Privacy Policy

This Privacy Policy explains how Vitalacy Inc. and its subsidiaries (“Vitalacy”, “we”, “us”, “our”) collect, use, and share information and the options available to you. If you have any questions, you may contact us. See the “Contacting Us” section below. We may change this Privacy Policy from time to time. Please consult this Privacy Policy regularly for updates. See “Changes to this Privacy Policy” below for more information. You acknowledge that you accept the practices described in this Privacy Policy by visiting and/or using our Services.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers the information that we may collect or receive through all digital formats, including the Internet and mobile, from users and users of our clients who: visit www.vitalacy.com and other websites owned and operated by us (including our client and user interfaces), use our software applications, use our social media pages such as LinkedIn, Twitter, and Facebook, or receive email messages from us or send email messages to us (collectively, the “Services”). Our platform allows our clients to collect data through our devices to analyze caregiver workflow. 

This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), such as our service providers. Our clients use our technology to track patient-caregiver interaction in their facilities through which they collect information from their staff and use the data in accordance with their terms.

Choice and Opting Out: see “Choices” below for information about your choices regarding opting out of email marketing communications, opting out of Vitalacy’s cookies, opting out of interest-based advertising from third party cookies, and opting out of use of precise location.

Access and Rights: see “Access and Rights regarding Personal Information” below for information about how to be informed, the right to data portability, the right to object, your rights in relation to automated decision making and profiling, and the right to access, rectification, erasure, and restrict the processing of, the personal information that Vitalacy maintains about you.

COLLECTION OF INFORMATION

We and our third party service providers may collect the following personal information from you from the Services:

  • Name

  • Email address

  • Phone number

  • Vialacy user name

  • Job title

 

For example, we collect your personal information when you request information about the Services, you sign up to use the Services through our client log in and user interfaces, or you request access to our resources. The decision to provide this information is optional, however, if you elect not to provide such information, you will not be able to access the information you had requested to access or use.

We and our third party service providers may also collect other information that is linked or reasonably linked to a particular computer or device. This information includes the following:

  • Browser information, including browser type

  • Device information, including screen dimensions, device brand and model

  • Operating system of mobile device

  • Language

  • Time spent on the Services and your activities on the Services, including date and time, clickstream data, the web page from which you came, and the web page(s) that you accessed during your visit

  • Your location data as derived from IP address

  • Unique identification numbers, including IP address and mobile device identifier

  • Data as provided by the client

  • Information provided by you

  • Aggregated information

 

We and our third-party service providers may collect this information in a variety of ways, including through: your browser or device; your mobile device identifier; your use of our applications; the use of pixel tags and other similar technologies; your IP address; the aggregation of information; and cookies (see Cookies and Similar Technologies below).

Our clients may also collect information about their staff members that they choose to pass to us either directly or through our Services. The information such clients may share includes demographic information such as age and gender and behavioral information.

 

Collection of Job Applicant Data

We may collect the following information from you in connection with your job application:

  • Name, address, telephone number, e-mail address, and other contact information

  • Username and password

  • Work authorization status

  • CV, résumé, cover letter, previous work experience and education information

  • Skills

  • Professional and other work-related licenses, permits and certifications held

  • Information relating to references

  • Background information through background checks

  • Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships)

 

We ask that you avoid submitting the following sensitive information, except where such information is legally required: race, color, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, genetic information, or trade union membership information.

To the extent the personal information you provide contains details of your: racial or ethnic origin; political opinions or beliefs; religious beliefs; membership in a trade union or political party; physical or mental health or condition; sexual orientation; commission (or alleged commission) of an offense or related proceedings; job evaluations or educational records, you expressly authorize Vitalacy to handle such details for the purposes of your job application.

Any information you submit through the career pages of the Services (including any pages hosted by a third party service provider) must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.

If you provide us with personal information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

We may also obtain information about you from your references or from a background check report in connection with your application, as permitted by applicable law.

