Privacy Policy
Last Updated: 12/30/22
This Privacy Policy (this “Policy”) describes how Visana Health, Inc., or its subsidiaries, divisions, and affiliates (“Visana,” “we,”“us,” or “our”), collects, uses, communicates, discloses, and otherwise manages the personal information that you provide to us by engaging our services on our websites, email, text, orother electronic messages between you and any employee or agent of Visana Health, mobile apps, and other online services on which this Policy is posted (collectively the “Service”). Visana is deeply committed to protecting the privacy and security of our customers’ data, and to keeping your health information safe.
This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extentthat any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.
As used in this Privacy Policy, the terms “using” and “processing” information may include, amongst other things, subjecting such information to analysis, using cookies, and managing information in a number of ways, including but not limited to: collection, storing, evaluating, modifying,deleting, using, combining, and/or disclosing. Some of the information we collect may constitute protected health information (“PHI”) under the HealthInsurance Portability and Accountability Act of 1996 (“HIPAA”), as amended by the Health Information Technology for Economic and Clinical Health Act of 2009(“HITECH”). For more information about your rights under HIPAA, please refer to Visana Health's HIPAA Notice and Consent to Share and Release Information.
Children and Individuals Under the Age of Eighteen
The Service is not meant for individuals under the age of eighteen, and the Service may use mechanisms to prevent the registration and use of the Service by such underage individuals. Visana will never knowingly request or collect personal information from any child. If you are under eighteen years old, please do not provide your information on our Service. Upon notification that a child has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records. If you believe we might have any information from a child, please contact us.
Collection of Personal Information
Information you provide to us
Visana will collect personal information from you directly when you interact with our Service, contact us, use our services, create anaccount, subscribe, share reviews, sign up to receive offers or emails, text messages, or other electronic messages from us, or complete surveys.
Information we obtain indirectly
We may receive personal information about you from our third-party affiliates or partners and from companies that provide us with suchinformation as a part of their relationship with us. We may combine this with data that we already have collected about you.
Information collected automatically
When you use our Service, we collect certain information about you automatically through our use of cookies and similar technologies.
Categories of Personal Information and Purpose forCollection
Visana collects the following categories of personal information: (1) contact information including your name, phone number, email address, street address, city, state, zip code; (2) authentication information, including the user name and password that you use to register an account on the Service; (3) financial information for payment processing purposes; (4)comments, reviews, suggestions; (5) personal characteristics including age, date of birth, gender, marital status, and nationality; (6) personal preferences including product preferences, online preferences, and interests;(7) online behavior information including online activity, preferences, andtime spent viewing features; and (8) IP address or mobile network information. If you use a mobile device to access the Service, Visana may also collect additional information from your mobile device, such as unique device identification numbers or geo-location information.
Visana may also collect certain sensitive personal information including your precise geolocation and personal informationcollected and analyzed concerning your health, such as symptoms, that youprovide in connection with use of our products or services. This information iscollected and used without the purpose of inferring characteristics about you. '
Beyond this, unless stated otherwise in a separate agreement, Visana does not collect sensitive personal information such as your social security, driver’s license, state identification card, or passport number; your account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; the contents of your mail, email and text messages, unless we are the intended recipient of the communication; your genetic data; and your biometric information for the purpose of uniquely identifying you. We ask that you not send nor disclose this sensitive personal information to us. Visana only collects and processes the minimum amount of personal information and sensitive personal information from you that is necessary to the purposes of our information processing activities and retains such information only if required to fulfill such purposes.
We may use information we collect about you to:·
Administer your account·
Allow your Visana Health Coach to personalize your experience;
Provide you with access to particular tools and services;
Respond to your inquiries and send you administrative communications;·
Obtain your feedback on our websites and our offerings;
Statisticallyanalyze user behavior and activity;
Provide you with more relevant content;
Conduct research and measurement activities;
Send you personalized emails or secure electronic messages pertaining to your health information; or
Contact you about the products and services that we offer.·
Customer communications and support·
User verification and payment processing·
Service maintenance and improvements
Where applicable, if Visana intends to further process your personal information for a purpose other than that for which the personal information was initially collected, Visana shall, prior to such processing, provide you with any relevant information on such additional purpose, and, tothe extent required by applicable law, obtain your consent for this.
Disclosure of Personal Information
Visana does not trade, rent, or sell your personal information to third parties or share your personal information with third parties for cross-context behavioral advertising. We may share or disclose your personal information for the following limited purposes:
Visana may share aggregate, non-personal information about website or mobile application usage with unaffiliated third parties. This aggregate information does not contain any personal information about our users.
Visana may employ third party companies and individuals to facilitate or improve the Service, to provide the Service on its behalf, to process payment, provide customer support, to perform website-related services (e.g., without limitation, maintenance services, database management, web analytics, and improvement of the Service’s features), or to assist Visana in analyzing how the Service is used. These third parties have access to your personal information only to perform these tasks on Visana’s behalf and are obligated not to disclose or use it for any other purpose other than the purpose for which we disclose it to them.
