VIRTUA HEALTH, INC.
DIGITAL SERVICES PRIVACY STATEMENT
Last Updated: August 19, 2020
Virtua Health, Inc. and its subsidiaries and affiliates (“Virtua” or “we” or “us”) are committed to respecting your privacy and maintaining your trust. This Digital Services Privacy Statement will help you understand what information we collect, use, and share when you use certain websites, mobile apps, or other online or mobile technology or digital tools (collectively, the “Digital Services”) owned by us or made available by us through our Vendors and their subcontractors. Virtua owns or makes available many Digital Services. This Digital Services Privacy Statement applies only to Digital Services that display or link to it. We encourage you to carefully review this Digital Services Privacy Statement, which is incorporated into and made part of our Terms of Use.
Scope and Applicability
Virtua’s Digital Services Privacy Statement only addresses information that we receive through your use of the Digital Services. It is important to understand that this Digital Services Privacy Statement does not apply to information you provide or that we receive when we render medical care to you; such information is called “Protected Health Information” under the Health Insurance Portability and Accountability Act (“HIPAA”). Please note that Virtua’s HIPAA Notice of Privacy Practices is a separate document that governs how we protect and may use or disclose our patients’ Protected Health Information.
Collection and Storage of Information
Definitions
There are two types of data or information we may collect and then store in information technology (IT) systems when you access the Digital Services. They are:
• Personal Information – This is information that personally identifies you. Personal Information includes, but is not limited to, such things as your name, email address, phone number, postal address, credit and debit card numbers, and date of birth. How we may receive your Personal Information is discussed below under Personal Information You Provide to Us.
• Non-Personal Information – This is any data we receive from your access and use of the Digital Services that is not Personal Information. Examples of Non-Personal Information are discussed below under Non-Personal Information Collected Automatically.
Personal Information You Provide to Us
We collect Personal Information through the Digital Services when you voluntarily provide it, such as in the following scenarios:
• Subscribing to one of our newsletters or mailing lists;
• Paying for a Virtua-sponsored event (such as a support group or seminar) using your name and credit card;
• Sending us a text message for more information about our services; or
• Requesting that information about Virtua’s medical services be sent to you.
Of course, you can access and browse our Digital Services at any time without providing any Personal Information.
If you voluntarily provide us with your Personal Information, you agree that we may use and share your Personal Information in accordance with this Digital Services Privacy Statement.
If you provide us with Personal Information about other people through the Digital Services, you represent that you have the authority to do so and give us permission to collect, use, and share their Personal Information in accordance with this Digital Services Privacy Statement.
Non-Personal Information Collected Automatically
When you access or use the Digital Services, some Non-Personal Information is automatically collected. Non-Personal Information may include but is not limited to:
•The Internet domain (for example, "xcompany.com") and IP address (an IP address is a number automatically assigned to your computer when surfing the internet) from which you access the Digital Services;
• The Internet service provider, type of browser and operating system used to access the Digital Services;
• The date and time you accessed the Digital Services;
• Certain location information, such as your mobile device’s GPS signal or information about nearby WiFi access points and cell towers;
• Information about the links you click and pages you view within the Digital Services, and other standard server log information;
• The specific web pages that you visited; and
• Web pages that you visit before and after using the Digital Services.
This Non-Personal Information is collected through technologies such as cookies, pixel tags, local shared objects, and through analytics tools. Cookies are small bits of information that are stored by your computer’s web browser. The cookies we use for the purposes described below under Use of Personal and Non-Personal Information may be first-party cookies or third-party cookies. First-party cookies are issued directly by the website you are viewing. Third-party cookies are issued by someone other than the website you are viewing. For example, if you link to a Virtua.org website from another website, the cookies issued from that website are considered third-party cookies. Pixel tags are small images or small pieces of data embedded in images that can recognize cookies, the date and time a page is viewed, a description of the page where the pixel tag is placed and similar information from your computer or device. Local shared objects (sometimes called “flash cookies”) are similar to standard cookies except that they can be larger and are downloaded to a computer or mobile device by the Adobe Flash media player. By using our Digital Services, you are consenting to the storing and accessing of the cookies, pixel tags, local shared objects and other technologies on your device. Please note that you may be able to adjust your web browser settings to decline all cookies.
