This policy applies to information we collect:
- On our Website and Application.
- In emails, text message, phone conversations, audio and video interactions and other electronic messages between you and our Website and Application.
- When you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by VIRTUAL DOCTORS TELEHEALTH or any third party.
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application.
- Children Under the Age of 18.
- Information We Collect About You and How We Collect It.
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
We collect several types of information from and about users of our Website and Application (collectively, “Individual Personal Information”), specifically information:
- By which you may be personally identified, such as name, address, e-mail address, home, work, and mobile telephone numbers, date of birth, credit or debit card number (for payment purposes only), audio (including recordings and transcripts), images and videos of you, gender, Social Security Number, your medical history, health insurance subscriber information, and health information. Payment Information, Device/IP Information, Web Analytics, Geolocation Data, Other Identifying Information That You Voluntarily, Providers Services information, User Contact Data, User Demographic Data, Medical Data, Insurance Information, Booking Appointment Data, Social Network Data
- About your Internet connection, the equipment you use to access our website or use our application and usage details, such as traffic data, logs, referring/exit pages, date and time of your visit to our website or use of our application, error information, click stream data, and other communication data and the resources that you access and use on the Website or through our application.
We collect this information
- Directly from you when you provide it to us.
- Automatically as you navigate through the Website or use our application. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and from third parties, for example, our business partners.
Healthcare Provider Personal Data
Payment Information, Device/IP Information, Web Analytics, Geolocation Data, Other Identifying Information That You Voluntarily, Healthcare Provider Contact Data, Healthcare Provider Demographic Data and Professional License Information
Information You Provide to Us
The information we collect on or through our website or through our application is:
- Information that you provide by filling in forms on our website or the Application videos, images and recordings when interacting with a Provider on our Website or the Application. This includes information provided at the time of registering to use our website or Application as well as information provided when using our Provider consultation services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our website or Application.
- Records and copies of your correspondence (including email addresses), if you contact us;
- Details of transactions you carry out through our website or through the Application and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our website or Application
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or Application or transmitted to other users of the Website or Application or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website and Application with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. The audio portion of your medical telehealth visit (including audio from visits that include video) is recorded for purposes which may include treatment, quality, improvement of health status, customer and patient experience, customer, and patient engagement and/or behavior modification, peer review, payment, efficiency, cost effectiveness and/or other purposes relating to operations and provision of telehealth services. Behavioral health visits are not recorded. By using the telehealth services available through our Website and Application you specifically consent to the recording of the medical visit.
Information We Collect through Automatic Data Collection Technologies
As you navigate through and interact with our Website and Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
- Details of your access to and use of the Application and Website, including traffic data, location data, logs, and other communication data and the resources that the end user accesses and uses on or through the Application and Website.
- Information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
- Information stored on your mobile device, including in other applications. This may include, photographs, audio and video clips, personal contacts, and health information. In particular, we may collect information through your application. This data will be used only to provide and improve our services, and will not be used or shared with third parties for marketing purposes;
- Real-time information about the location of your device.
The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and Application and to deliver a better and more personalized service by enabling us to:
- Estimate our audience size and usage patterns.
- Forecast future needs, functions, and uses of our services, the Website, and the Application.
- Better understand user satisfaction levels and experiences
- Store information about your preferences, allowing us to customize our Website and our Application according to your individual interests.
- Recognize you when you return to our Website and our Application.
- In other ways to improve your experience and the quality of our Website, Application, and services.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website and Application may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Web site and Application. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.
- We use Facebook Pixel, a web analytics and advertising service provided by Facebook Inc.(“Facebook”) on our Website and Application. With its help, we can keep track of what users do after they see or click on a Facebook advertisement, keep track of users who access our Website and Application or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel is also saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel https://www.facebook.com/settings/?tab=ads#_=_.Please also refer to Choices About How We Use and Disclose Your Information below for more information about tracking technologies, targeted advertising and your choices relating to the use of your information for these purposes.
- Other Third Party Cookies: We encourage you to review the privacy policies of the other third party cookies deployed on our Website and Application, including Live Ramp’s (https://liveramp.com/privacy/service-privacy-policy/)and Adobe’s (https://www.adobe.com/privacy/policy.html).
