Vanna Health Privacy Policy

Your privacy is an important priority to Vanna Health, and We take great care to protect Your information.

The purpose of this Privacy Policy is to describe Our collection, use, and disclosure of Your information when You use the Platform and tells You about Your privacy rights and how the law protects You. This Privacy Policy also applies when We communicate with You by email, text message, and other electronic messages.

Please take a moment to review this Privacy Policy. By using the Platform, You agree to the terms of this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined below. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Platform or parts of our Platform.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.
Application means the software program provided by Vanna Health downloaded or accessed via the internet by You on any electronic device.
Company (referred to as either "the Company", "We","Us" or "Our" in this Privacy Policy) refers to Vanna Health, 706 Mission Street #1402, San Francisco, CA 94103.
Device means any device that can access the Platform such as a computer, a smartphone, or other digital device.
Personal Data is any information that relates to an identified or identifiable individual.
Platform refers to the Application or the Website or both.
Usage Data refers to data collected automatically, either generated by the use of the Platform or from the Platform infrastructure itself (for example, the duration of a page visit).
Website refers to Vanna Health’s websites including http://www.vannahealth.com.
You means the individual accessing or using the Platform or legal entity on behalf of which such individual is accessing or using the Platform, as applicable.

Collecting, Using, and Sharing Your Personal Data

Types of Data Collected

Health Information

Vanna Health provides its members with the ability to obtain health care services provided by independent medical practitioners including, but not limited to, Emilio Medical Group (“Medical Group”), an independent medical group with a network of United States based health care providers (each, a “Provider”). Accordingly, some Personal Data we collect may constitute Protected Health Information ("PHI") and/or medical information and is governed by applicable state and federal laws that apply to that information, for example the Health Insurance Portability and Accountability Act (“HIPAA”). The Medical Group’s Notice of Privacy Practices describes the collection and use of Your PHI. We will only collect and use PHI to support the Medical Group for purposes described in the Notice of Privacy Practices. We may combine Your PHI with Personal Data that we have either obtained from You or through a third-party, such as Your Provider, health insurer, or other health care providers. PHI will not be used for any other purpose without Your consent or as otherwise permitted by law.

Personal Data

While using Our Platform, We may ask You to provide Us with certain personally identifiable information that can be used to identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code,City
Social Determinants of Health
Birth date
Gender and age
Race, ethnicity
Usage Data

We collect most of this Personal Data directly from You. For example, We will collect information from You when You visit our Website or Application and fill out forms or use Our services.

Usage Data

Usage Data is collected automatically when You navigate through our Platform.

Usage Data may include information such as Your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Platform that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Platform by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Platform or when You access the Platform by or through a mobile device.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on Our Platform and store certain information. Tracking technologies used are beacons, tags, scripts, and server logs to collect and track information and to improve and analyze Our Platform and services. The technologies We use may include:

Cookies or Browser Cookies. We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever You interact with our Platform or services through Your Device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of Your Device. You can instruct Your browser to refuse all cookies or to indicate when a cookie is being sent. However, if You do not accept cookies, You may not be able to use some parts of our Platform. Unless You have adjusted Your browser setting so that it will refuse cookies, our Platform may use cookies.
Flash Cookies. Certain features of our Platform may use locally stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Platform. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available here.

Web Beacons. Certain sections of our Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or"Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device unless deleted by You or by Your browser settings, while Session Cookies are deleted as soon as You close Your web browser.

Use of Your Personal Data

The Company may use Your Personal Data for the following purposes:

To operate, administer, provide, maintain, and enhance our Platform and services, including to monitor and analyze the usage of our Platform and services, aggregate site usage data and other usage of the Platform or services, determine the effectiveness of Our promotional campaigns and to evaluate and improve our Platform, products, services, marketing and Your experience, and to provide our services to You, in a custom and user-friendly way.
To manage Your Account: to manage Your registration as a user of the Platform. The Personal Data You provide can give You access to different functionalities of the Platform that are available to You as a registered user.
For the performance of a contract: to carry out our obligations and enforce our rights arising from any contracts entered into between You and Us.
To authenticate use, detect fraudulent use, and otherwise maintain the security of OurPlatform and the safety of others.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication related to products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about the Platform, services, other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
To notify You about changes to our Platform or the services or any products we offer or provide through them.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held byUs is among the assets transferred.
To respond to law enforcement requests, court orders, and subpoenas and to carry out Our legal and contractual obligations.
Anonymize and aggregate information for analytics and reporting.
Fulfill any other purpose for which You provide it.
Any other purpose with Your consent.