One of the analytics tools we use for our Digital Services is Google Analytics. For more information about how Google Analytics collects and processes data when you visit our Digital Services, please review Google’s Privacy and Terms by visiting this link. You may opt-out of Google Analytics by visiting this link. For some of our Digital Services, we may enable one or more Google Analytics Advertising Features, including: Remarketing with Analytics; Demographics and Interests Reporting; Campaign Manager Integration; Google Display Network Impression Reporting; and Segments. The Google Analytics Advertising Features use advertising cookies to tailor digital advertisements to your interests. You may opt-out of the Google advertising cookies by following the steps outlined in Google’s Privacy & Terms under “How you can control advertising cookies.”
Use of Personal and Non-Personal Information
We may use the Personal and Non-Personal Information we collect for many reasons, including but not limited to:
• Provide, improve and optimize the Digital Services;
• Respond to your comments, questions, and requests for information and provide customer service;
• Send you information about our medical and health and wellness services, products, and offerings, as well as our new initiatives, events and other news about our organization;
• Better understand you and your preferences so that we can personalize our interactions with you and provide you with materials and content that is relevant and tailored to your interests;
• Develop and send surveys and other interactive feedback tools to allow us to better understand your needs and concerns;
• Determine the effectiveness of our promotional and informational campaigns so that we can adapt our campaigns to the needs and interests of our users;
• Plan, administer, and coordinate events (such as seminars and support groups), community groups, and outreach activities;
•If you are a patient, send you a link to allow you to securely access or discuss with your provider your Protected Health Information and other confidential Personal Information;
•If you are a patient, send you appointment reminders or confirmations;
• Create aggregate and/or anonymized data of the Personal Information that we use for many purposes, including to better understand the interests and trends of our Digital Services users. Once Personal Information is aggregated or anonymized, it is no longer subject to this Digital Services Privacy Statement; and
• We may use or share Personal Information for a purpose not covered by this Digital Services Privacy Statement. Should that happen, we will tell you what that purpose is at the time we collect the Personal Information from you or obtain your consent to use the Personal Information for that new purpose.
We may combine the Personal and Non-Personal Information that we receive through the Digital Services with other data we receive about you for any of the purposes mentioned above. As one example, if you are a Virtua patient, we may combine the Personal Information you provide through the Digital Services with publicly available data and your Protected Health Information to provide a tailored communication to you. In such instances, your Protected Health Information will continue to be protected by HIPAA and we will only use and disclose your Protected Health Information in accordance with our HIPAA Notice of Privacy Practices.
Phone Calls and Texting: If you provide us with a phone number, we may communicate with you through phone calls and text messaging. We will only contact you via phone call or text message as permitted by federal and state laws. By providing us with your phone number, you expressly consent to us contacting you via phone call or text message for any of the purposes mentioned above at that phone number. This contact may include, but is not limited to, the use of pre-recorded/artificial voice messages, interactive voice recognition system, an automatic dialing device, and/or Short Message Service (SMS) text messaging. Message and data rates may apply for any text messages sent from us to you or from you to us. Contact your carrier for details. By providing us a phone number, you represent that it is your phone number or you have the authority to provide consent to receiving phone calls or text messages to that phone number.
We will send you text messages on an infrequent basis, unless you have opted-in to receive text messages from us relating to a particular topic(s) of interest to you, such as organizational announcements, general health information or emergency notifications. The frequency of these text message communications will be disclosed to you before you opt-in to such communications. You may opt-out of receiving text messages from us at any time by following the instructions outlined in the “Opt-Out Option” section of this Digital Services Privacy Statement.
Sharing Personal Information Outside of Virtua
As permitted by applicable laws and regulations, we may share Personal Information we receive about you through the Digital Services with individuals, companies or government agencies that are not employed or owned by Virtua, as described below:
•Vendors.We may share Personal Information with our vendors/service providers who help us provide certain business or administrative services (“Vendors”). Vendors may include companies that perform website hosting, data analysis, data storage, advertising, event registration, and communications delivery. Vendors may perform on our behalf any of the Personal Information collection, storage, use or transmission activities described in this Digital Services Privacy Statement. Our Vendors are not authorized to use or share your Personal Information other than to: (i) provide the duties we engage them for (either themselves or through their subcontractors); and (ii) to comply with legal requirements.
