Effective Date: January 18, 2024

This Privacy Policy applies to Personal Information (as defined below) collected by CareVitality, Inc. (“we,” “us,” or the “Company,”) through https://carevitality.com/. Our website is operated solely for business purposes and not for any health care or medical purpose.

Please read this policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By accessing or using our website, you agree to this privacy policy. When you submit or provide Personal Information to us, you consent to the collection, use and disclosure of your Personal Information as described in this Privacy Policy.

This policy may change from time to time as described below. Your continued use of our website after we make changes is deemed to be acceptance of those changes, so please check this policy periodically for updates. See Section 2 below (Changes to this Privacy Policy).

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR WEBSITE AND DO NOT PROVIDE US WITH YOUR PERSONAL INFORMATION.

This privacy policy DOES NOT apply to

Protected Health Information or PHI (as described below),
Information about our own employees, contractors, agents, and job applicants,
Information that you share with any third-party website or service that you may access through our website, or
Information disclosed or acquired through other activities as described below.

This policy applies to Personal Information we collect on or through our website or that you choose to provide (assuming that none of it is PHI). For example, it will apply if you include personally identifiable contact information when using the “Contact Us” function on the website or if you later include Personal Information in texts, emails or other electronic messages between you and the website.
This policy does not apply to information collected by us through any means other than our website. For example, it does not apply to information obtained when you respond to advertising that links to our website or information that we learn when we participate in a conference that you are attending. It also does not apply to information obtained by any of our affiliates through their websites or their other activities.
Please click here for more information about specific privacy rights applicable to California residents.

THIS PRIVACY POLICY DOES NOT APPLY TO PHI (PROTECTED HEALTH INFORMATION) UNDER HIPAA

Our website describes care management and related services that we may provide from time to time under contracts with health care providers (“Our Services”). Our Services may make us “Business Associates” of some health care providers or others that are subject to “HIPAA” (the Health Insurance Portability and Accountability Act of 1996 and its related regulations). HIPAA provides privacy protections for the PHI (protected health information) of individuals in connection with their treatment and certain related activities. HIPAA defines PHI (protected health information) at https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-160/subpart-A/section-160.103.
However, our website is NOT intended to be used by patients or their representatives for health care or related services so this policy DOES NOT apply to PHI. No patient, customer of the Company, potential patient, potential customer or any of their representatives should submit PHI to our website or try to use it to transmit or maintain PHI.

CHANGES TO THIS PRIVACY POLICY

The Effective Date of this Privacy Policy is set forth at the top of this webpage. As business needs change, we will review our practices regarding the collection and use of your Personal Information, and we may amend this Privacy Policy as appropriate. The amended Privacy Policy supersedes all previous versions. Your continued use of our website after the Effective Date constitutes your acceptance of the amended Privacy Policy.

PERSONAL INFORMATION WE MAY COLLECT

In this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, with an individual (for example, you) or household. Personal Information does not include aggregated information to the extent that an individual’s identity cannot reasonably be derived from it. The Personal Information we collect about you depends on your interactions and engagement with us.
We may collect the following types of Personal Information:

Direct Identifiers such as your name, postal address, email address, phone numbers, and unique personal identifiers, if any.
Commercial Information such as records of personal property, and products or services purchased or obtained, any background information provided by you or collected by us as part of our business analysis, customer onboarding, regulatory compliance checks and other related processes, and other customer information provided to or made available to us by or on behalf of you, as well as information generated by us in the course of providing Our Services to you.
Internet or Other Electronic Network Activity Information such as records of your use of our website, mobile applications or other online services. This may include your online identifiers, IP address, details of your device, operating system and browser, and other information as described in Section 7 of this policy.
Geolocation Data such as your location as derived from your IP address.
Professional or employment-related information, such as job title, organization and other professional information.

HOW WE MAY COLLECT PERSONAL INFORMATION

We may collect Personal Information for all lawful purposes in the operation and conduct of our business.

Directly From You: We may collect Personal Information through your use of the website (such as when you register with us, participate in surveys and questionnaires or subscribe to newsletters and blog updates), when you provide us Personal Information in the course of providing Our Services and when you otherwise provide Personal Information to us both online and offline. We also may collect the Personal Information that you publish or display on public areas of the website, such as one of our blogs (collectively, “User Contributions”). Your User Contributions are made publicly available at your own risk. We do not control the actions of third parties that access your User Contributions.