USE OF INFORMATION

We and our third-party service providers may use personal information (such as name, phone number and email address) collected from the Services:

  • To respond to your inquiries and fulfill your requests

  • To send administrative information to you

  • To communicate with your concerning your account and customer service issues

  • To provide access to and use of the Services

  • To manage users’ accounts

  • To send you communications that we believe may be of interest to you, including any communications for marketing purposes related to the Services

  • To enhance users’ experience using our Services

  • To personalize and customize the Services,
    for our business purposes, such as data analysis, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our campaigns, and technical functioning purposes

  • With respect to job applicants: to process your employment application; to assess your capabilities and qualifications for a job; to conduct reference checks; to respond to your inquiries and communicate with you about your application, and to send you information regarding the career pages and changes to our terms and policies; to comply with or monitor compliance with any applicable law or regulation; and to conduct background checks if we offer you a position, as permitted by applicable law

  • As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things).

 

We and our third-party service providers may use other information from the Services that is linked or reasonably linked to a particular computer or device:

  • To operate, improve, analyze and manage the Services, including improve the user experience

  • To ensure the Services function properly

  • To track your use of the Services to improve the design, functionality and effectiveness of the Services

  • To measure and report on the success of advertising and marketing campaigns and content

  • To understand users’ navigation behavior

  • To understand opportunities to develop new product

  • To diagnose server problems, administer the Services via your IP Address (a number automatically assigned to the computer or device that you are using by your internet service provider) and ensure the technical functioning of the Services, an

  • To provide you with personalized location-based services and content through the use of your device’s physical location (where permitted by law)

  • As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things)

 

We may partner with certain third parties to collect other information about you to engage in analysis, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other devices and may also use web logs or web beacons. See “Cookies and Similar Technologies.”

In some instances, we may combine information from the Services that is linked or reasonably linked to a particular computer or device with personal information. If we combine such information with personal information, the combined information will be treated by us as personal information as long as it is combined.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies in connection with our Services. A cookie is a small data file that we store on your computer’s or mobile device’s memory. Some cookies help you navigate our Services, including setting a cookie to remember your login details and to validate your identity. Other cookies collect information about how you use our Services and analyze trends, which highlights areas we can improve, how we can otherwise improve the quality of our Services and how to tailor our Services to meet our users’ personal interests. We may receive reports based on the use of these cookies on an individual as well as aggregated basis.

If you submit name and email and similar personal information to us via the Services, that personal information will not be stored in cookies or tied back to you for interest-based advertising purposes across websites and applications. However, you may receive email marketing communications from us and you may receive targeted advertising from third parties based on the information stored in a third party’s cookie. To opt out of marketing communications and to opt out of interest-based advertising from third party cookies, see “Choices.”

We may also use “pixel tags,” “web beacons”, “clear GIFs” or similar means (individually or collectively “Pixel Tags”) to analyze usage patterns of consumers. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a webpage or in a mobile application and may be associated with cookies on your hard drive. Some Pixel Tags are used to drop cookies on users’ devices. Pixel Tags allow us to count users who have visited our Services, and pages within our Services, and to help determine the effectiveness of promotional or advertising campaigns.

Third parties may also use cookies or similar technologies on visitors of our websites to serve interest-based advertisements to such visitors when they visit other websites and mobile applications, including advertisements promoting our Services. The collection of information through cookies or similar technologies by such third parties will be governed by such third parties’ own privacy policies and principles, which we do not control.

Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. However, please note that certain features of the Vitalacy platform may not work if you delete or disable cookies.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

To read about your choices with regard to Vitalacy’s and third parties’ uses of cookies in our services, please see “Choices.”

We do not currently track users when they cross to third party websites, and therefore we do not respond to Do Not Track (DNT) signals.

INFORMATION SHARING

Your personal information (such as name, phone number and email address) collected from the Services may be shared:

  • Among our affiliates for the purposes described in this Privacy Policy (Vitalacy Inc. is the party responsible for the management of the information jointly used by it and its affiliates)

  • With the particular client on whose behalf we have collected your personal information through our Services

  • With our third-party service providers who provide services such as email management and marketing analytics

  • With our third-party service providers who provide services relating to our career pages, recruiting, background check processing and similar services

  • Directly by you on profile pages and blogs and other services to which you are able to post information and materials yourself (including, without limitation, our social media pages)

  • With a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)

  • As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things)

We and our third party service providers may share other information from the Services that is linked or reasonably linked to a particular computer or device:

  • Among our affiliates for the purposes described in this Privacy Policy (Vitalacy Inc. is the party responsible for the management of the information jointly used by it and its affiliates)

  • With our clients to allow them to analyze the effectiveness and performance of our Services

  • With our third-party service providers who provide services that enhance our Services, including cloud storage vendors, marketing, analytics and other services

  • With a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)

  • As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things).