- How We Use Your Information.
We use your Personal Information for various purposes described below, including to:
- Provide our website or Application to you.
- Provide services to you.
- Provide you with information you request from us.
- Enforce our rights arising from contracts.
- Notify you about changes
- Provide you with notices about your account.
We use information that we collect about you or that you provide to us, including any Personal Information:
- To provide and improve our Website, Application, products, and services. For example, we may convert our recordings to text and perform machine learning on data we receive.
- To provide you with information, products, or services that you request from us or that may be of interest to you
- For purposes of treatment, quality, improvement of health status, customer and patient experience, customer, and patient engagement and/or behavior modification, peer review, payment, efficiency, cost effectiveness and/or other purposes relating to operations and provision of telehealth services.
- To process, fulfill, support, and administer transactions and orders for products and services ordered by you.
- To provide you with notices about your VIRTUAL DOCTORS TELEHEALTH account.
- To contact you in response to a request.
- To administer surveys.
- To fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us or between us and health plans or other benefit programs, including for billing and collection.
- To notify you about changes to our website, our application, or any products or services we offer or provide though them.
- In any other way we may describe when you provide the information;
- For any other purpose with your consent.
We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications.
Some information VIRTUAL DOCTORS TELEHEALTH collectsconstitutes protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). As set forth above, VIRTUAL DOCTORS TELEHEALTH (or your own medical provider if you do not use a VIRTUAL DOCTORS TELEHEALTH Medical Provider) will provide you with a Notice of Privacy Practices describing its collection, use and disclosure of your PHI, not VIRTUAL DOCTORS TELEHEALTH. VIRTUAL DOCTORS TELEHEALTH is a “business associate” (as that term is used under HIPAA) that provides services to and for VIRTUAL DOCTORS TELEHEALTH Medical Group, other health care providers and health care plans, referred to as “covered entities” under HIPAA, and enters into business associate agreements with these covered entities. VIRTUAL DOCTORS TELEHEALTH will use and disclose PHI only in accordance with the business associate agreements and HIPAA. We may de-identify your Personal Information so that it no longer reasonably identifies you. In this case, we may use this de-identified data without restriction and for any purpose, including to improve our Website, Application, and products and services.
Keeping Data Confidential
We place strict controls over our employees’ access to user data and have technical controls and audit policies in place to ensure the confidentiality, integrity, and availability of user data. Our employees and contracted personnel working with any user data are bound to our policies, and we treat these issues as matters of the highest importance.
Privacy and Security Training
Everyone at VIRTUAL DOCTORS TELEHEALTH receives regular training to ensure that we remain focused on privacy and security. This includes privacy training that covers the Health Insurance Portability and Accountability Act (“HIPAA”), which establishes national standards for protecting the identifiable health information of health plan beneficiaries and patients, and other relevant state and federal laws. We also ensure that our employees receive annual data security training, regardless of their role in the company.
Certifications and Audits
VIRTUAL DOCTORS TELEHEALTH works with outside experts to maintain high standards and rigorous security practices. We hire third parties to test our services and processes as part of our recurring penetration testing program.
We employ industry standard technology to safeguard data. Our platform uses full volume encryption on all data stored at rest, with secure backups and robust backup policies. We also use Transport Layer Security (TLS) connections to transmit data over HTTPS.
VIRTUAL DOCTORS TELEHEALTH leverages secure cloud computing, including Google Cloud platform (GCP), to store data in physically and electronically secure facilities. For a list of all current GCP security accreditations, see the GCP Compliance Programs page.
In addition to sophisticated system monitoring and logging, we utilize robust administrative identity, authorization, accountability, and authentication controls (including multi-factor authentication), as well as intrusion prevention and detection controls to protect our platform.
We have a vulnerability management policy that covers internal and external testing, including annual third-party penetration testing, to find and remediate vulnerabilities that may present a risk to our platform or data.
Logging and Monitoring
VIRTUAL DOCTORS TELEHEALTH operates an extensive security information and events management system. VIRTUAL DOCTORS TELEHEALTH maintains a centralized logging environment, which contains events pertaining to security, monitoring, availability, access, and other metrics about the platform. We review our logging and monitoring systems regularly and respond promptly to automatic alerts.
