Privacy Policy

Privacy Notice

This Privacy Notice describes the information collection, use, retention and sharing practices of Vitara Health (“Vitara Health”, “we”, “us”, “our”) when you interact with us through our website, https://www.vitarahealth.com (the “Website”), or through the provision of our products and services (collectively, the “Services”).

PERSONAL INFORMATION WE COLLECT, WHY, AND FOR HOW LONG

We collect personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you, when you:

• Contact us via the Website. When you contact us through the Website, for example, to submit questions regarding our Services, we collect, from you, your personal identifiers (first and last name, email address, and telephone number). We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, provide Services, and address any issues you have with the Services.
• Create a customer account. When you create a customer account (“Account”), we collect, from you, your personal identifiers (first and last name, email address, telephone number, physical address, and date of birth). Please see the “Sign up for our newsletter” section if you choose to opt in to our mailing list.
• Make a purchase. When you make a purchase on our Website, we collect, from you or from our third party payment processor, your personal identifiers (first and last name, email address, telephone number, physical address, and date of birth (if provided) and your sensitive financial information (credit or debit card number, CVV, and expiration date)). We use this information to process your payment for the requested Services, fulfill and manage purchases, orders, payments, and returns or exchanges. If you choose to opt-in to our mailing list, we will send you company news and other related product or service information that may be of interest to you. You can opt-out of email marketing communications at any time by clicking on the “unsubscribe” link included in the email you receive from us. Please note we will continue to send you messages that are necessary to perform the Services.
• Sign up for our newsletter. When you sign up to receive our newsletter, we collect, from you, your personal identifiers (first and email address). We use this personal information to send you updates, news, and special offers as requested. You may unsubscribe at any time by clicking the “unsubscribe” link included with each email you receive from us. However, we will continue to send you service-related messages. We retain this information for the minimum period necessary, which is determined upon the existence of: (i) an ongoing business relationship we have with you; (ii) applicable legal requirements; and (iii) potential legal claims that may be brought against us where the relevant statute of limitations has not expired. Our emails include a tracking pixel that tracks whether you open the email and whether you click banners in the email and your subsequent clicks and usage of our Website. We use this personal information to send you additional email communications which may be of interest to you, as based on your interaction with our emails and/or Website.
• Interact with us on social media. When you interact with our web pages on social networking websites, such as LinkedIn, Instagram, and Facebook (each a “Social Media Page”) (collectively “Social Media Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how LinkedIn, Instagram, and Facebook use your personal information, please see LinkedIn’s Privacy Policy, Instagram’s Privacy Policy, and Facebook’s Privacy Policy.
  • Social Media Pages. When interacting with our Social Media Pages, we collect, from you, your personal identifiers (first name) as well as any information that you provide when interacting with our Social Media Pages (e.g. commenting, sharing and rating). We use this information to advertise our services and to communicate with users via the contribution and comment function.
    
    Because our Social Media Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit.
    
    The content posted on our Social Media Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to concierge@vitarahealth.com.
  • Community Management. With the help of a third party, we collect, from you, your contact, including "likes", shares, messages and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts. We use this information to create advertisements that match our Social Media Page and to disseminate them via Facebook based on demographic data.
  • Facebook Messenger. When using Facebook messenger, Facebook collects, automatically, your internet or other electronic network activity information (IP address, date and time of the server request, time zone, specific browser or app function, access status, amount of data transferred, browser or app from which the Request comes, device type, operating system used, and its interface (e.g. Android or IOS), language, version of the operating system, and device identifiers). We do not use this information; its use is governed by Facebook’s Privacy Policy.
  • Facebook Page Insights. When you visit our Facebook Social Media Page, Facebook records your IP address and other information about your usage behavior on our Facebook Social Media Page. Facebook collects, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Facebook app through your mobile device (e.g. smartphone or tablet). Facebook uses this information to create statistical evaluations for us of the use of the Social Media Page. We receive this information, from Facebook, in the form of aggregated data and anonymous statistics regarding things like: age, gender, city/country, device, inquiries from individuals about other Facebook Social Media Pages, region and language settings of the users, proportion of men and women, the number of people reached, clicks on posts, "Likes” and reactions, comments and shared content, and total video views. We do not collect or process any other personal data in connection with the page insights.
    
    We do not retain this information independently. For information on data protection and the storage period on Facebook in relation to the "Page Insights" function see here and Facebook’s Privacy Policy. It has been contractually agreed with Facebook that Facebook is responsible for providing you with information about the processing for Page Insights.
  • Information Processed Solely by Facebook. We do not know how Facebook uses personal information for its own purposes, how long the personal information is stored on Facebook or whether Facebook data is passed on to third parties.
    