Sharing of Your Personal Data

We may share Your Personal Data with third parties in the following situations:

Our business purposes: We may share Your Personal Data with our affiliates, vendors, service providers, and business partners, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security advisors. We may also share Your Personal Data with professional advisors, such as auditors, law firms, and accounting firms.
For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all the Company assets, financing, or acquisition of all or a portion of Our business to another company whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us is among the assets transferred.
With other users: When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
Compliance with law: We may share Your Personal Data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
To enforce our rights: We may share Your Personal Data to enforce any applicable terms and conditions, and to ensure the safety and security of our services and our users.
De-identified information: We may also disclose de-identified information, so that it cannot be reasonably used to identify any individual, for any purpose permitted bylaw.
To market our products and services: We may share Your Personal Data with affiliates and third parties to market our products and services.
With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

We offer You choices on how You can opt out of our use of tracking technology, and disclosure of Your Personal Data for our advertising to You. We do not control the collection and use of Your information collected by third parties. These third parties may aggregate the information they collect with information from their other customers for their own purposes. You can opt out of third parties collecting Your Personal Data for targeted advertising purposes in the United States by visiting the National Advertising Initiative's (NAI) opt-out page and the Digital Advertising Alliance's (DAA) opt-out page.

Each type of web browser provides ways torestrict and delete cookies. Browser manufacturers provide resources to helpYou with managing cookies. Please see below for more information.

For other browsers, please consult the documentation that Your browser manufacturer provides.

If You do not wish to have Your email address used by Vanna Health to promote our own products and services, You can opt out at any time by clicking the unsubscribe link at the bottom of any e-mail or other marketing communications You receive from us. This opt out does not apply to information provided to Vanna Health as a result of a product purchase, or Your use of our Platform and/or the services. You may have other options with respect to marketing and communication preferences through our Platform.

‍Does Vanna Health Respond to Do Not Track Signals?

Some web browsers have a“Do Not Track” feature. This feature lets You tell websites You visit that You do not want to have Your online activity tracked. These features are not yet uniform across browsers. Our Platform is not currently set up to respond to those signals.

How do I Correct My Personal Data?

You may contact Us to inform Us of any changes or errors in any Personal Data We have about You to ensure that it is complete, accurate, and as current as possible or to deleteYour account. We cannot delete Your Personal Data except by also deleting Your account with us. We may also not be able to accommodate Your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

Who May Use the Platform?

This Privacy Policy applies to all personal uses of our Platform and You should not use the Platform and/or the services if You do not agree to the Privacy Policy. You represent that You are not a person barred from enrolling for or receiving the services under the laws of the United States or other applicable jurisdictions in which You may be located. Access to and use of the Platform and/or the services is limited exclusively to users located in states within the United States where the Platform and/or the services is available. The Platform and/or the services are unavailable to users outside the United States. Accessing the Platform and/or obtaining the services from jurisdictions where content is illegal, or where we do not offer the Platform and/or the services, is prohibited.

Children’s Privacy

Vanna Health understands the importance of protecting children’s privacy in the interactive online world. Our Platform is not designed for, or intentionally targeted at, children under 18 years of age. We do not knowingly collect or sell Personal Data from children under the age of 18. If You are under the age of 18, do not use or provide any information on or to the Platform or through any of its features. If we learn we have collected or received Personal Data from a child under the age of 18 without verification of parental consent, we will delete it. If You are the parent or guardian of a child under 18 years of age whom You believe might have provided us with their Personal Data, You may contact Us to request the Personal Data be deleted.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retainYour data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Platform, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers outside your state, province, country, or other governmental jurisdiction where the data protection laws may differ from yours.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls designed to protect the security of Your Personal Data.

Security of Your Personal Data

We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. The Internet is not 100% secure and we cannot guarantee the security of information transmitted through theInternet. Where You have been given or You have chosen a password, it is Your responsibility to keep this password confidential.

The sharing and disclosing of information via the Internet is not completely secure. We strive to use best practices and industry-standard security measures and tools to protect Your data. However, we cannot guarantee the security of Personal Data transmitted to, on, or through our services. Any transmission of Personal Data is at Your own risk. We are not responsible for circumventing any privacy settings or security measures on our Platform, in Your operating system, or mobile device.

Links to Other Websites

This Privacy Policy does not apply to information collected by any other website operated either by

Us or by a third party unless the website is listed above or links to this Privacy Policy. This Privacy Policy also does not apply to any website that we may provide a link to or that is accessible from our Platform.

Our Platform may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

California’s Shine the Light Law

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Platform and/or the services that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes.

Vanna Health does not share Personal Data to third parties for their own direct marketing purposes.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Platform, prior to the change becoming effective, and update the "Last updated" date at the top of this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for You.

You are advised to review this Privacy Policy periodically for any changes. Changes to this PrivacyPolicy are effective when they are posted on this page.

Contact Us

If You have any questions, concerns,complaints, or suggestions about this Privacy Policy or otherwise need tocontact us, You can contact us:

By phone number: +1 (415) 340-0090
By Email: privacy@vanna.health
By mail: Vanna Health, 706 Mission Street #1402, San Francisco, CA 94103