Last updated: July 18, 2019
Veta Health, LLC. (“Veta Health,” “Company,” “Us,” “Our,” and “We”) is a service that enables patients to engage in clinically-validated care plans with their doctors, care teams, and other healthcare providers.
For patients, Veta Health provides you with access to your health data, along with interpretation and analytics tools (collectively the “Services”) to help you understand and actively participate in your personal health management. For care partners, Veta Health provides a tool to allow family members and/or contributors to be an active participant in the patient’s health.
For healthcare providers, Veta Health provides a platform to facilitate care coordination through data sharing and to enable remote patient monitoring for improved patient management and engagement.
For health organizations, Veta Health offers tools designed to streamline workflows and care coordination along with the ability to measure system wide performance to improve care efficiency and outcomes.
For the purposes of the Policy (as defined below), patients, care partners, healthcare providers, and health organizations may collectively be referred to as “Users.”
This Policy describes:
- What Information Do We Gather?
- What Do We Do With the Information We Collect?
- How Do We Share the Information We Collect?
- How Do We Protect the Personal Information We Collect?
- How Do I Make Choices and Select Privacy Preferences Regarding Marketing?
- Do Not Track Disclosure
- How Do You Correct and Update Your Personal Information?
- What Happens When You Link to a Third-Party Website?
- Your California Privacy Rights
- Your International Privacy Rights
- What If You Have Questions?
1. What Information Do We Gather?
1. Information Consumers Provide to Us
In order for Veta Health to help consumers become active participants in health management, we need to collect certain information about you whenever you interact with and/or use our Services or Platforms. This information includes Non-Personal and Personal Information. For purposes of this Policy:
“Non-Personal Information” refers to information that may not by itself be reasonably associated with, linked to, or used to individually identify you. For example, general, non-specific Information regarding your use of the Platform or derived from the Information that you provide to us through the Platform.
“Personal Information’’ refers to information about you that alone or in combination with other information may be used to readily identify, locate, or contact a specific person and includes: full name, address, phone numbers, email address, medical records or other health data, insurance information, financial and/or payment information (if applicable).
You may provide us with Personal Information when you:
- Request information
- Contact us
- Subscribe to our newsletter
- Register with the Platforms
- Update your profile
The information we gather allows us to personalize and improve our Services or Platforms. The information we gather may include, but is not limited to:
- Name, username and password
- Contact information, including physical address, email address and phone number
- Medical records and other health data and insurance information
If you are a patient of a Healthcare Provider who has subscribed to the Services, we collect Personal Information about you when your Healthcare Provider invites you to use the Services. We also collect Personal Information about you when you provide it during the User registration process and as you enter information on our Platforms and/or create a Veta Health account and build your personal profile.
If you are an individual authorized by a Patient to use the Services to contribute and monitor the Patient’s health, (“Care Partner”), we collect Personal Information about you, including, without limitation, your name, email address, phone number and your relationship to the Patient.
The information that you provide in each case and on each Platform will vary. In some cases, we may ask you to create a username and password that should only be known to you.
As a consumer, contingent upon your and your healthcare provider’s consent, we will collect information directly from your personal health record maintained by your healthcare provider to build your health profile. From time to time, we may use or augment your Personal Information 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 calendars, smart devices, wearables, or other health monitoring devices, we may collect information to your use of such services or devices. If these services or devices are administered by a third party, the applicable information practices are the responsibility of that third party. We cannot warrant or guarantee the accuracy of this information.
As a healthcare provider, we may have information about you from your healthcare organization of which you are an employee or agent. We cannot warrant or guarantee the accuracy of this information.
Important Notice About Your Health Information: As a consumer, you should understand that much of the Personal Information you provide may be related to your health, including diagnoses, x-rays, and conditions. Veta Health is not a healthcare provider. Veta Health is a business that facilitates the reviewability and portability of your health information. The Platforms are convenience tools, not substitutes for consultation with a doctor. Unless otherwise established in an agreement between Veta Health and a Covered Entity (i.e., a doctor, pharmacy, or insurer) as defined by the Health Insurance Portability and Accountability Act (“HIPAA”), Veta Health does not collect “Protected Health Information” as defined under HIPAA. HIPAA provides for certain privacy and security requirements relating to the use and disclosure of Protected Health Information. Personal Information that consumers provide to us (such as insurance receipts, grocery lists, etc.) is generally not Protected Health Information and therefore not subject to HIPAA. Regardless, your Personal Information will be handled in accordance with this Policy. Any Protected Health Information we receive from your provider or health organization will be handled in accordance with the provisions of HIPAA and the business associate agreement between your provider or health organization and Veta Health. Questions or concerns about your medical record or the Protected Health Information provided to Veta Health by your Healthcare Provider or Health Organization should be directed to either, respectively. Such information is not under the direct control of Veta Health.
2. Information We Collect Through Automated Tools
We may also track certain information regarding your use of the Platforms such as the domain name and the name of the web page from which you entered our Platforms, when you click on a page or other resources, and how much time you spend on each of our pages and your IP address. An IP address is a number that is assigned to your computer when you are using your browser on the Internet. We may collect such usage information from you when you visit our Platforms via the use of “cookies” or other automated data collection tools
One trusted third-party partner we use is Google Analytics. The Platforms may send aggregated, non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Platforms’ performance. To opt-out of being tracked by Google Analytics across all websites, click here.
2. What Do We Do With the Personal Information We Collect?
You will be asked to provide Personal Information in certain fields on the Platforms that allow you to use our Services or Platforms. The Personal Information we collect is used only for the purpose we state at the time of collection or for purposes contained below. Our uses may include, but are not limited to, the following:
- We may use your information, including your Personal Information, to provide you with the Services we make available on the Platforms.
