Effective Date: August 30, 2016
Personally Identifiable Information. Personally Identifiable Information ("PII") is information VIRTUAL METM collects that uniquely identifies the User. This information may include name, email address, phone number, date of birth and credit card information, as well as other information User may choose to share while interacting with VIRTUAL METM on the Site or through other means of communication. While your IP address may not be considered PII on its own, when it is combined with certain other identifiers, it may become PII.
Non-personally identification information. Non-Personally Identifiable Infor-mation ("Non-PII") is anonymous information that VIRTUAL METM collects, which information is not traceable to any individual person or computer. Non-PII may include the browser name, the type of computer and technical information about Users means of connection to the Site, such as the operating system and the internet service provider's utilized and other similar information.
Individually Identifiable Health Information. As defined under 45 CFR 160.103, Individually Identifiable Health Information (("IIHI") is information that is a subset of health information, including demographic information collected from an individual, and (1) Is created or received by a health care provider, health plan, employer, or health care clearinghouse; and (2) Relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual; and (i) That identifies the individual; or (ii) With respect to which there is a reasonable basis to believe the information can be used to identify the individual. For example, IIHI might include a combination of information such as patient name, diagnosis, and date of service.
Protected Health Information (PHI). PHI means Individually Identifiable Health Information that is transmitted or maintained in electronic or other media, as defined in 45 CFR 160.103.
Third-Party. Third Party means a business that is outside the VIRTUAL ME LLC family and that is not a Partner.
Partner. Partner means a business that VIRTUAL METM, Virtual Me LLC, or any subsidiary or affiliate works with to maintain or improve our service, or who may provide services on our behalf, such as credit card processing companies or email service providers.
2. Collection of Information
VIRTUAL METM is the owner of the information collected on this Site.
Collection of PII.
2.2.1 VIRTUAL METM may collect PII from Users in a variety of ways, including, but not limited to, when Users visit the Site, register on the Site, purchase a VIRTUAL METM e-card or subscription, fill out a form, and in connection with other activities, services, features or resources VIRTUAL METM makes available on the Site. Users may be asked for, as appropriate, name, email address, mailing address, phone number and credit card information.
2.2.2 VIRTUAL METM will collect PII from Users only if they voluntarily submit such information to VIRTUAL METM. Users can always refuse to supply PII, except that it may prevent them from engaging in certain Site related activities. Users can browse the Site without revealing any personal information; however, once User provides VIRTUAL METM with personal information, User ceases to be anonymous to VIRTUAL METM. If User chooses to provide VIRTUAL METM with PII, User consents to the transfer and storage of that information on VIRTUAL METM servers. VIRTUAL METM may collect and store the following PII:
(a) Email address, physical contact information, and shipping, billing and other information User provides to purchase a healthcare card or healthcare subscriber access;
(b) Clicks and page information such as the address (or URL) of the web site that User came from before visiting the Site, which pages User visits on the Site, which browser User used to view the Site and any search terms User entered on the Site;
(c) Other information from User's interaction with the Site, including computer and connection information, statistics on page views, traffic to and from the Site, ad data, IP address and standard web log information;
(d) Information User chooses to provide through the linking of devices where User is actively choosing to share personal information, including health information, to interact with an application or program hosted on the Site;
(e) Information User chooses to allow VIRTUAL METM access to through social media channels; and
(f) Information from other companies, such as demographic and navigation data.
Children's Online Privacy Protection Act. This Site is not directed at children under the age of 18 and does not knowingly collect PII from children under the age of 18. We strongly recommend that children under the age of 18 ask for their parent's or guardian's permission before viewing our Site. Should you, as a parent or legal guardian of a minor, become aware that a user who is under the age of 18 has provided VIRTUAL METM with PII without the consent of a legal guardian, please contact us at the address below to have such account, and the information associated with it, removed. To delete your account, you can send an email, with the subject line, "Delete My Account," to firstname.lastname@example.org or you can send mail to VIRTUAL ME LLCTM, 315 S. Coast Hwy 101, U44, Encinitas, CA 92024
3. How VIRTUAL METM Uses Collected Information.
To Provide the Services. VIRTUAL METM may use PII, including PHI, to pro-vide you with the healthcare communications services that you request.
To personalize user experience. VIRTUAL METM may use information in the aggregate to understand how Users as a group use the services and resources provided on the Site.
To improve the Site or Services. VIRTUAL METM continually strives to improve the Site offerings based on the information and feedback received from Users.
To improve customer service. User information helps VIRTUAL METM to more effectively respond to customer service requests and support needs.
To process transactions. VIRTUAL METM may use the information Users provide about themselves when placing an order only to provide service to that order. VIRTUAL METM does not share this information with outside parties except to the extent necessary to provide the service.
