VAI ACQUISITION, LLC.
PRIVACY POLICY

This policy covers how VAI Acquisition, LLC (more commonly known as “VerbalCare”), which operates the website located at verbalcare.com, accompanying mobile platform (“mobile apps or apps”), and any successor or related websites or platforms (hereinafter "VerbalCare") treats Personally Identifiable Information ("PII") and Protected Health Information ("PHI") (hereinafter "PHI") that VerbalCare collects, receives, maintains, stores or transmits, including information you transmit or submit through our mobile applications (the "Platform"). Your PHI includes information that individually identifies you or is information about you that can be traced back to you, your IP address, or your location. It may also include, but is not limited to your name, address, email address, phone number, and information about your health and/or other types of protected health information or personally identifiable information.

Agreement

BY USING VERBALCARE’S MOBILE PLATFORM, WEBSITE AND/OR VERBALCARE'S PRODUCTS OR SERVICES, YOU ACCEPT AND HEREBY EXPRESSLY CONSENT TO THE TERMS OF THIS PRIVACY POLICY. This Privacy Policy may change from time to time, so please check back periodically to ensure that you are aware of any changes. Your continued use of the Platform and/or VerbalCare's products or services signifies your acceptance of any such changes. If you do not agree to such changes, you must immediately stop using the mobile platform and website.

Information Collection and Use

VerbalCare collects personal information when you register with VerbalCare through its mobile platform, or when you use any other VerbalCare products or services. When registering with VerbalCare, we will ask you to provide us with your name, address, e-mail address, phone number, date of birth and other related information that VerbalCare may ask of you from time to time, and you may submit additional information and comments through the Platform. It is always your choice whether or not to provide us with such information. If you choose not to provide the requested information you may not be able to use certain features or functions of this Platform, or VerbalCare' products or services. Whenever you visit our website, VerbalCare also receives and records information on our server logs from your browser, including your IP address, VerbalCare's cookie information, and the pages you request, and relates it to the PII you provide.

VerbalCare collects and uses information you provide to:

  1. provide VerbalCare' products and services to you;
  2. communicate with you about our products and services or to reply to your request for information or comments;
  3. with your consent, provide information to you about developments, announcements, promotions or new products or services;
  4. conduct research and improve our products and services;
  5. with your consent, provide information to your healthcare provider related to VerbalCare programs and/or services; and
  6. provide de-identified reporting (i.e. reporting that does not contain any PHI) for internal and external clients and associated partners. Your name will not be attached to any data we share with external partners.

You may opt-out of receiving future messages and announcements and remove your name from our mailing lists at any time. The opt-out provisions do not apply to information collected by cookies or used internally to recognize you and/or facilitate your visits to our website or the mobile platform, or information we retain to comply with legal requirements. In order to dis-enroll from the mobile platform or to opt out of receiving information in the future, you may contact VerbalCare Customer Support by calling us at 617-410-8372 or emailing us at support@verbalcare.com.

Our mobile platform and website uses a software technology called "cookies." Cookies are small text files that we place in visitors' computer browsers to store their preferences. Cookies themselves do not contain any PHI.

"Web beacons" are small pieces of code placed on a web page to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We may use web beacons on our website or platform from time to time for this purpose.

Information Sharing and Disclosure

VerbalCare does not rent, sell, or share your PHI with other people or nonaffiliated companies.  VerbalCare does not share, disclose or transfer your PHI except: a) to provide products or services you have requested; b) when we have your authorization to share such information; or c) when we provide the information to companies or consultants working on behalf of or with us under confidentiality agreements. VerbalCare may elect to rent, sell, or share your de-identified information in aggregate (your name will not be included). Examples of how this information may be used include the use of the aggregate data to a) research the effectiveness and side-effects of a drug or drugs in a non-clinical setting; b) research predictors of adverse events to build algorithms that can help alert patients or providers before such events occur; c) or other such examples.

We will disclose your information in response to a valid legal process, for example, in response to a court order or a subpoena to comply with its applicable legal and regulatory reporting requirements. We also may also disclose your information in response to a law enforcement agency's request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or to verify or enforce compliance with the policies governing our products and services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. In addition, we may transfer your information to an entity or individual that owns, acquires, buys, or merges with VerbalCare, or our other business units.

Confidentiality and Security

We have taken reasonable and necessary steps to ensure that all information collected will remain secure and in its original form, i.e., free from any alteration. We have put in place appropriate physical, electronic, and administrative procedures in an effort to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. All of your information will be stored and processed within North America.

VerbalCare’s website and mobile Platform may contain links to other sites that are not owned or controlled by VerbalCare. VerbalCare is not responsible for and will not be a party to any transactions between you and a third party provider of products, information or services. VerbalCare does not monitor such transactions to ensure the confidentiality of your PHI, including credit card information. VerbalCare is not responsible for the privacy practices of these other sites. Any separate charges or obligations you incur in your dealings with these third parties linked to VerbalCare's mobile Platform or website are solely your responsibility. We encourage you to review the privacy policies and statements of other sites to understand their information practices. VerbalCare’s Privacy Policy applies only to information collected by our website, mobile platform and related Services.

International Or Cross-Border Transfer Of Your Personal Information And Your Express Agreement

 

Given that the Internet operates in a global environment and that transfer of your data is necessary to process your registration and use of the Services, to provide updates, and to respond to your inquiries, using the Internet to collect and process PII and PHI necessarily involves the transmission of data on an international, or cross-border, basis.  By signing up for or using the Services, and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your PHI and PII in this way.   The PHI an PII of users who are located outside the U.S. will be transferred outside of each eligible country to the United States where our servers are located and where it will be processed and stored on servers in the U.S.  The U.S. does not provide an adequate level of protection according to EU data protection regulations. We will take all steps reasonably necessary to ensure that users’ PII and PHI is treated securely in respect of such transfer, but will not otherwise take steps to ensure compliance with applicable laws in each user’s country of residence. By registering for or using the website, mobile platform or Services or by sending us emails, you expressly agree to such transfer and disclosure.

By signing up for or using VerbalCare’s Services, sending us email, or by using the website, mobile platform or Services, you provide your express consent to our disclosure of your PII and PHI to our Subcontractors for the purposes described in this Privacy Policy.

Children’s Online Privacy Protection Act Compliance

VerbalCare is in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), as we do not knowingly collect any information from anyone under 13 years of age.  The mobile platform is directed to people who are at least 13 years old or older.

Accessing Your Information

You may request access to your PHI and request information about our collection, use and disclosure of such information by contacting us at support@verbalcare.com. We use best efforts to keep our records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your PHI. Your rights to access your PHI are not absolute. We may deny you access when required by law or if disclosure would likely reveal personal information about a third party.

Disclosure for Marketing Purposes

By agreeing to the terms of this Privacy Policy, you expressly authorize VerbalCare to share your PHI with third parties for direct marketing purposes. If you are a California resident, California Civil Code Section 1798.83 permits you to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. Since we do not make such disclosures, we are exempt from these reporting requirements.  In addition, we currently do not honor “Do Not Track” signals. If you do not want your name and contact information to be shared with any company or organization, you may notify us at any time by writing to us at support@verbalcare.com or our regular mailing address below.

Questions, Complaints and Suggestions

If you have questions, complaints or suggestions, or wish to correct your profile information, please email VerbalCare at support@verbalcare.com or call us at (617) 410-8372.

Written communication should be sent to:

Customer Support
Verbalcare, Inc.
800 Technology Center Drive
Stoughton, MA 02072

This Privacy Policy was last updated on or about January 15, 2016.

See more at:  http://verbal.care/contact/