Privacy Policy

By using the Website, you consent to our collection, analysis, and retention of data relating to the use of the Website. Personal Information is collected when you:

• access and use the Website and
• communicate with us (including communications with our customer support team).

Cookies, Automatic Data Collection, and Related Technologies. The Website will collect and store information that is generated automatically as you access and use it, including your preferences and anonymous usage statistics.

When using the Website, we collect information such as your IP address, through cookies and similar technology. Cookies are small text files that store your preferences. Blocking or deleting cookies may affect the functionality of the Website. If you are using a mobile device, we may also receive your mobile device ID and information about your operating system. We may correlate this information with other Personal Information we have about you. Additionally, when you visit the Website, we and any third parties placing ads receive the URL of the webpage from which you came. If you click on an ad, we and the third party may also receive the URL of the page you were on when you clicked the ad and the URL of the site associated with the ad that you clicked.

We have implemented various measures to protect the security of collected information. This Website adheres to the highest levels of cyber security and privacy compliance to ensure a strong security posture that meets commercial and federal guidelines. However, please note that no internet transmission is ever completely secure, and we cannot guarantee, ensure, or warrant the security of your information. We are not responsible for any unintentional disclosure or loss of your information, including Personal Information. By using this Website, you understand and accept this risk, to the extent permitted by applicable law.

By using the Website or providing Personal Information to us, you agree to receive communications electronically regarding security, privacy, and administrative issues. In the event of a security breach, we will attempt to notify you electronically. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at [email protected].

We use Personal Information:

• to facilitate and improve our services,
• to communicate with you,
• to aggregate with other data.

Internal and Service-Related Usage. We collect and use Personal Information for internal and service-related purposes. We may also use and retain the data we collect to improve our services.

Communications. We may contact you to discuss the Vibrent Health services.

Aggregate Data. The data collected through the Website may be anonymized and combined with other data for various purposes in accordance with applicable law.

We may share your information:

• to comply with legal obligations,
• in connection with a merger, sale, or other asset transfer, and
• with your permission.

As Required by Law and Similar Disclosures. In order to comply with legal requests and protect the rights, safety, and property of yourself and others, we may access, preserve, and share your Personal Information, as well as other account information and content. This may include responding to court orders, subpoenas, and other legal processes, as well as fulfilling your specific requests.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing for due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed, sold, or transferred as part of such transaction as permitted by law and/or contract. You acknowledge and consent to any such disclosure, sale, or transfer. We cannot control, and are not responsible for, how entities may use or disclose your information following any such disclosure, sale, or transfer.

Non-Personal Information. This Privacy Policy does not restrict our use or disclosure of non-Personal Information collected through cookies, web beacons, or Website activity logging. If you prefer not to share this information with Vibrent Health, you can limit passive data collection by disabling cookies. We may share non-Personal Information with partners and third parties.

Our Website is not designed for and is not marketed to people under the age of 18 or such other age designated by applicable law (“minors”). We do not knowingly collect or ask for Personal Information from minors. If you are a minor, please do not use our Website or send us your Personal Information. We delete Personal Information that we learn is collected from a minor without verified parental consent.

If you learn that anyone under the age of 18 for whom you are responsible has provided us with Personal Information without your consent, you may alert us at [email protected].

If you are a current resident of California, you may have additional rights under the California Consumer Privacy Act of 2018 (“CCPA”).

Rights Under the CCPA and other California Laws. Individuals whose Personal Information is covered by the CCPA have the right, subject to certain limitations, to:

1. Right to Know: You can request that Vibrent disclose to you: (1) the categories and/or specific pieces of Personal Information they have collected about you, (2) the categories of sources for that Personal Information, (3) the purposes for which Vibrent uses that information, (4) the categories of third parties with whom Vibrent discloses the information, and (5) the categories of information that Vibrent sells or discloses to third parties. You can make a request to know up to twice a year, free of charge. Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
2. Right to Delete: You can request that Vibrent delete Personal Information they collected from you and tell their service providers to do the same, subject to certain exceptions (such as if Vibrent is legally required to keep the information).
   1. Upon receiving and verifying a request to delete, Vibrent Health will delete the Personal Information that we have collected about you, unless that information is necessary for Vibrent Health to complete the transaction for which we collected the information; provide you with a good or service you requested; perform a contract Vibrent Health entered into with you; detect security incidents; maintain the functionality or security of Vibrent Health’s systems; comply with or exercise rights provided by the law; or use the information internally in ways that are comparable with the context in which you provided the information to Vibrent Health or that are reasonably aligned with expectations based on your relationship with Vibrent Health, among other things. We may also retain information where another exception to the deletion requirements in Cal. Civ. Code § 1798.105(d) applies.
   2. Please note that if you or your authorized agent request that your Personal Information be deleted, you may no longer be able to access or use certain parts of the Sites.
   3. Process for Access or Deletion of Personal Information. If you are a California resident, please send an email request to [email protected] to request access to or deletion of your Personal Information. Vibrent Health may request additional information confirming your identity if the request involves sensitive information. We will verify and respond to your request consistent with applicable law, however we will confirm receipt within ten (10) business days and generally respond no more than forty-five (45) calendar days after receipt of request. We may extend this period to ninety (90) calendar days and, in the event that we do extend the period, we will explain to you why we did so.
3. Right to Opt-Out of Sale or Sharing: You may request that Vibrent stop selling or sharing your Personal Information (“opt-out”), including via a user-enabled global privacy control. Vibrent cannot sell or share your Personal Information after they receive your opt-out request unless you later authorize them to do so again.
4. Right to Correct: You may ask Vibrent to correct inaccurate information that they have about you.
5. Right to Limit Use and Disclosure of Sensitive Personal Information: You can direct Vibrent to only use your sensitive Personal Information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested.

In the twelve (12) months preceding the “Last Updated” date of this Privacy Policy, Vibrent Health has not sold any Personal Information. You have a right not to be discriminated against for the exercise of the privacy rights conferred by the CCPA.

By using the Website, you will transfer data to the United States.

By choosing to visit the Website or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the Commonwealth of Virginia and the adjudication of any disputes arising in connection with Vibrent Health or the Website will be in accordance with the Terms of Use.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and global processing. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

The Website is operated by Vibrent Health. You may contact us at [email protected].

We may make changes to this Privacy Policy from time to time, so please review it periodically. We will post any changes to our site.

Posting of Revised Privacy Policy. We will post any changes to the Privacy Policy on this web page. The revised version of the Privacy Policy will be effective when it is posted.