Privacy Policy Provider

1. Introduction

Veta Health, INC., (“we”, “us”, “our,” “Veta Health,” or “the Company”) is a service that enables patient users (“Patient User(s)”) to engage in clinically validated care plans with their care partners, healthcare providers, and health organizations (collectively, “Healthcare Provider”). We are committed to respecting the privacy rights of our customers, visitors, and other users of Veta Health. This Provider Privacy Policy (the “Privacy Policy”) is intended to describe how we collect, use, and disclose information regarding Healthcare Providers through (i) our websites located at www.myvetahealth.com, www.vetahealth.com, and www.veta.health (collectively, the “Site”), and (ii) our web portal and mobile applications (collectively, the “Platform”). The Site and Platform are provided by Veta Health for Patient Users and Healthcare Providers to use in connection with our services (collectively, the Site, Platform, and accompanying services are the “Service(s)”). If you are reading this Provider Privacy Policy, you are a Healthcare Provider.

Privacy Policy Applicability

This Privacy Policy applies to personal data that Veta Health collects from Healthcare Providers who use the Services (“Personal Data”). The term “Personal Data” includes any information that can be used on its own or with other information in combination to identify or contact one of our users.

We believe that privacy and transparency about the use of your Personal Data are of utmost importance. Therefore, our privacy practices are intended to comply with all applicable federal, state, and international laws related to privacy. Additionally, in this Privacy Policy, we provide you detailed information about our collection, use, maintenance, and disclosure of your Personal Data. The Privacy Policy explains what kind of information we collect, when and how we might use your Personal Data, how we protect Personal Data, and your rights regarding your Personal Data.

This Privacy Policy is incorporated and made part of our Terms of Use. Therefore, terms used in this Privacy Policy that have been previously defined will have the same meanings as provided in our Terms of Use, as applicable.

For additional information related to how we use and disclose your Personal Data, please contact us at compliance@myvetahealth.com

Agreement to Privacy Policy Terms

BY ACCESSING AND/OR USING THE SITE, SERVICE, AND/OR PLATFORM, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE, YOU MUST IMMEDIATELY CEASE USING THE SERVICES AND PLATFORM.

Privacy Policy Updates

Please note that we occasionally update this Privacy Policy, and it is your responsibility to stay up to date with any amended versions. We will post a notice regarding any revisions to this Privacy Policy at a prominent location on the Site or Platform. Any changes to this Privacy Policy will be effective immediately upon providing notice on the Site or Platform and will apply to all Personal Data that we maintain, use, and disclose. If you continue to use the Site, Service, and/or Platform following such notice, you are agreeing to those changes.

Account Deletion

If at any point you no longer agree to the use and disclosure of Personal Data, as described in this Privacy Policy, you can delete your account on the Platform (“User Account”) by sending a deletion request to compliance@myvetahealth.com with the following information:

Your login email address; and
A statement that you are requesting account deletion.

Collection And Use Of Personal Data

What Personal Data Does Veta Health Collect?

We collect the following types of information: (i) demographic and User Account data; (ii) support data; and (iii) technology and usage data. Each category of data is explained in depth below.

Demographic and User Account Data: Veta Health collects demographic data from Healthcare Providers, which may include, but not be limited to, your name, date of birth, gender, phone number, address, e-mail address, your role within your organization, the state where you are located, the level of supervision necessary for you to provide services, the state(s) in which you are licensed, and your title within your organization. The collection of this demographic data is primarily used to create your User Account, which you can use to securely receive the Services. As part of your creation of a User Account, we may collect your username and password.

Support Data: If you contact us for support or to lodge a complaint, we may collect technical or other information from you through log files and other technologies, some of which may qualify as Personal Data (e.g., IP address). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Platform and Services in accordance with this Privacy Policy. Calls with Veta Health may be recorded or monitored for training, quality assurance, customer service, and reference purposes.

Technology and Usage Data: We use common information-gathering tools, such as log files, cookies, web beacons, device IDs, geolocation, and similar technologies to automatically collect information, which may contain Personal Data from your computer or mobile device as you navigate our Platform or interact with emails or other communications we have sent you. The information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, help us provide and improve our Services, and ensure the proper functioning and security of the Platform and Services.