To send periodic emails. Email addresses provided by Users for order processing will only be used to (i) send information and updates pertaining to such order; (ii) respond to inquiries, and/or other requests or questions. If User elects to opt-in to VIRTUAL METM's mailing list, User will receive emails that may include VIRTUAL METM news, updates, related product or service information, etc. If at any time User desires to unsubscribe from VIRTUAL METM's mailing list, VIRTUAL METM includes detailed unsubscribe instructions at the bottom of each email or User may contact VIRTUAL METM at email@example.com.
For Statistical Research. VIRTUAL METM may disclose your information in aggregate, anonymized form to our partners who are conducting statistical research and analysis on various health issues; these partners may include pharmaceutical manufacturers, clinical research entities, educational institutions, insurance companies, and data processing companies.
4. Sharing User Information
VIRTUAL METM does not sell, trade, or rent Users' PII, including PHI, to others. VIRTUAL METM may share generic aggregated demographic information not linked to any PII regarding visitors and users with our Partners, including trusted affiliates and advertisers, for the purposes outlined above. We may use Partners to help us operate our business and the Site, or administer activities on our behalf, such as sending out newsletters or surveys, or to assist in providing financial or operational activities on VIRTUAL METM's behalf. We may share your information with these Partners for those limited purposes, provided that you have given us your permission.
VIRTUAL METM may also disclose your PII to Third Parties under the following limited circumstances: (i) when required by law, regulatory or legal process, which may include exchanging information for the purpose of fraud protection; (ii) when necessary to protect and defend the rights or property of VIRTUAL METM; or (iii) when necessary to protect the personal safety of VIRTUAL METM website users and customers.
5. How VIRTUAL METM Protects User Information
In accordance with applicable law, VIRTUAL METM has adopted data collection, storage and processing practices, and has security measures in place to protect against the unauthorized access, alteration, disclosure, loss, misuse, or destruction of your personal information, username, password, transaction information and data stored on our Site or under our control. We safeguard the security of the data you send us with physical, electronic, and other procedures. Sensitive and private data exchange between VIRTUAL METM and its Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures.
As no data transmission over the Internet is completely secure, we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers ("strong passwords"), and use a secure browser. Because no physical or electronic security is impenetrable, by using VIRTUAL METM, you agree to assume all risks in connection with the information sent to us or collected by us when using VIRTUAL METM.
6. Third Party Websites
Now and in the future, Users may find advertising or other content on the Site that links to the sites of VIRTUAL METM's partners, suppliers, advertisers, sponsors, licensors and other third parties ("Third Party Sites"). VIRTUAL METM does not control the content or links that appear on Third Party Sites and VIRTUAL METM is not responsible for the practices employed by Third Party Sites. In addition, Third Party Sites, including their content and links, may be constantly changing.
Third Party Sites may have their own privacy policies and customer service policies. Web browsing and interaction on any website, including Third Party Sites, is subject to the terms and policies of such sites. We encourage you to be aware when you leave our Site and to read the privacy statements of every website that collects PII. This Policy applies solely to information collected by our Site and does not cover information collected elsewhere, including without limitation on websites linked to from the Site.
7. Updating or Correcting Your User Information
A User may review, request corrections, ask that we delete, or refuse further collection or use of the PII that VIRTUAL METM collects. The User may do this by contacting VIRTUAL METM using the contact information provided at the end of this document. Updates and corrections to a User's profile information may be made by clicking on the "My Access" link at the top or bottom of any page, logging in with your Username and Password when prompted, and selecting "Update Your Profile Here!"
8. Opting Out of Communications, Do Not Track
Email Opt-Out. If you prefer that we not disclose PII about you to Third Parties for advertising or marketing purposes, you may opt out of those disclosures; that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you receive communications from us that you do not want to receive, you can opt-out of receiving these communications by specifically telling us to stop sending them to you. On every email you receive from VIRTUAL METM , other than those sent by Providers, we will provide you with a link to opt out of future emails by clicking the "Unsubscribe" link in the header or the footer. We will generally be able to give effect to your withdrawal on 30 days' notice. If you wish to opt out of disclosures to Third Parties, you may email your request to VIRTUAL METM at firstname.lastname@example.org
Do Not Track. There are many tools you can use to manage how VIRTUAL METM and other parties can monitor your activity on our Site and elsewhere on the Internet. One option is by using "Do Not Track," a voluntary program among commercial website operators and online services that is intended to give users the ability to opt-out of such tracking. We do not currently take actions to respond to Do Not Track signals because there is no uniform definition as to what constitutes a Do Not Track signal, no technological standard with regard to how to respond to any such signals, and no consensus as to what adherence to Do Not Track entails.
9. How You Can Protect Your User Information
VIRTUAL METM recommends that Users take the following precautions to safe-guard data:
11. Limitation of Liability for Privacy
VIRTUAL ME LLC
PO Box 1193, Cardiff, CA 92007