We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above in this section “Information Sharing.”

We ask our service providers to confirm that their privacy and security practices are consistent with ours and maintain the confidentiality of personal information received from us, we provide our service providers with only the personal information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by Vitalacy.

There may be areas of the Services in which you are able to post information that will be available to all other users of the Services. By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any information that you post to those areas and as such, immediately upon posting, the materials or information you post shall be considered public information.

If you identify any of your information as public within your account settings, you are authorizing us to share such information publicly in any manner we elect at any time.

ACCESS AND RIGHTS REGARDING PERSONAL INFORMATION

For registered users, if you would like to modify or delete any personal information stored in your profile that we maintain in our database, or if you would like to delete your profile completely, you can do so by contacting account manager or emailing us at security@vitalacy.com. We will use all reasonable efforts to implement these changes within ten (10) calendar days. Please note that any personal information that we have copied in connection with providing our Services may remain in secure back-up storage for some period of time after your request. Note that we are unable to recover any personal information from any Vitalacy business client once it has been transferred to such business client. You may contact that business client directly to access information about your personal information that is in their possession.

  • To opt out of receiving marketing communications from us, please see “Choices.”

  • To opt out of Vitalacy’s cookies, please see “Choices.”

  • To opt out of interest-based advertising from third party cookies, please see “Choices.”

  • To opt out of the use of precise location, please see “Choices.”

RETENTION

We will retain your personal information for the period necessary to fulfill the purposes outlined in our Data Security Policy unless a longer retention period is required or permitted by law, or an individual requests deletion in accordance with applicable law. See “Access and Rights regarding Personal Information.”

CHOICES

Opting Out of Marketing

We give you choices regarding our use and disclosure of your personal information for marketing purposes.

You may opt-out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at security@vitalacy.com or by clicking on the opt-out link within the email message that you receive from us.

Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.

Opting Out of Vitalacy’s Cookies

You may disable cookies, including Vitalacy cookies, by modifying the settings in your browser. However, please note that certain features of the Services may not work if you delete or disable cookies.

Opting Out of Interest-Based Advertising from Third Parties’ Cookies
Some third parties who use cookies when you visit our websites, also have opt-out mechanisms either directly from their website or through an industry-developed web page. When you opt out of receiving interest-based advertising, note that the opt-out only applies to the applicable browser in which you set it. Note also that most opt-out tools are cookie-based. This means that, if you have cookies blocked, you will not be able to use it. Note also that if you delete cookies entirely then you will need to opt out again. Finally, note that once the opt-out has been completed, you will still receive advertisements, but such advertisements will not be interest-based ads.

If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes.

For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

Opting Out of Use of Precise Location

To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.

Android

For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you may uninstall the relevant program(s).

iOS

In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.

 

THIRD PARTIES

This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), including any third parties operating any site or service to which our Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. These third parties are bound by their own privacy policies.

We are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of our clients (including our clients who create their own online research communities through our Services), app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers (except as required by applicable law), including any Personal Information you disclose to other organizations through or in connection with the Services. These third parties are bound by their own privacy policies.

SENSITIVE INFORMATION

If we ask you to provide sensitive personal information (i.e. information specifying medical or health conditions, personal financial information, social security number, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information regarding your sex life, among similar such information), we will require that you first affirmatively agree (i.e., opt-in) to provide such information before we collect it from you. The information we request is not designed for any discriminatory purpose and you are not required to provide any such sensitive information if you do not wish to do so, although your use of our Services may be affected thereby.

SECURITY

Vitalacy maintains a strong commitment to secure software development practices. We practice regular code scans, penetration tests, and are SOC II, Type 2 certified. Our security procedures and practices are reasonably designed to help protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed by us.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to make changes to our Privacy Policy. Please look at the date at the top of this page to see when this Privacy Policy was last revised. Where required by law, we will obtain your consent to make these changes.

CONTACTING US

For any questions about this Privacy Policy or Vitalacy’s privacy practices, please contact us by email at security@vitalacy.com or by mail at:

Vitalacy Inc.,
11859 Wilshire Blvd., Suite 500
Los Angeles, CA 90025

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