Further, we may collect certain information regarding your use of the Platform and Services, such as the domain name and the name of the web page from which you entered the Platform or Service, when you click on a page or other resources, how much time you spend on each of our pages, and your IP address.

Does this Privacy Policy Apply to Third Party Sites?

Our Platform and Services may contain links to other sites that are not operated by Veta Health. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy(ies) of every site you visit. Veta Health has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. This Privacy Policy does not apply to your use of or access to any third-party sites or services.

Please note that if you choose to link our Services to a third-party account, such as social media or an online forum, we may receive information about you, including your profile information, your photo, and your use of the third-party account. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

How Does Veta Health Collect Your Personal Data?

Veta Health’s collection and processing of your Personal Data depends on how you use our Services. Below are some examples of how Veta Health may collect your Personal Data:

When You Register as a User or Otherwise Use Our Services. We may collect Personal Data when you register as a user.
When You Contact Us or Subscribe to Our Mailing List. We may collect Personal Data when you communicate with us, including when you submit information through the Site or contact us to ask questions. We may also collect Personal Data when you subscribe to our mailing list, including newsletters, updates, white papers, or other information and content. If you receive emails from us, we may use certain analytics tools to capture data, such as when you open our email or click on any links or banners in the emails. This data can help us gauge the effectiveness of our communications and marketing campaigns.
When We Collect Data from Third Parties. From time to time, we may use or augment your Personal Data with information obtained from third parties. For example, we may use third-party information to confirm contact information, verify eligibility, or to better understand your interests based on demographic information. If you choose to link your Veta Health account to other devices or services, such as smart devices, wearables, or other health monitoring devices, we may collect information on your use of such services or devices. We may combine Personal Data with data we obtain from our Services, other users, or third parties to enhance your experience and improve the services. If these services or devices are administered by a third party, we cannot warrant or guarantee the accuracy of the information.

How Does Veta Health Collect Your Personal Data?

Veta Health processes your Personal Data based on legitimate business interests, the fulfillment of our Services to you, compliance with our legal obligations, and/or your consent. We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill those purposes described in this Privacy Policy. Where required by law, we will ask for your prior consent before disclosing your Personal Data to a third party.

More specifically, Veta Health processes your Personal Data for the following legitimate business purposes:

To provide the Site, Platform, and/or Services;
To fulfill our obligations to you under the Terms of Use;
To communicate with you regarding the Services, including to facilitate your communications with Patient Users and to provide you with important notices regarding Service updates, this Privacy Policy, and our Terms of Use.
To communicate with you about and manage your User Account, including verifying your identity and authenticating and authorizing access to the Site, Platform, and/or Services;
To properly store and track your data within our system;
To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings and court orders;
To protect our rights, privacy, safety, or property, and/or that of you or others by providing proper notices, pursuing available legal remedies, and acting to limit our damages;
To handle technical support and other requests from you, including providing customer support and addressing or responding to your requests, inquiries, and complaints;
To enforce and ensure your compliance with our Terms of Use or the terms of any other applicable services agreement we have with you;
To manage and improve our operations and the Platform, including the development of additional functionality and tailoring the features, performance, and support of the Site and Services;
For statistical and analytical purposes;
To evaluate the quality of service you receive, identify usage trends, and improve your user experience;
To contact you for market research purposes;
For internal record keeping purposes related to purchases and transactions;
To find and prevent fraud, and keep our Platform safe and secure;
To send you information about changes to our terms, conditions, and policies;
To allow us to pursue available remedies or limit the damages that we may sustain; and
For other purposes for which we provide specific notice at the time the information is collected.

Does Veta Health Use Personal Data for Analytics or Collect Personal Data Through Automated Tools?

Veta Health uses third-party service providers to monitor and analyze the use of the Platform as part of our Services. The analytics services and automated tools we use may include, but are not limited to, Google Analytics and Mixpanel.

The Platform may send aggregated, non-Personal Data to Google Analytics and Mixpanel for the purpose of providing Veta Health with the ability to conduct technical and statistical analysis on the Platform’s performance. To opt-out of being tracked by Google Analytics across all websites, click here.

Where Is Personal Data Processed?

