User Privacy Policy | Very.Health

Privacy Policy

INTRODUCTION

This Privacy Policy describes how Very.Health P.C. (“VERY”) collect, use, disclose and otherwise process personal information we obtain in connection with the services we provide, including through our website and mobile applications (collectively “Site”) that link to this Privacy Policy. In addition, this Privacy Policy discusses our practice of working with third parties that you agree to within the eating disorder community.

The Privacy Policy is part of VERY’s Terms. When you use VERY’s services and this Site you accept and agree to both the Terms and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Services and this Site immediately or cease to provide the Services, as applicable. By accessing and using our platform or providing the Services, as applicable, you affirm that you have read the Terms and the Privacy Policy and that you understand, agree to, and acknowledge all the terms contained in both of them.

Please note that some of the services we provide are governed by the Health Insurance Portability and Accountability Act (“HIPAA”). When VERY provides services covered by HIPAA, you will receive a separate HIPAA privacy notice (“Notice of Privacy Practices”), which will govern the collection, use, and disclosure of your protected health information. To the extent there are inconsistencies between the Notice of Privacy Practices you receive and this Privacy Policy, the Notice of Privacy Practices will govern.

PERSONAL INFORMATION WE COLLECT

VERY collects personal information from you, other program participants, family members, and caregivers, as well as the participants’ care teams, which may consist of physicians, dietitians, therapists, and other health care professionals, and support personnel. These individuals may provide information about themselves (e.g., patients who sign up to participate) as well as about each other (e.g., physicians who provide information about program participants).

This information may include:

Health and Medical Information, such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, and medications an individual may take, including the dosage, timing, and frequency.
Personal and Business Contact Information and Preferences, such as name, email address, mailing address, phone number, and emergency contact information.
Biographical and Demographic Information, such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians.
Audio and Video Feed, when you engage in VERY’s telemedicine and technological services. We may record your audio and video conversations for quality and training purposes, and to advance and optimize the telemedicine program and technological platform.
Transaction Information, such as information about payments to and from you and other details of products or services you have purchased from us.
Feedback or Correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
Other Information you provide to us, such as in emails, on phone calls, or in other correspondence with VERY or its service providers.

We and our service providers may use cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies to automatically collect information about your interaction with our services through your computer or mobile device, including:

Cookies

The Site may use a technology called “cookies”. A cookie is a tiny element of data that VERY’s websites and our third-party technology providers can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. If you have registered with our Services, these cookies: (1) may let VERY know who you are, (2) may be necessary to access your information to deliver the Services, and (3) may provide us and our service providers with information that we will use to personalize our Services and marketing activities. You may set your web browser to limit or block the use of cookies. However, should you decide not to accept cookies from our websites, you may limit the functionality we can provide when you visit our Services.

Tracer Tags

VERY’s Services and email communications may also use a technology called “tracer tags”. These may also be referred to as “clear GIFs” or “web beacons”. This technology allows us and our third-party technology providers to understand which pages or content you view. These tracer tags are used to help VERY optimize and tailor our Services for you and other web visitors.

Google Analytics

VERY uses automated technologies and applications, such as Google Analytics, to evaluate usage of our Services. We also may use other analytic means to evaluate our Site and Services. We use these tools to help us improve the Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes:

To provide you the agreed upon Services, including to:

Establish and maintain your account
Facilitate your interaction with peers, coaches, health care professionals and others, at your request
Provide information about our services through announcements, updates, security alerts, and support and administrative messages
Enable the services’ security features, such as two-factor authentication
Understand your needs and interests, and personalize your experience with the Services and our communications
Provide support and maintenance for the services, analyze, and improve our Services and to develop new products and Services
To respond to your requests, questions, and feedback

For Research and Public Health Purposes

We may use your personal information for research and public health initiatives, including to prepare for symposia, research publications, conferences, and scientific and educational events. In connection with this research, we will not disclose your name or contact details.

To Comply with Law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For Compliance, Fraud Prevention, and Safety

We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the services; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With Your Consent

We may offer you opportunities to opt in to allow us to collect, use and share your information for other purposes, and we will do so only if you opt in.

HOW WE SHARE YOUR PERSONAL INFORMATION

Affiliates

We may share your personal information with our corporate parent, subsidiaries, and affiliates that are involved in providing the Services to you, such as Aspire Wellness LLC and other third party healthcare providers.

Service Providers

We may share your personal information with third party companies and individuals that provide Services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.

Clinical Research Organizations, Healthcare Organizations or Healthcare Providers, Researchers, Institutions, and Publishers

For the research and public health purposes described above, we will not disclose your name or contact details to these organizations.