Through Social Media: Our website may link to social media platforms and plug-ins, such as Facebook (collectively, “Social Media”). When accessing the website through a Social Media account, we may (depending on the applicable user privacy settings) automatically receive Personal Information from that Social Media platform. We may collect and use this Personal Information for the purposes described in this Privacy Policy or as described at the time the information is collected.

From Third Parties: We may collect Personal Information about you from third parties where such information is required for us to fulfil our legal obligations or to provide you with a requested service.

Through Gathering Service Usage Data, including for our Website: When you use the website we and our vendors may collect the Internet Usage Information that is collected by most browsers or automatically through your device. We also collect Usage Data through our use of Data Collection Technology. For more information about how we use Data Collection Technology, including cookies, please review Section 7; for more details on your choices please see Section 8. Where Usage Data includes Personal Information, or is combined with Personal Information, it will be treated as Personal Information itself – as described in Sections 3 through.

HOW WE MAY USE PERSONAL INFORMATION

We may use Personal Information for all lawful purposes in the operation and conduct of our business. Our use may be for the purposes described at the time of its collection or as described in this Privacy Policy. For example, we may use your Personal Information:

To provide you or your company with Our Services, such as carrying out any applicable contractual obligations that we have to you or third parties; verifying your identity; processing payments that you make to us; confirming registrations, responding to your inquiries or fulfilling your requests, for example, to register you for a seminar or to email you materials you requested; sending you information (for example, event announcements) that we think may interest you; enabling you to provide us with further information; keeping a record of your contact information and correspondence to use when responding to you if you contact us through the website or through other methods both online and offline; and notifying you about important information regarding changes to our terms, conditions and policies.
For our internal business purposes, such as updating our records of your details, including contact and marketing details, where we identify that they are inaccurate or incomplete.
For our internal research and product improvement purposes, such as analyzing use of the website to help us detect problems, identify usage trends and improve user experience.
For legal, safety or security reasons, such as complying with legal requirements; complying with reporting and similar requirements; investigating and responding to claims against us and our customers; completing due diligence (such as in connection with a corporate transaction); protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
In connection with a corporate transaction, such as if we acquire, or some or all of our assets are acquired by, another entity, including through a sale in connection with bankruptcy and other forms of corporate change.
For marketing, such as marketing Our Services or those of our affiliates. For example, we may use Personal Information we collect to send you newsletters, surveys, questionnaires, or information about events or webinars. You can unsubscribe from our email marketing by contacting us using the information in Section 14.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

HOW WE MAY DISCLOSE PERSONAL INFORMATION

We may disclose Personal Information for all lawful purposes in the operation and conduct of our business including, without limitation for the following reasons and to the following categories of third parties:

With your consent: We may disclose your Personal Information to any party for whom your consent has been provided.
To our affiliated entities: We may disclose your Personal Information within our corporate family for the purposes described in this Privacy Policy and as required by law. For a list of our affiliated entities, please refer to our Legal Notices webpage.
To our service providers: We may disclose your Personal Information to third-party vendors that support our operations such as internet service providers, data analytics providers, external consultants, advertising networks, operating systems and platforms, and vendors that facilitate registering and hosting webcast and live events.
To professional consultants: We may disclose your Personal Information to such professional consultants as accountants, lawyers, and financial advisors.
To vendors necessary to complete transactions you request: We may disclose your Personal Information to such third-party vendors as shipping companies and logistics providers.
In relation to a corporate transaction: We may disclose and transfer your Personal Information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (whether in whole or in part), including negotiation and diligence of such transaction.
Business partners: We may disclose your Personal Information to our business partners, such as companies that operate cookies and other tracking technologies and social media companies.
For legal, security, or safety purposes: We may also disclose your Personal Information: (i) as permitted by law; (ii) if we determine that the disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process; (iii) to protect the legitimate rights, privacy, property, interests or safety of our company or our affiliated entities, customers, business partners, employees or the general public; (iv) to pursue available remedies or limit damages; and (v) to respond to an emergency.