Incident Management & Response
VIRTUAL DOCTORS TELEHEALTH has incident management policies and procedures in place in the event of a security breach. This includes notifying users of any unauthorized access to their data in the event of a breach as defined under relevant state laws.
Product Security Practices
New features, functionality, and design changes go through a security review process facilitated by the VIRTUAL DOCTORS TELEHEALTH development team. We utilize automated static analysis software, and our teams manually peer-review code prior to being deployed to production. The Information Security team works closely with development teams to resolve any security concerns that may arise during development.
- Disclosure of Your Information
Payment Information, Device/IP Information, Web Analytics, Geolocation Data, Other Identifying Information That You Voluntarily, Healthcare Provider Contact Data, Healthcare Provider Demographic Data and Professional License Information
- Our affiliates and third-party service providers that we use to support our business
- To a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form.
- To comply with our legal obligations.
- To enforce our rights
- With your consent
- To affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, and ordering, marketing, and payment processing services.
- 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by VIRTUAL DOCTORS TELEHEALTH aboutour Website and Application users are among the assets transferred.
- To fulfill the purpose for which you provide it. For example, we may disclose your personal information to a Provider
- For any other purpose disclosed by us when you provide the information.
- With your consent,We may also disclose your Personal Information.
- 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 VIRTUAL DOCTORS TELEHEALTH, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Choices About How We Use and Disclose Your Information
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising.We do not control the collection and use of your information collected by third parties. We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information:
- Promotional Offers from VIRTUAL DOCTORS TELEHEALTH. If you do not wish to have your email address used by VIRTUAL DOCTORS TELEHEALTH to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any promotional emails or other marketing communications you receive from us. This opt out does not apply to information provided to VIRTUAL DOCTORS TELEHEALTH as a result of a product purchase, or your use of our services.
- Location Information. You can choose whether or not to allow the Application to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Application may then be inaccessible or not function properly.
- Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may review and change your Personal Information by logging into the Application or Website and visiting your User Preferences page.You can review and change your Personal Information by logging into our Website or Application and visiting either the Account Details section of our Application or Website. You may also notify us through the Contact Information below of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.With respect to any PHI in our possession, you have certain rights under HIPAA as described in the Notice of Privacy Practices provided to you by your healthcare Provider.
- Do Not Track Signals
We currently do not use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not automatically honor such signals. However, please review other portions of this Policy regarding your ability to disable tracking technologies.
- Data Security
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Information. You can help protect your Personal Information and other information by keeping your password to our website confidential.We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use application timeouts and encryption technology for information sent and received by us.The safety and security of your information also depends on you. Where you have chosen a password for the use of our website or Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.Unfortunately, the transmission of information via the Internet is not completely secure. Although we work diligently to try and protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our website or on or through our application. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the Application.
- California Privacy Rights
Categories of Sources from which VIRTUAL DOCTORS TELEHEALTH has collected Personal Information:
We collect Personal Information directly from you, for example when you provide it to us to when you contact us to our Website for Application, for create an VIRTUAL DOCTORS TELEHEALTH account; and indirectly from you automatically through your computer or device as you use our Website or Application. We may also collect Personal Information about you from our advertising partners and service providers.
Use of Personal Information:
Sharing Personal Information
VIRTUAL DOCTORS TELEHEALTH may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, such as to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for Business Purposes:
We may disclose your Personal Information for our business purposes, such as your contact information, other information you have provided to us and unique identifiers that identify you to us or to our service providers, such as companies that assist us with marketing and advertising.We disclose your Personal Information to certain third parties such as our health care Provider partners, service providers, including companies that assist us with marketing and advertising.
Access Request Rights
You have the right to request that VIRTUAL DOCTORS TELEHEALTH disclose certain information to you about our collection and use of your Personal Information over the past 12 months for the above business and commercial purposes. To submit an access request, see Exercising Access and Deletion Rights. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing.
- Sales, identifying the Personal Information categories that each category of recipient purchased.
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that VIRTUAL DOCTORS TELEHEALTH delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless certain exceptions apply.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
- Emailing us at firstname.lastname@example.org Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must.
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g., requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please contact us by email at email@example.com