Veta Health may store the Personal Data it processes about you in the United States. When we do this, if you are located outside of the United States, the transfer of Personal Data is necessary to provide you with the requested information and Services and/or to perform any requested transaction. We will only transfer your Personal Data using appropriate safeguards, such as standard contractual clauses adopted by the European Commission. By using any portion of the Services, you acknowledge and consent to the transfer of your information to our facilities in the United States.

With Whom Does Veta Health Share Personal Data?

We may share your personal information with the following categories of individuals/entities:

Business Partners and Vendors: We share Personal Data with a limited number of partners, service providers, and other persons/entities who help run our business (“Business Partners”). Specifically, we may employ third-party companies and individuals to facilitate our Services, provide Services on our behalf, perform Service-related functions, or assist us in analyzing how our Services are used. Our Business Partners are contractually bound to protect your Personal Data and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT services, customer services, order fulfillment, and payment processing.

Our Advisors: We may share your Personal Data with third parties that provide advisory services to Veta Health, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively, “Advisors”). Personal Data will only be shared with Advisors if Veta Health has a legitimate business interest in the sharing of such data.

Third Parties Upon Your Direction or Consent: You may direct Veta Health to share your Personal Data with third parties. Upon your request and consent, we may share such Personal Data with those third parties that you identify.

Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Veta Health’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may share your Personal Data with a third party.

Government and Law Enforcement Authorities: If reasonable and necessary, we may share your Personal Data to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Privacy Policy or the Terms of Use; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of Veta Health or any third party, including other users of our Services. We may disclose Personal Data if it is necessary or appropriate to protect the rights, property, or safety of Veta Health, our customers, or others.

How Long Does Veta Health Retain Personal Data?

Veta Health retains your Personal Data only if necessary and as required for our business operations, the provision of Services, archival purposes, and/or to satisfy legal requirements. The exact period of retention (the “Retention Period”) will depend on: (i) the amount, nature, and sensitivity of the Personal Data; (ii) the personal risk of harm for unauthorized use or disclosure; (iii) the purposes for which we process your Personal Data, including whether those purposes can be achieved through other means; and (iv) business operations and legal requirements

At the end of the applicable Retention Period, we will remove your Personal Data from our databases and will require that our Business Partners remove any identifiable Personal Data from their databases. If there is any data that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing of such data. Please note that once we disclose your Personal Data to third parties, we may not be able to access that Personal Data and we cannot force the deletion or modification of such information by third parties.

Veta Health and its Business Partners reserve the right to continue using de-identified data indefinitely, even after Personal Data has been removed from Veta Health’s databases. We may continue to disclose de-identified data to third parties in a manner that does not reveal personal information, as described in this Privacy Policy. Our continued use of de-identified data will comport with applicable law.

What Happens to Personal Data Submitted by Minors?

Veta Health does not knowingly collect Personal Data from individuals under the age of 18. Additionally, our Services are not directed to individuals under the age of 18. We request that these individuals not provide Personal Data to us. If we learn that Personal Data from users under the age of 18 has been collected, we will deactivate the User Account associated with that data and take reasonable measures to promptly delete such data from our records. If you are aware of a user under the age of 18 accessing the Services or Platform, please contact us at compliance@myvetahealth.com

If you are a resident of California under the age of 18 and have registered for a User Account with us, you may ask us to remove content or information that you have posted to our Platform.

User Rights

What Happens to Personal Data Submitted by Minors?

As a user of Veta Health’s Services and Platform, you may have certain rights relating to your Personal Data. These rights are subject to local data protection and privacy laws, and may include the right to:

Request access to, modification or rectification, or erasure. You may have the right to access your Personal Data, correct inaccuracies in your Personal Data, and request the erasure of your Personal Data.
Request restriction of processing. In certain circumstances, you may have the right to restrict the processing of your Personal Data.
Object to processing. In certain circumstances, you may have the right to object to our processing of your Personal Data, such as a request to stop the processing of your Personal Data for marketing purposes. To opt-out of marketing communications, please see the instructions in the “How Can Users Withdraw Their Consent” section of this Policy.
Data portability. In certain circumstances, you may have the right to receive Personal Data concerning you that you provided to us and request that we transmit your Personal Data to another data controller.
Receive Communications. You have the right to receive communications related to the processing of your Personal Data.
Data Transfer. You have the right to request that your Personal Data be transferred to a third party, if possible.
Lodge a complaint. You have the right to lodge a complaint with a supervisory data protection authority.