Your Family Members, Caregivers, and Care Team

By participating in our programs, you direct us to share some of your information with your family members, caregivers, and care team. For example, they may be able to view the contents of your monitoring history, treatment outcomes, and other information contained within the Services. Your care team may obtain the information about you through the Services and store it in their own systems. The Services may permit your care team to see the names and other identifying information about your other health care providers and their organizations to facilitate collaborative care.

Your Insurance Provider

When you participate in programs sponsored by your insurance provider, you also direct us to provide certain information about your use of our Services to the insurance provider, including engagement and outcome metrics. We may also provide some of your information to confirm your eligibility for our Services.

Third-Party Platforms

By enabling features or functionality that connect your account to a third-party platform (such as by logging in to the website or mobile application using your account with the third-party, providing your API key or similar access token for the services to a third-party, or otherwise linking your account with the services to a third-party’s services), you chose to disclose certain of your personal information with those platforms. We do not control the third party’s use of your personal information.

Professional Advisors

VERY may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

For Compliance, Fraud Prevention, and Safety

VERY may share your personal information for the compliance, fraud prevention, and safety purposes described above.

Business Transfers

We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

With Your Consent

VERY may offer you opportunities to opt in to allow us to collect, use, and share your information for other purposes, and we will do so only if you opt in.

YOUR CHOICES

Access or Update Your Information

If you have registered to use our Services, you may review and update certain personal information in your account profile by logging into the account or emailing us at support@very.health.

Cookies and Browser Web Storage

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the services may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

SECURITY

VERY maintains organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. In the event that VERY is required to notify you about a situation involving your data, we may do so by email or telephone to the extent permitted by law.

DATA RETENTION

VERY retains personal information for as long as necessary to (a) provide our services; (b) comply with legal obligations; (c) resolve disputes; and (d) enforce the terms of customer agreements.

Data Deletion

You may request deletion of your personal information by us, however, we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete personal information, it will be deleted from the active database, but may remain in our archives (subject to applicable law) and we may also retain anonymous information about your use of our services. Once we disclose some of your personal information to third parties, we may not be able to access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. After we delete personal information, we may retain de-identified information and will continue to use de-identified information as permitted under this Privacy Policy.

Notice to California Residents

The California Consumer Privacy Act provides California consumers with the right to obtain from us information about personal information about you that we collect, use, and disclose. You can exercise your rights by sending an email to support@very.health.

CREATION OF ANONYMOUS DATA FOR ANALYTICS

We may create anonymous data from personal information by excluding information that makes the data personally identifiable and use that anonymous data for our lawful business purposes. We de-identify any patient data in accordance with applicable HIPAA requirements.

CHILDREN

If we have obtained consent from a parent or legal guardian, VERY may collect, use, and disclose the personal information of a child under 13 as described throughout this Privacy Policy. Parents or legal guardians may contact us to ask if we have collected their child’s personal information, to review or correct that information, and to request that VERY stop collecting this information or have it deleted. Such requests are subject to VERY’s verifying to our satisfaction that the requester is in fact the child’s parent or legal guardian.

JOB APPLICANTS

When you visit the “Careers” portion of our website, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to provide improved administration of the website, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on VERY; (b) to protect and defend the rights or property of VERY or others; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or VERY’s Terms.

INTERNATIONAL DATA TRANSFERS

VERY is headquartered in the United States and has affiliates and service providers in other states, and your personal information may be transferred to locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

OTHER SITES AND SERVICES

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by VERY. These links are not an endorsement, authorization, or representation that we are affiliated with that third party. We do not exercise control over third party websites or services and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

CHANGES TO THIS PRIVACY POLICY

VERY may update our Privacy Policy from time to time by posting a new version on the Site. You should check this page occasionally to review any changes. If we make material changes to this Privacy Policy, we will notify you by email, notification, Site notice, or another method that we believe is reasonably likely to reach you.

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Very.Health, P.C. and associated professional entities (“VERY”) are committed to obtaining, maintaining, using, and disclosing your protected health information (“PHI”) in a manner that protects your privacy. We urge you to read this Notice of Privacy Practices (this “Notice”) carefully in order to understand both our commitment to the privacy of your PHI and your rights.

VERY is required by law to maintain the privacy of your PHI and to provide you with a notice of our legal duties and privacy practices with respect to PHI. PHI is information about you, including basic demographic information, that may identify you and that relates to your past, present or future physical or mental health condition, treatment, or payment for health services. This Notice describes how we may use and disclose your PHI to carry out treatment, payment, or health care operations, and for other specified purposes that are permitted or required by law. The Notice also describes your rights with respect to your PHI.

