you elect to receive our Pharmacy Assistance VYTAL Service, we will share information from the applicable Profile to the pharmacy as requested by the pharmacy to perform its functions (such as the name and dose of your medication, your prescription record, the name of the prescribing doctor and the identity of your pharmacy). Your registration to receive the Pharmacy Assistance VYTAL Services constitutes your express consent for us to make such disclosures to the pharmacy as an agent on your behalf. All information we disclose to the pharmacy is Personal Information contained within the Profile Content, except for credit card information. We will need to collect your credit card information in order to provide the same to the pharmacy to process payments for any prescriptions. We do not retain your credit card data but simply pass it through to the pharmacy.
- Other Third Parties. If you elect to use or otherwise take advantage of some of the other third party services that we may provide and make available to you, we will share certain of your information with such third party and will disclose to you at the time what information would be necessary to share with such third party.
- Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose non-Personal Information with third parties for industry analysis, demographic profiling and other purposes.
- Service Providers. We will disclose Personal Information to the third party service providers that we engage to assist us in making the Site, VYTAL App and VYTAL Services available. These service providers consist of our datacenter provider, storage provider, customer support system provider, email service providers, and software development contractors. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
- Compliance with Laws and Law Enforcement. We take the protection of your private health information very seriously. In the event that we receive any subpoena or similar request from a court, government or law enforcement official, we will only disclose any Personal Information about you or other information in our custody or control as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of VYTAL or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity. Given the sensitivity of the Personal Information within your Profiles, it is our policy to carefully review any such request for information in our systems and we will decline to comply with any such request in our discretion.
- Business Transfers. VYTAL may sell, transfer or otherwise share some or all of its assets, including your Personal Information and related Account, Profiles and Profile Content, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
CHANGING OR DELETING YOUR INFORMATION
All Members may review, update, correct or delete their Account information and any associated Personal Information or Profile Content by contacting us or by accessing VYTAL. If you would like to close your Account or delete any Profile from your Account, please contact us at email@example.com. We will use commercially reasonable efforts to honor your request. We will retain an archived copy of your records as set forth below.
We will retain the information you provide via our Site or the VYTAL App for as long as your Account is active or as needed to provide you with the VYTAL Services. We will also retain and use the information you provide via our Site or VYTAL App, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you delete your Account or any Profile, any Personal Information associated with the same is moved out of our active databases, but will still be retained in our systems pursuant to our data backup and retention policies.
DO NOT TRACK SIGNALS AND AD NETWORKS
Our Site does not have the capability to respond to "Do Not Track" signals received from various web browsers. At this time, we do not participate in any third party service that tracks users across websites and over time.
SECURITY — HOW WE PROTECT YOUR DATA
All communications between you and the Site or VYTAL App is encrypted using the highest level of encryption available to us on your device. We use industry-standard AES encryption for stored data.
Identity theft is of great concern to VYTAL. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
The Site, VYTAL App and VYTAL Services rely on the Internet and mobile networks, which are not always secure. We use commercially reasonable efforts to maintain the confidentiality, availability and integrity of any information we collect, but we cannot assure that the use of the Site, VYTAL App or VYTAL Services are secure or that your Personal Information or any other data that we may have will be secure. In the event we become aware of a security incident, we will notify you to the extent required under applicable law.
REPORTING A PROBLEM
If you feel your account may have been compromised, or you discover abuse or misuse of VYTAL Services, the Site or the VYTAL App, please report it immediately by sending an email to firstname.lastname@example.org and we'll investigate.
LINKS TO OTHER WEBSITES
Our Site may contain links to other websites. If you choose to click on a third party link, you will be directed to that third party's website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
OUR POLICY TOWARD CHILDREN
If you have created a Profile for a minor under the age of 18, you represent and warrant to us at VYTAL that you are the parent or legal guardian for that minor with a right to provide us the Personal Information of that minor. The information and features provided on Site and VYTAL Apps are not directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at email@example.com. If we become aware that a child under 18 has provided us with Personal Information, without the consent of parent or legal guardian, then we will delete such information from our files.
Vytal Healthtech Pvt. Ltd 202A, Kukreja Residency, Patil Road
Chembur, Mumbai, Maharashtra