No mobile information that you provide through our website will be shared with third parties for marketing/promotional purposes without your consent.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

Our website and related technology (and authorized third parties) use cookies and other tracking technologies to collect information about you, your device, and how you interact with our website. We refer to cookies, web beacons (also known as pixel tags and clear GIFs) and other similar technology as “Data Collection Technology.”

Cookies are a small text file that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (when it expires), and a randomly generated unique identifier. A cookie may also contain information about your computer, such as user settings, browsing history and activities conducted while using the website and related technology.
Pixels, web beacons, and tags are types of code or transparent graphics that contain a unique identifier. These technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.
Session replay tools record your interactions with our website and related technology, such as how you move throughout our website and engage with our webforms. This information helps us improve our website and identify and fix technical issues visitors may be having with our website.
Information Collected: These tracking technologies collect data about you and your device, such as your IP address, cookie ID, device ID, AdID, operating system, browser used, browser history, search history, and information about how you interact with our website (such as pages on our website that you have viewed).
How We Use Data Collection Technology: We and authorized third parties use these technologies to remember user preferences, login details and browsing behavior; improve the performance of our website, products, and Services; conduct analytics; provide you with offers that may be of interest to you; track your activity across online properties over time to better understand your preferences and interests; to conduct advertising on our website and those of third parties; measure the effectiveness of our communications with you and advertising campaigns, including identifying how and when you engage with one of our emails; and personalize online content. For example, we use Google Analytics to help us improve our website, performance and user experiences. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners. You may prevent Google Analytics from recognizing you on our website by deleting or disabling the relevant cookies. For more information, see Section 8, “Choices”.

Disclosures of Your Information: Depending on your selected cookie and privacy settings, we may disclose information to third parties or allow third parties to directly collect information using these technologies on our website. These third parties, which include social media companies and advertising networks, use your information to provide you with more relevant advertising known as interest-based advertising.

CHOICES

Marketing Emails: If you do not wish to receive marketing-related emails from us, please click the unsubscribe link at the bottom of a marketing email or email us at contact@carevitality.com.

Cookies and web trackers: Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. The choices available, and the mechanism used, will vary from browser to browser. Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or alert you when a cookie is placed on your computer or device. You may also be able to reject mobile device identifiers by adjusting the appropriate setting on your mobile device. Such browser settings are typically found in the “options,” “tools” or “preferences” menu of your browser. You may also consult your browser’s “help” menu.
Please note that tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies or other tracking technologies. For information on disabling Flash cookies, visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html. Please be aware that if you disable or remove these technologies, some parts of our website may not work and when you revisit our website your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.

Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the website. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser.
Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.

Our Policy on Do Not Track Signals: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. Our website currently does not respond to or follow DNT signals that we receive from your browser(s).

Disable Google Analytics: You may exercise choices regarding the use of cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptout

SPECIAL NOTICE TO CALIFORNIA RESIDENTS

California residents have the privacy rights listed in Attachment A to this Privacy Policy with respect to their Personal Information.

LINKS TO OTHER WEBSITES AND SERVICES

Our website may include links to third-party websites and services that we do not operate, such as social media plug-ins. If you visit a third-party website or service via a link on the website, you are subject to that third party’s privacy practices and policies. This Privacy Policy does not apply to any Personal Information that you provide to third-party websites or services. A link to a third-party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.

NOTICE TO INTERNATIONAL VISITORS

Our website is not intended to subject us to the laws or jurisdiction of any state, country or territory other than the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. Your use of our website may involve the collection, processing, and transfer of information to or from countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

SECURITY

We take reasonable precautions intended to help protect the Personal Information that we collect and store; however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through our website. Any transmission is at your own risk. Please use security measures to protect your Personal Information.

CHILDREN’S PRIVACY

Our website and Services are not directed to or intended for use by minors. Consistent with the requirements of the US Children’s Online Privacy Protection Act, if we learn that we have received information directly from a child under age 13 without his or her parent’s or legal guardian’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the website. Subsequently, we will make commercially reasonable efforts to delete such information.

QUESTIONS OR COMMENTS

We welcome your questions and comments about this Privacy Policy or how we process your Personal Information. Please contact us using the information below, and we will respond to you as soon as reasonably possible.