VERY reserves the right to amend this Notice from time to time. When material changes are made, VERY will promptly post the updated Notice on the Site at very.health and provide a copy to you at your request.

Uses and Disclosures of Your Information

VERY may use or disclose your PHI for the following purposes:

Treatment. VERY may use or disclose your PHI for purposes of providing your treatment. For example, we may disclose your PHI to your primary care physician if needed to coordinate your medical care.
Payment. VERY may use or disclose your PHI for purposes of billing and collecting payment for our services. For example, we may disclose your PHI to your health plan to obtain payment for our services.
Healthcare Operations. VERY may use or disclose your PHI to facilitate our healthcare operations. For example, we may review your PHI internally as part of an audit to confirm the quality of services being delivered to our patients.
As Required by Law. VERY may use or disclose your PHI if required to do so by federal or state law.
Disclosures to your Representative and/or Individuals Involved in Your Care. VERY may disclose your PHI to your family members who are involved in your care, including those who are responsible for paying for your care. VERY may also disclose your PHI to your personal representative, as established under applicable law to an administrator or authorized individual associated with your estate.
Disclosures to Business Associates. VERY may disclose your PHI to certain of our service providers that have agreed to maintain the privacy and security thereof. For example, we may disclose your PHI to Virtual Eating Recovery, Inc., which provides administrative support services to Very.
De-Identification of PHI. VERY may de-identify your PHI, meaning that VERY would remove all identifying features as determined by law to make it extremely unlikely that the information could identify you. De-identified information no longer qualifies as PHI, meaning that VERY may use and disclose it for purposes not set forth in this Notice.

VERY may also use or disclose your PHI in other ways as permitted by law. Generally, these are ways that serve the public health and/or research. Specifically:

VERY may use or disclose your PHI as needed to assist with public health and safety issues and may disclose your PHI to law enforcement officials when needed, to health oversight agencies for authorized activities and for special government functions including national security needs.
VERY may disclose your PHI as needed to organ procurement organizations, medical examiners, and funeral directors in the event of an individual’s death.
VERY may use or disclose your PHI to address workers’ compensation claims.
VERY may use or disclose your PHI in response to a court or administrative order, or in response to a subpoena.

Uses and disclosures of PHI for purposes other than those described above, including for marketing purposes and disclosures that would constitute the sale of PHI, will not be made in the absence of a written authorization signed by you or your personal representative. Once you sign an authorization, you may revoke it by contacting VERY at support@very.health. However, any use or disclosure of your PHI already taken in reliance on your authorization prior to your revocation cannot be reversed.

Your Rights Regarding Your PHI

You have the following rights with respect to your PHI:

You have the right to request restrictions on certain uses and disclosures of your PHI. VERY will consider every request to restrict uses or disclosures of your PHI and will strive to honor those that are reasonable. However, VERY is not legally required to honor each request unless the requested restriction involves a disclosure not required by law to a health plan for purposes of payment or health care operations, and you have paid for the applicable services in full, out of pocket. With respect to any requested restriction, if VERY agrees to honor it, we will document such restriction and continue to abide by it.
You have the right to receive confidential communications of your PHI from VERY. Specifically, you may request that VERY communicate with you about your PHI using a specific means, phone number or address. VERY will accommodate reasonable requests regarding confidential communications of your PHI.
Subject to applicable state law, you have the right to inspect and copy your PHI. You also have the right to access and receive your PHI electronically if readily producible in such format.
You have the right to correct or update your PHI. If you believe that there is an error in your PHI, you may request that VERY update it as appropriate.
You have the right to receive an accounting of certain disclosures of your PHI made by VERY. Upon receipt of such request, VERY will provide you with a list of disclosures made by VERY in the prior six (6) years, not including certain types of disclosures such as, by way of example only, those made directly to you or pursuant to your written authorization.
You have the right to obtain a paper copy of this Notice upon request.

To exercise any of these rights, please send written communication to support@very.health.

Breach Notification

VERY is required by law to notify you in the event that your PHI is subject to a security breach unless VERY reasonably determines that, after fully investigating the situation and assessing the risk presented, there is a low probability that the privacy or security of your PHI has been compromised. You will be notified without unreasonable delay and in no event later than sixty (60) days following discovery of the security breach. Such notification will include information about the security breach, including steps that VERY has taken to mitigate potential harm, and a contact person to whom you may address additional questions.

Questions, Comments, or Complaints

If you have any questions or comments about this Notice, or if you have any complaints about VERY’s privacy practices, please contact us at support@very.health. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services. VERY will not retaliate against you for filing a complaint.

CONTACT INFORMATION

If you have any questions or concerns about our Privacy Policy, please contact us at support@very.health.