Privacy Policy - Vibrent

Privacy Policy

Privacy Policy for
Website
Privacy Policy for
Participants / Patients
Privacy Policy for
Researchers / Providers

Last Updated: April 25, 2024

This Privacy Policy is incorporated by reference into Vibrent Health, Inc.’s Terms of Use.

The terms “Vibrent Health,” “we,” and “us” includes Vignet, Inc., a Delaware corporation d/b/a “Vibrent Health,” and our affiliates and subsidiaries. The Privacy Policy describes how we may collect and use information we obtain through the “Vibrent Health Tools.”

The “Vibrent Health Tools” are websites, apps, and software developed by Vibrent Health for health research purposes. They help with outreach, recruitment, enrollment, and engagement in studies. Any content such as consent language, surveys, or messages that are distributed to individuals through the Vibrent Health Tools may be produced and/or authored by our partners and customers.

“Personal Information” refers to information that can be used to readily identify, contact, or locate you, such as your name, address, email address, or phone number. It does not include anonymized information that cannot easily identify a specific individual.

“Health-Related Information” refers to individually identifiable health information, related to an individual’s physical or mental health, including demographic information, health care provision, and/or payment. Health-Related Information is considered Personal Information.

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

> register to use the Vibrent Health Tools; and
> use the Vibrent Health Tools (including by posting, interacting with and making submissions); and
> communicate with us (including communications with our customer support team).

Personal Information Collection. You must register to use the Vibrent Health Tools. To register, you will need to provide Personal Information such as your email address and phone number, along with a username and password. You may also provide other optional information.   If you are under the age of 18, you must get permission from a parent or guardian who has an account for the Vibrent Health Tools to use any of the Vibrent Health Tools.

Cookies, Automatic Data Collection, and Related Technologies. The Vibrent Health Tools collect and store information that is generated automatically as you use them, including your preferences and anonymous usage statistics.

When using the Vibrent Health Tools, 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 Vibrent Health Tools.  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 Vibrent Health 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. Vibrent Health Tools adhere 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 the Vibrent Health Tools, you understand and accept this risk, to the extent permitted by applicable law.

By using the Vibrent Health Tools 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 support@vibrenthealth.com.

We use Personal Information:
> to facilitate and improve our services,
> to communicate with you,
> for marketing purposes, and
> to aggregate with other data.

Internal and Service-Related Usage. We collect and use Personal Information for internal and service-related purposes. This may involve sharing information with third parties who help us facilitate some services such as sending SMS messages or email services. We may also use and retain the data we collect to improve our services.

Communications. We may send you messages using the contact information you provided for (i) requesting your response or action for research study or project activities, (ii) informational and operational purposes, such as account management, customer service, or system maintenance, and (iii) to inform you about health research studies or special offers that may be of interest to you.  

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

We may share your information:
> with other Vibrent Health Tools users,
> to comply with legal obligations or to protect and defend our rights and property,
> in connection with a merger, sale, or other asset transfer, and
> with your permission.

Sharing with Other Users. If you provide consent, the Vibrent Health Tools may share information, including Health-Related Information, to other users, such as researchers and healthcare providers. However, we are not responsible for how these users may use your shared information.

Marketing. We respect your privacy and will not share your Personal Information with other individuals or companies for direct marketing purposes unless you give us your explicit consent.

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.

To opt out of data collection or be removed as a Vibrent Health Tools user, please contact us at support@vibrenthealth.com.

Vibrent Health follows the United States Children’s Online Privacy Protection Act (COPPA), guidelines to protect children’s privacy (anyone under the age of 18). Users under 18 must have parental/guardian permission to use our tools. We collect and use children’s personal and health-related information in a limited and necessary manner.

Parental Rights. You have a right create an account for your child, to enter and review your child’s Personal Information, request that we amend or delete your child’s account and/or Personal Information and opt-out of further collection or use of your child’s Personal Information.

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 support@vibrenthealth.com.

If you are a current resident of California, you may have additional rights under the California Consumer Privacy Act of 2018 (“CCPA”), as amended. These provisions of the CCPA do not, however, apply to certain medical information that is collected pursuant to the California Confidentiality of Medical Information Act (“CMIA”) or protected health information under the Health Insurance Portability and Accountability Act (“HIPAA”). The CCPA exempts most clinical trial data.

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

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).
a. 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.
b. 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.
c. Process for Access or Deletion of Personal Information. If you are a California resident, please send an email request to support@vibrenthealth.com 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.

Pursuant to the Texas Health and Safety Code, Sec. 181.154, if Vibrent Health receives any information that identifies you that relates to your past, present, or future physical or mental health, healthcare, or payment for your healthcare, such information may be subject to electronic disclosure by such means as file transfers or email.

By using the Vibrent Health Tools, you will transfer data to the United States.

By choosing to visit the Vibrent Health Tools 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 Vibrent Health Tools 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 Vibrent Health Tools are operated by Vibrent Health. You may contact us at support@vibrenthealth.com.

If you would like to update or correct any information that you have provided to us through your use of the Vibrent Health Tools, or otherwise, you may use the Vibrent Health Tools to change or delete such information. If such functionality is insufficient or if you have suggestions for improving this Privacy Policy, please send an email to support@vibrenthealth.com.

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 page. The revised version of the Privacy Policy will be effective when it is posted.