• Vendor subcontractors. Virtua requires any Vendor who has access to your Personal Information to require its subcontractors to adhere to the same confidentiality protections of your Personal Information as the Vendor itself must provide. In applicable circumstances, such as when a Vendor hosts a Virtua webpage, Virtua requires the Vendor to comply with the terms of this Privacy Statement or maintain comparable privacy practices that protect your Personal Information.
• Others. With respect to those who are not our vendors or our vendors’ subcontractors, as described above, we may use and share your Personal Information that we receive through the Digital Services: (i) to comply with applicable laws and regulations and to cooperate with law enforcement; (ii) if we reasonably believe such disclosure is important to protect the rights, property, safety, privacy, or security of any of our users, workforce, or the public; (iii) to respond to an emergency; or (iv) with your consent or at your direction.
Sharing Non-Personal Information Outside of Virtua
We may use and disclose Non-Personal Information for any purpose, except where prohibited under applicable law.
Security
The security of your Personal Information is very important to us. We use various measures, such as technical applications and administrative policies, to protect your Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. No data storage system or digital data transmission method can be guaranteed to be 100% secure but Virtua works very hard to protect the security of your Personal Information.
Opt-Out Option
As described above, we may use the Personal Information that you provide to us to send you promotional communications about us or our medical and health and wellness products or services, such as e-mails, text messages, phone calls, or newsletters. If you do not wish to receive such communications from us, you may opt-out from receiving it at any time by following the instructions included in the applicable communication sent to you. We work to comply with your request(s) as soon as reasonably practicable.
Text Messaging Opt-Out:You may opt-out of receiving text messages from us at any time. To opt-out, reply "STOP" to the text message that you received from us. After we receive your reply, we will send you a text message confirming that you have been successfully unsubscribed. After you receive this text message, you will no longer receive further text messages from us. If you change your mind and would like to opt back in to receiving text messages from us, follow the same steps you originally took to sign up for the text messages. If you experience any issues with our text messages, you may reply to such communication with the word “HELP” or you may email [email protected] to receive assistance.
Third Party Sites
In order to provide you with other helpful information, our Digital Services may contain links to web sites not owned or controlled by Virtua (“Third Party Sites”). This Privacy Statement only applies to our Digital Services and does not apply to these Third Party Sites. We are not responsible for the privacy practices on Third Party Sites. Once you follow a link to a Third Party Site, you are subject to the privacy statement or notice (if any) of that Third Party Site. We encourage you to carefully read the privacy statement and notices on any Third Party Sites before providing them with your Personal Information.
International Users
Virtua is located in the United States, has a principal purpose of delivering health care to customers located in the United States, and the Personal and Non-Personal Information we collect is governed by U.S. law. The Digital Services described in this Privacy Statement are directed only to customers located in the United States.
If you are not located in the United States when you use the Digital Services, by accessing or using the Digital Services or otherwise providing Personal Information to us, you consent to your Personal and Non-Personal Information being transferred to, stored, or processed in the United States and/or maintained on computers or servers located in the United States, where the privacy laws may not be as protective as those in your jurisdiction.
Children's Privacy
We encourage parents to get involved with their children’s online usage and to provide guidance and be aware of personal information your child may be providing online. If you are a parent and become aware that your minor child has provided us with personally identifiable information through the Digital Services, please contact our Privacy Officer as described in the “Contact Information” section of this Digital Services Privacy Statement and we will work with you to address the issue.
Our Digital Services are not intended or designed to attract children under the age of 13. In compliance with the Children’s Online Privacy Protection Act of 1998, we do not knowingly collect personally identifiable information from any child under the age of 13.
If you choose to engage in public activities on the third party sites that we link to, you should be aware that any information you share there can be read, collected, or used by other users of these sites and forums. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in public areas.
Acceptance of these Terms; Updates
By accessing and/or otherwise using the Digital Services, you are agreeing that we may collect, use and share Personal and Non-Personal Information as described in this Digital Services Privacy Statement.
We reserve the right to modify this Digital Services Privacy Statement at any time. All updates will be posted on this page, so please review it periodically. If you use the Digital Services following any amendment of this Privacy Statement, you accept and agree to be bound by the revised statement.
Contact information
If you have any questions regarding this Privacy Statement, please contact Virtua’s Privacy Officer at:
Virtua Health Privacy Officer
303 Lippincott Drive, 4th Floor
Marlton, NJ 08053
[email protected]