    If you are currently logged in to Facebook as a user, Facebook automatically collects, through trackers on your device, your Facebook ID or a link between the Facebook ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Facebook app through your mobile device (e.g. smartphone or tablet). This enables Facebook to understand that you have visited our Facebook Social Media Page along with other Facebook pages that you have clicked on, whether you clicked on Facebook buttons integrated into websites that partner with Facebook, and other online interactions that report user data to Facebook. Based on this data, content or advertising tailored to you can be offered.
    
    You can find more information about the personal information collected by Facebook, how it is used and how long it is stored by visiting Facebook’s Privacy Policy.
• Aggregate data. We aggregate the data we collect for benchmarking purposes and for internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data, unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.
• Interact with the Website. In addition to the personal information you provide directly to us, we also collect information from you automatically as you use our Website via “cookies” and similar tracking technologies (including through the use of pixel tags). This includes the following internet or other electronic network activity information.
  
  We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information (determined through your IP address) when you interact with the Website. We use this information to: (i) track you within the Website; (ii) enhance user experience; (iii) conduct analytics to improve the Website; (iv) prevent fraudulent use of the Website; (v) diagnose and repair Website errors, and, in cases of abuse, track and mitigate the abuse; and (vi) market to you more effectively across different web pages and social media platforms based on your browsing habits and history.
  
  Third party marketing and analytics cookies may be considered sale or sharing (i.e. disclosure for targeted advertising purposes) under certain state consumer data privacy laws. If you wish to opt out or manage your cookie preferences, please visit Do Not Sell or Share My Personal Information. [insert hyperlink to DNSSMPI] In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent. Please note, if you opt out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt out of each browser or device that you use.
  
  Particular third-party cookies to note on our Website include: Google Analytics and Google Tag Manager.
  • Google Analytics. We use Google Analytics to collect information on your use of the Website for its improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there (for more information about how Google collects and uses the information see here). Google Analytics also receives information about you from applications you have downloaded or services that you use that partner with Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Website or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Policy. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on, which can be accessed here. You can also adjust your Ad Settings or change settings in your Google My Activity if you are signed into your Google Account. If you wish to opt out of the sale or sharing through cookies, please visit Do Not Sell or Share My Personal Information. [insert hyperlink to DNSSMPI]
  • Google Tag Manager. Google Tag Manager is a tag management system to manage tags used for tracking and analytics on our Website. Tags are small code elements that, among other things, are used to manage traffic and visitor behavior and to test and optimize websites. We utilize Google Tag Manager to manage and organize all third-party tags on our Website and to control when those tags are triggered. You can view more information about Google Tag Manager’s privacy practices here.
  • Ad Services. We utilize Ad Services by LinkedIn and Meta to optimize our online marketing campaigns and to provide targeted advertisements to our Website visitors. For more information on how LinkedIn, Instagram, and Facebook use your personal information, please see LinkedIn’s Privacy Policy, Instagram’s Privacy Policy, and Facebook’s Privacy Policy.

Vitara Health will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

DATA RETENTION

Unless otherwise stated in this Privacy Notice, we retain your personal information (i) for as long as you maintain an account with us, (ii) until we receive a valid request to delete the information, in which case we will delete or anonymize the information within 60 days after receiving the request, (iii) until we no longer need the information to fulfill the purposes for which we collected it, or (iv) until the information is no longer needed for a service provider or contractor’s operational purpose(s).

We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for such purposes or a service provider or contractor’s operational purpose(s): (i) whether there is a retention period required by statute or regulations; (ii) the existence of actual or threatened litigation for which we are required to preserve the information; (iii) the statutes of limitations for potential legal claims; and (iv) generally accepted best practices in our industry, including in relation to the safety and security of our properties and assets. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed operational purposes based on the above criteria, we will delete or anonymize your personal information.

HOW WE SHARE YOUR PERSONAL INFORMATION

Vitara Health shares personal information in the following instances:

• Within Vitara Health. We share your personal information among our affiliated entities for the legitimate business purposes of efficiently and effectively providing the Services. Access to your personal information is limited to those on a need-to-know basis.
• In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
• With third parties. We may need to disclose your personal information to third parties, such as auditors or legal advisors to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, and to comply with our legal obligations.
• For legal purposes. We share your personal information where we are legally required to do so, such as in response to court orders, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.
• With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time and may do so by contacting us via email at concierge@vitarahealth.com.

For a business purpose. In the preceding twelve (12) months, Vitara Health has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

• We have disclosed your personal information to service providers that assist us in providing the Services. These service providers assist us with the following: information technology (“IT”) support; website hosting; cloud storage; data analysis; customer service; email delivery; marketing; payment processing; and similar services.
• We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Services and platform errors.
• We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to update, improve, and maintain the Services.