By Mail:

CareVitality, Inc.
Attn: Vanessa Bisceglie
5100 Jarlath Avenue
Skokie, IL 60077

By Email:

contact@carevitality.com

ATTACHMENT A

SPECIAL NOTICE TO CALIFORNIA RESIDENTS

California residents have the privacy rights listed below with respect to their Personal Information.

CALIFORNIA’S “SHINE THE LIGHT” LAW

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us at contact@carevitality.com. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than to the email address above, or to the mailing addresses specified at the end of this notice.

CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”)

A. Supplemental Disclosures

Although we do not “sell” Personal Information for money, we engage in routine practices with our website involving third parties that could be considered a “sale” or “sharing” as defined under California law. We do not knowingly sell or share the Personal Information of minors under the age of 16.

Below please find a chart detailing the categories of Personal Information and to whom it was sold or shared or disclosed for a business or commercial purpose in the past 12 months:

We do not collect the following information through our website:

Personal Records such as your signature, financial account information and insurance information), payment card information (for example, if you make payments to us directly).
Protected Characteristics such as your age (including birthdates), marital status, gender.
Audio, electronic, visual, or other sensory information, such as records of building and suite access and parking card use, and footage from workplace security cameras that indicate your location.
Sensitive Personal Information such as government-issued identification information, social security number, visa and passport information, account names and passwords, and, where necessary to fulfil our legal obligations or to provide you with a requested service, and disability information (if necessary for your access to the website).

B. Privacy Rights

The CCPA grants California residents additional privacy rights with respect to their Personal Information. The CCPA privacy rights include:

Right to Know: You have the right to request to know (i) the specific pieces of Personal Information that we collected about you; (ii) the categories of Personal Information that we collected about you in the past twelve (12) months; (iii) the categories of sources from which that Personal Information was collected, (iv) the categories of your Personal Information that we sold or disclosed in the past twelve (12) months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the past twelve (12) months; and (vi) the purpose for collecting and selling your Personal Information in the past twelve (12) months. You may exercise your right to request to know twice a year, free of charge.
Right to Delete: You have the right to request that we delete the Personal Information that we collect from you.
Right to Correct: You have the right to request that we correct inaccurate Personal Information that we maintain about you.
Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your Personal Information.
Right to Non-Discrimination: If you choose to exercise any of your rights under the CCPA, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of the website.

EXERCISING YOUR RIGHTS UNDER THE CCPA

To make a privacy rights request, please contact us at 1- 800-376-0212 or email us at contact@carevitality.com.

In order to exercise the Right to Opt Out of Sales or Sharing with respect to any “sale” or “sharing” of information automatically collected online through cookies and other tracking technologies, you may disable the use of advertising cookies and other tracking technologies in the preference center. See Sections 7 and 8 above for further information. You must complete this step from each browser and on each device that you use. These steps are necessary so that we can place a first-party cookie signaling that you have opted out on each browser and each device you use. Please note:

If you block cookies, we will be unable to comply with your request to opt out with respect to device data that we automatically collect and disclose to third parties online using cookies, pixels, and other tracking technologies.
If you clear cookies, you will need to disable the use of all advertising cookies and tracking technologies in the preference center again on each browser on each device where you have cleared cookies.

Verification: Only you or your authorized agent may submit a consumer request. You may submit a consumer request on behalf of your minor child. In order to respond to your consumer request, we will take steps to verify your identity before processing your request. To the extent possible, we will use our existing account authentication practices to verify your identity. Where necessary, we may request additional information about you so that we can verify your identity. Where we did not already hold that information, we will use it only for the purpose of verifying your identity and to process your request. If we cannot verify your identity based on the information provided, we will let you know that we are unable to fulfil your request.
Please note that if we maintain your Personal Information on behalf of a third party, we may need to refer you to that third party in order to respond to your request. If we cannot comply with your request, or with part of your request, we will explain the reasons in our response.

Authorized Agent: You may use an authorized agent to submit a privacy rights request. Authorized agents may exercise rights on behalf of you by submitting a request via phone at 1- 800-376-0212 or email at contact@carevitality.com and indicating that they are submitting the request as an agent. When we verify your agent’s request, we may verify both you and your agent’s identity and request a signed declaration from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.