Where the processing of your Personal Data by Veta Health is based on consent, you have the right to withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the above rights, please contact us at compliance@myvetahealth.com

Exercising Rights: To exercise your rights, you may send an email to compliance@myvetahealth.com. As permitted by law, certain data elements may not be subject to access, modification, erasure, restriction, and/or portability. We will make reasonable efforts to respond to and accommodate requests as soon as practicable and as required by law. To protect your privacy and security, we may take steps to verify your identity in order to respond to your request.

How Can Users Withdraw Their Consent?

Where the basis of processing is legitimate interest, you have a right to object to the processing of your Personal Data. Please note that, subject to applicable law, we may continue to process your Personal Data even where you object if there are compelling legitimate grounds for processing that override your interests and rights, or where processing is necessary to establish, exercise, or defend legal claims.

If we are relying on your consent to process your Personal Data, you have the right to withdraw your consent you provided for the processing of your Personal Data at any time by contacting us at compliance@myvetahealth.com with “Withdraw Consent” in the subject line, provided that we are not required by applicable law or professional standards to retain such information. Please note that if you withdraw your consent, we will not be able to provide you with access to the Platform and Services.

How Can Users Update, Correct, or Delete Personal Data or Their User Account?

You have the right to request restrictions on uses and disclosures of your Personal Data. While we are not required to agree to all restriction requests, we will attempt to accommodate reasonable requests when appropriate.

You may change your email address and other contact information by accessing your Veta Health User Account. If you need to make changes or corrections to other information, you may contact us at compliance@myvetahealth.com. To comply with certain requests to limit use of your Personal Data, we may need to terminate your ability to access and/or use some or all of the Services. BY REQUESTING TO LIMIT USE OF YOUR PERSONAL DATA OR DELETE PERSONAL DATA, YOU ACKNOWLEDGE AND AGREE THAT VETA HEALTH WILL NOT BE LIABLE TO YOU FOR ANY CORRESPONDING LIMITATION IN THE SCOPE OF SERVICES OR TERMINATION OF SERVICES AS NECESSARY TO COMPLY WITH YOUR REQUEST.

You have the right to request deletion of any Personal Data from your User Account or the Platform. To request deletion of your Personal Data, please email us at compliance@myvetahealth.com and include a description of the Personal Data you would like removed. We will respond to all requests for data deletion as soon as reasonably possible.

Should you decide to delete your User Account entirely, you may do so through your User Account dashboard and by emailing compliance@myvetahealth.com. By terminating your User Account, you agree that you will not be able to access any information previously contained in your User Account. You further understand that it may not be technologically possible to remove all of your Personal Data from our systems. While we will use reasonable efforts to remove your Personal Data, the need to back up our systems to protect information from inadvertent loss means a copy of your Personal Data may exist in a non-erasable form that will be difficult or impossible for us to locate or remove.

Protection Of Personal Data

Is Personal Data Secure?

Veta Health understands the importance of data confidentiality and security. We use a combination of reasonable physical, technical, and administrative security controls to: (i) maintain the security and integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of your Personal Data; and (iii) protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm to you.

While Veta Health uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT SUCH TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TO YOUR PERSONAL DATA. VETA HEALTH IS UNABLE TO GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA TRANSMITTED OVER THE INTERNET, AND THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA AT ANY TIME.

How Can Users Protect Their Personal Data?

You are solely responsible for preventing unauthorized access to your devices and your User Account by protecting your account credentials and limiting access to your devices. Veta Health has no access to or control over your device’s security settings, and it is your responsibility to implement any device-level security features and protections you feel are appropriate (e.g., password protection, encryption, remote wipe capability). We recommend that you take all appropriate steps to secure any device that you use to access our Services and Platform.

Please note that Veta Health will never send you an email requesting confidential information, such as account numbers, usernames, passwords, or Social Security Numbers. If you receive a suspicious email from Veta Health, please notify us at compliance@myvetahealth.com.