Visana cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Visana will disclose any information about you to government or law enforcement officials or private parties as Visana, in its sole discretion, believes necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Visana, a user of the Service, or a third party, to protect the safety of the public or any person, or to prevent or stop activity Visana considers to be or to have the potential to be, illegal, unethical, or legally actionable. In addition, Visana may disclose information about you to counter or prevent any malicious access or use of the Service or to prevent harm or loss to any user of the Service.
Do Not Track Signals, Cookies, and Other Technologies
We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity and interactions with our emails, mobile applications, and to allow us to keep track of analytics and certain statistical information that enables Visana to improve our services and provide you with more relevant content. You may disallow receiving cookies at any timethrough your web browser, but some features of the Service, such as account logins, may not work properly or you may not be able to use the Service at all.Similarly, you may set your mobile device to refuse to provide certain information, but certain features of the Service may not work without such information.
It is not our intention to use cookies to retrieve information that is unrelated to our Service or your interaction with our Service. At this time, we do not respond to browser “do not track” or “DNT” signals.
Links and Third-Party Websites
Our Service may contain links to other websites owned and operated by third parties. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect personal data or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information by third parties through the linked sites. Visana is not responsible for the privacy practices or the content of such other websites. Visana expressly disclaims any liability that may arise from your use or provision of any of your information whatsoever to third-party websites. You understand and agree that by clicking on a link to another site or service that you have left our Service.
Opting Out of Certain Emails
When you register, subscribe, create an account, sign up to receive offers or emails from us, or otherwise communicate with us through our Service, you may “opt out” of receiving future communications from us by indicating that you decline such communications. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or contacting us at members@visanahealth.com.
Notification of Privacy Policy Changes
We may update this Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on the Service prior to the change becoming effective. Use of information we collect now is subject to the Policy in effect at the time such information is used. You are bound by any changes to our Policy when you use the Service after such changes have been first posted. We encourage you to periodically review this policy for the latest information on our privacy practices.
u Security If you choose to provide us with your personal information, you understand that we are transferring it to Visana’s locations and systems inthe United States. Visana uses reasonable security measures to protect theloss, misuse, and alteration of the information under its control. For example,we use encryption protocols for sensitive information, such as healthinformation. Such measures may change from time to time, depending on industrystandards and perceived security risks. However, despite such securitymeasures, Visana cannot guarantee the security of your information anddisclaims liability for loss, misuse, and alteration of your information underits control to the maximum extent permitted under applicable law. By using theService, you agree to assume any security risk related to personal information.You should report any security violations to us by sending an email to members@visanahealth.com. The security of your Visana account relies on yourprotection of your user profile information. You are responsible formaintaining the security of your user profile information, including yourpassword and for all activities that occur under your account. You may notshare your password with anyone. We willnever ask you to send your password or other sensitive information to us in anemail. Any email or other communication purporting to be from one of ourwebsites requesting your password or asking you to provide sensitive accountinformation via email, should be treated as unauthorized and suspicious andshould be reported to us immediately. If you believe someone else has obtainedaccess to your password, please change it immediately by logging in to youraccount and report it immediately by contacting us via email. Special Notice to CaliforniaResidents If you wouldlike to submit a Consumer Request, you can contact Visana at members@visanahealth.com. If you choose to submit a Consumer Request, youmust provide us with enough information to identify you and enough specificityon the requested data. Visana will only use the information it receives torespond to your request. Visana will not be able to disclose information if itcannot verify that the person making the Consumer Request is the person aboutwhom we collected information, or someone authorized to act on such person’sbehalf. “Personalinformation” means information that identifies, relates to, describes, iscapable of being associated with, or could reasonably be linked, directly orindirectly, with a particular consumer or household. “Personal information”does not include publicly available information. 1. Request to Correct.You may correct or update your personal informationat any time by logging into your account or by contacting us.
2. Request to Access. You may submit a Consumer Request to obtain a copy of oraccess to the personal information that Visana has collected on you.
3. Request to Know. You may submit a Consumer Request to receive informationabout Visana’s data collection practices. ·
Right to Know what Personal Information is being Collected. You may request information on the categories of personal information Visana has collected about you; the categories of sources from which the personal information is collected; Visana’s business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom Visana discloses personal information, if any; and the specific pieces of personal information it has collected about you. ·
Right to Know what Personal Information is Sold or Shared and to Whom. You may also request the categories of personal information that Visana has collected about you; the categories of personal information that Visana sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared, and the categories of personal information that Visana disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
Please note that the categories of personal information, sources, and disclosure will not exceed what is contained in this Policy. Additionally, Visana is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. Visana is also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.
4. Request to Delete.
You may request that Visana delete personal information it has collected from you. Subject to certain exceptions set out below we will, on receipt of a verifiable Consumer Request, delete your personal information from our records, direct any service providers to do the same, and notify all third parties to whom Visana has shared your personal information to delete it unless this proves impossible or involves disproportionate effort.
Please note that we may not delete your personal information if it is necessary to:
Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12of Part 2 of the Penal Code.
Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.
To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.
Comply with a legal obligation.
Visana may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.
Questions and How to Contact Us
If you have any questions, concerns, complaints or suggestions regarding this Privacy Policy or otherwise need to contact us, please email us at members@visanahealth.comor contact us by United States mail at 5123 W 98th St #1345, Minneapolis, MN 55437.