- We may use your email address to contact you about new features on the Platforms, or to provide you with other information that is relevant to your use of the Platforms.
- We may use your information for internal record keeping purposes related to purchases and transactions.
- We or our affiliates may periodically send you promotional emails about new products, special offers or other information which we believe may be of interest using the email address provided.
- We may communicate with you through our Veta Health platform or other means enabled by the Services, such as text messages, push-notifications, or in-app messaging.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.
- We may use your information to customize the Platforms according to your interests.
- We may provide your information to our partner networks or your primary care physician in a manner consistent with federal and local laws.
- We may disclose your information to implement and enforce our Terms of Service.
- We may disclose your information to respond to subpoenas, judicial processes, or government requests or investigations.
- We may use your information to protect the security of our services, servers, network systems and databases or to protect our users and affiliates against liability or harm.
We may de-identify your Personal Information and aggregate that de-identified information with other de-identified information collected through the Platforms. We may use de-identified data and share it with third parties to enhance or develop our Platforms, our other products and services, and our business operations for marketing, to conduct research and analysis, or for other lawful business purposes.
We will not use your Personal Information to send commercial or marketing messages to you unless we have your consent. You will always have the ability to opt-out of such messaging at any time by sending an email to firstname.lastname@example.org. In your request, please make clear that you would like to opt-out with “Opt-Out Request” in the subject line, whether you would like to have your Personal Information deleted from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information.
3. How Do We Share the Information We Collect?
- To provide you with the Platforms and related services or otherwise to fulfill the purpose for which you provide it.
- To contractors, service providers and other third parties we use to support our business. For example, should you opt-in to receiving text messages, we share mobile phone numbers that you provide to us with a third party vendor to send automated SMS messages to your mobile device.
- To your family members or caregivers when Users add a family member or caregiver to your account.
- To your healthcare provider.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Veta Health’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
- If you choose to allow Veta Health to share information with others, we may also use your Personal Information to communicate with others at your request. You can adjust your communication preferences in your Veta Health account settings or by unsubscribing to our marketing emails.
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Veta Health, our customers or others.
- For any other purpose disclosed by us when you provide the information.
Non-Personal Information: We may use or disclose the Non-Personal Information we collect and obtain for any lawful business purpose without any duty or obligation of accounting other wise to you, provided that the information remains Non-Personal Information.
4. How Do We Protect the Personal Information We Collect?
The privacy and the security of your Personal Information is important to us. We have established reasonable and appropriate technical, physical and administrative safeguards designed to protect the information we collect. However, the security of information transmitted through the Internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. Users of the Platforms are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our Platforms. In order to protect you and your data, we may suspend your use of the Platforms, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of the Platforms are restricted to authorized users only. Unauthorized access to such areas is prohibited.
5. How Do I Make Choices and Select Privacy Preferences Regarding Marketing?
We want to provide you with relevant information that you have requested. We may give you the opportunity to opt out of having your Personal Information used or shared for certain purposes otherwise permitted by this Policy.
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Any transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services and are not intended for the purposes of marketing.
We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt-out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
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 Service.
Any such communications you receive from us will be administered in accordance with your preferences and this Policy.
You can also opt-out of our marketing emails at any time by contacting us at email@example.com.
6. Do Not Track Disclosure
We do not support Do Not Track with respect to the Platforms at this time. Do Not Track 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. For details, including how to turn on Do Not Track, visit www.donottrack.us. Other than as disclosed in this Policy, the Platforms do not track Users over time and across third-party websites to provide targeted advertising.
7. How Do You Correct and Update Your Personal Information?
You can change or correct some of your account information at any time. Send an email with your old information and your corrections to firstname.lastname@example.org with “Correction” in the subject line. Veta Health will make reasonable efforts to accommodate your request for correction. Please note that some information in Veta is sent by your Healthcare Provider or Health Organization, and therefore not under the direct control of Veta Health. Please direct questions about your medical record or Protected Health Information to your Healthcare Provider or Health Organization.
We understand the importance of protecting the privacy of all individuals, especially the very young. Our Platforms are intended for United States audiences over the age of 18. We neither target nor sell our products to children under the age of 13, and we do not knowingly collect Personal Information from them. Subscribing to our online service is restricted to adults who are either 18 years of age or older or as otherwise legally defined.
9. What Happens When You Link to a Third-Party Website?
We may on occasion update our Policy. Your acceptance of any minor changes to this Policy is indicated by your continued use of our Services or Platforms. If we make any material changes to our Policy, we will message a notice about the change at a prominent location on the Platforms. We encourage you to periodically review our Platforms and this Policy for any changes.
11. Your California Privacy Rights
We will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
12. Additional Information for EU Residents
Veta Health is the controller of the personal data you submit through the Platforms and Services. We process personal data as necessary to pursue our legitimate interest of providing the Platforms and Services to you, to fulfill our contractual obligations to you and our customers or with your consent. You may have the right to access your personal data, correct inaccuracies in your personal data, request the erasure of your personal data and restrict the processing of your personal data. To access, rectify and erase your personal data, please send your request in reasonable detail to email@example.com. In addition, you have the right to lodge a complaint with a supervisory data protection authority. If the processing of your personal data is based on your consent, you may contact us at firstname.lastname@example.org to withdraw your consent with “Withdraw Consent” in the subject line. Please not that if you withdraw your consent we will not be able to provide you with access to the Platforms and Services.
If you are using the Services from the European Union, we will only transfer your personal data to the United States through the use of appropriate safeguards such as standard contractual clauses adopted by the European Commission or with your consent.
The Veta Health data protection officer can be contacted at:
IITR Datenschutz GmbH, Dr. Sebastian Kraska, Marienplatz 2, 80331 Munich
13. What If You Have Questions?