Vitara Health shares your internet or other electronic network activity information collected via cookies and other tracking technologies with our data analytics providers and ad networks as described in PERSONAL INFORMATION WE COLLECT, WHY, AND FOR HOW LONG to provide targeted advertising. Such sharing may be deemed a sale or sharing under certain state consumer data privacy laws. To opt out of this sale or sharing or otherwise opt out of the processing of your personal information for purposes of targeted advertising, please visit Do Not Sell or Share My Personal Information [hyperlink to DNSSMPI].

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information:

• Correct or View Your Information. You may access your account to correct or view certain personal information you have provided to us and which is associated with your account.
• Opt Out of Google Analytics. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser, which can be accessed here.
• Opt Out of Advertising Cookies. To set your cookie preferences or opt out of the sale or sharing of your information via cookies, please visit Do Not Sell or Share My Personal Information [insert DNSSMPI hyperlink]. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your device. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.
  • Association of National Advertisers opt-out registration: https://dmachoice.thedma.org/
  • Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
  • In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent.
• Opt Out of Email Tracking. You can disable this tracking by blocking automatic loading of images in your email.
• Opt Out of Marketing Communications. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send. Please note that we will continue to send you notifications necessary to the Services.

STATE PRIVACY RIGHTS

To the extent certain state consumer data privacy laws apply to our processing of your personal information, you may be entitled to the following rights:

• Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort. You may only make a request for access twice within a 12-month period.
• Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
• Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain.
• Right to Opt Out of Sale/Sharing. You have the right to opt out of the sale or sharing of your personal information to third parties. Vitara Health does not have actual knowledge that it sells or shares personal information of minors under the age of eighteen (18) years. To exercise your right to opt out of the sale or sharing of your personal information, you may submit a request by completing our webform, or by contacting us toll-free at +1 646‑596‑7386. To opt out of the sale or sharing via cookies, you may submit a Do Not Sell or Share My Personal Information request by completing our webform.
• Right to Opt Out of Targeted Advertising. You have the right to opt out of the processing of your personal information for purposes of targeted advertising. Vitara Health does not have actual knowledge that it processes the personal information of minors under the age of eighteen (18) years for purposes of targeted advertising. To opt out, you may submit a Do Not Sell or Share My Personal Information request by completing our webform.
• Right to Opt Out of Profiling. You have the right to opt out of profiling (i.e. automated processing of personal information) in furtherance of decisions that produce legal or similarly significant effects. We do not engage in such processing.
• Right to Data Portability. You have the right to request that we transfer your personal information to another organization or give it to you.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment in the processing of your personal information if and when you exercise your privacy rights.
• Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the Services or certain other permissible purposes like fraud, customer service or quality control. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. Vitara Health does not use sensitive information collected through the Services in this manner.
• Right to Appeal. You have the right to appeal an action taken (or not taken) by Vitara Health in response to your request. To exercise your right to appeal, you may submit your appeal by emailing concierge@vitarahealth.com, subject line: “Appeal My Consumer Request.” We will review the appeal and notify you of our response. If we still refuse to take action on your request, you have the right to file a complaint with applicable state regulator, as follows:
  • For California residents: If you are a concerned with our response as a result of your appeal, you may submit a complaint to the California Privacy Protection Agency here.
  • For Connecticut residents: If you are a concerned with our response as a result of your appeal, you may submit a complaint to the Connecticut Attorney General here.
  • For New Jersey residents: If you are a concerned with our response as a result of your appeal, you may submit a complaint to the New Jersey Attorney General here.
  • For Texas residents: If you are a concerned with our response as a result of your appeal, you may submit a complaint to the Texas Attorney General here.

To exercise your right to access/know, correct, or delete your personal information, you may submit a request by completing our webform, or by contacting us toll-free at +1 646‑596‑7386. To opt out of the sale or sharing of your personal information via cookies or the processing of your data for purposes of targeted advertising, you may submit a Do Not Sell or Share My Personal Information request by completing our webform. To opt out of the sale of your personal information for marketing purposes, or to limit the use of your sensitive personal information, you may submit a request by completing our webform, or by contacting us toll-free at +1 646‑596‑7386.

If the browser or extension that you (or your authorized agent) are using supports Global Privacy Control (GPC) (see here for more information), you may utilize the GPC opt out preference signal to instruct us to not sell or share any of your personal information collected online. The GPC opt out preference signal will apply to the device, platform, or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings. Please note that you must opt out of each device and each browser.

For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access/know and deletion requests with the information provided, we may ask you for additional pieces of information.

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

DO NOT TRACK

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

CHILDREN’S PRIVACY

The Services are not directed to or intended for individuals under the age of eighteen (18) years. We do not allow registration by, nor do we directly collect personal information from any person we know to be under the age of eighteen (18) years.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.

CONTACT US

If you have any questions or concerns regarding this Privacy Notice, please contact our Compliance Department via telephone at +1 646‑596‑7386 or via email at concierge@vitarahealth.com.