Further, if you know of or suspect any unauthorized use or disclosure of your User Account information or any other security concern, please notify Veta Health immediately.

What If Veta Health Experiences a Data or Security Breach?

Veta Health takes the security of your Personal Data seriously. In the event of a data or security breach, Veta Health will take the following actions: (i) promptly investigate the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities within Veta Health’s control which may have given rise to the security incident; (ii) comply with laws and regulations directly applicable to Veta Health in connection with such security incident; (iii) as applicable, cooperate with any affected Veta Health user or client in accordance with the terms of Veta Health’s contract with such user or client; and (iv) document and record actions taken by Veta Health in connection with the security incident and conduct a post-incident review of the circumstances related to the incident and actions/recommendations taken to prevent similar security incidents in the future. Veta Health will notify you of any data or security breaches as required by and in accordance with applicable law.

Advertising, Marketing, and Tracking

Does Veta Health Send Marketing or Advertisement Materials?

Veta Health may use your Personal Data to contact you with newsletters, marketing, or promotion materials and other information that may be of interest to you. We will not use your Personal Data to send commercial or marketing messages to you unless we have your consent or other lawful basis to do so. If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you can do so at any time by clicking on the unsubscribe link in the emails that we send or by sending an email to hello@myvetahealth.com with “Opt-Out Request” in the subject line. Likewise, should you opt-in to receiving text messages from us or our affiliates, you can also opt-out at any time by following the instructions or contacting us. For more information on text messaging, please review our Terms of Use. Please be advised that you may not be able to opt-out of receiving certain messages from us, including legal notices.

Can Users Opt Out of Receiving Communications from Veta Health?

We may send communications, including emails, to you regarding your User Account and the Services or Platform. You can choose to filter any User Account, Services, and Platform emails using your email settings, but we do not provide an option for you to opt out of these communications.

If you consent to receive marketing or other communications not related to your User Account or the Services/Platform, we will provide you with the option to opt out of such marketing communications within the applicable message.

What Is Veta Health’s Cookie Policy?

Cookies are small files that a web server sends to your computer or device when you visit a web application that uses cookies to keep track of your activity on that site. Cookies also exist within applications when a browser is needed to view or display certain content within the application. Cookies hold a small amount of data specific to a web application, which can later be used to help remember information you entered in the application (like your email or username), preferences selected, and movement within the application. We use cookies and other technologies to, among other things, better serve you with more tailored information, and to facilitate efficient and secure access to the Services.

Cookies can be classified as either “session” or “persistent” depending on how long they last after they are placed on your browser. We may use both. Our cookies do not, by themselves, contain Personal Data. Further, we do not combine the general information collected through cookies with any other Personal Data to identify you. However, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your User Account (if one exists).

In addition, Veta Health may also collect information using pixel tags, web beacons, clear GIFs, or other similar technologies. This information may be used in connection with website pages and HTML formatted email messages to, among other things, track the actions of users and email recipients and compile statistics about usage and response rates.

How Can Users Opt Out of Cookies?

If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you enable a do not track signal or otherwise configure your browsers to prevent us from collecting cookies, you will need to re enter your login information each time you visit the login page. You may also be unable to take advantage of some of the Services.

Do Not Track Disclosure

Some web browsers may transmit do not track (“DNT”) signals to websites with which the User communicates. DNT is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. To date, there is no industry standard for DNT and users cannot know how a given company responds to a DNT signal they receive from browsers. Veta Health is committed to remaining apprised of DNT standards. However, Veta Health does not support DNT browser settings and does not currently participate in any DNT frameworks that would allow Veta Health to respond to signals or other mechanisms regarding the collection of your personal information.

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may apply to you. Please see the CCPA Attachment for an explanation of your rights.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and obtain from us an annual list identifying the categories of personal customer information which we shared, if any, with our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will be provided free of charge. Contact information for such affiliates and/or third parties must be included. If you are a California resident and would like a copy of this notice, please submit a written request to the address provided below.

Contact Us

If you have questions regarding this Privacy Policy, you may contact us at compliance@myvetahealth.com with “Privacy Policy” in the subject line.