Virtual Health Partners – Online Privacy Notice

Effective Date: March 14th, 2023

This Online Privacy Notice applies to information about you that Virtual Health Partners, Inc. (“VHP,” “we,” or “us”) may obtain about you when you visit http://virtualhealthpartners.com/, or visit either https://*.vhpgo.com or use our mobile application (collectively, the

“Platform”). This Privacy Notice also describes how we may collect, use, or share information about you; your choices regarding our use of your information; the ways in which we safeguard the information we collect; and how you may contact us regarding our privacy practices.

How We Collect Information

Information You Provide

We obtain information that you provide to us directly through the Platform. For example, we collect information you submit when you register on the Platform or contact us, including details regarding your health history, your height, weight, body mass index, birthday, and medical conditions. The information we collect from you may include personal information, which is information that can be used to identify you individually, such as your name, email address, or telephone number.

If you choose to link an activity tracker (such as a Fitbit, pedometer, or other fitness app) to your account on the Platform, we may obtain information about you that is collected by the activity tracker(s), such as statistics regarding your mobility, exercise habits, and other personal information that you may allow those devices to collect. Similarly, if you choose to link a Bluetooth-enabled device (such as a scale) to the Platform, we may obtain information about you that is measured or otherwise collected by those devices.

Information Collected Automatically

In addition to information you submit to us, we may collect certain information using automated tools such as cookies, web beacons, and web server logs. The types of information we collect automatically may include IP addresses, device identifiers, browser characteristics, operating system details, language preferences, referring URLs, length of visits, and pages viewed.

We may combine certain automatically-collected information with other information we obtain about you, which may include data we obtain from third parties.

Information about your use of services available through the Platform and other websites may be collected across time, devices, and websites, and used for various purposes including to associate different devices you use and to deliver relevant and/or retargeted content.

Information We Obtain From Partners and Other Sources

We also may obtain information about you from other sources (for example, from your healthcare provider) and combine that information with information you provide to us directly or that we collect automatically through the Platform.

Data Analytics

We use certain third-party web analytics services to help us understand our visitors and analyze how they use the Platform. Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our Platform is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you may wish to visit http://www.allaboutdnt.com/.

How We Use Your Information

We may use the information we collect about you for various purposes, including to:

Personalize and improve your online experience;
Help you execute your wellness and/or weight loss management plan;
Permit the healthcare provider who invited you to the platform, or partner who invited you to the platform, to obtain reports about your progress;
Respond to emails or other requests for support, inquiries, comments, or questions;
Monitor and analyze trends, usage, and activities of visitors and users;
Improve the Platform and other products or services we may offer;
Contact you regarding your use of the Platform or, in our discretion, changes to our policies;
Verify and/or authenticate a registered user’s identity;
Comply with applicable laws, regulations, or legal process as well as industry standards and our company policies;
Prevent, investigate, identify, or take any other action with regard to any suspected or actual fraudulent or illegal activity or any activity that violates our Terms of Use; or
For any other purpose, with your consent

We also may use the information we obtain about you in other ways, in which case we will notify you at the time of collection.

In addition, we use information collected online through cookies, web beacons, and other automated tools for purposes such as recognizing your device when you visit the Platform, tracking your activity as you navigate the Platform, or analyzing your use of the Platform. This information may be used to track your activity over time on various websites and services, as well as across different devices you may use to access the Internet.

Legal Basis for Collecting/Processing Your Information

When we collect and process your personal data, we may rely on one or more of the following legal bases, depending on the purpose for which the processing activity is undertaken.

We have your consent to do so. For example, because you clicked “I agree” or any similar phrase, to our Terms & Conditions.
We have a legitimate interest to collect your information that is not overridden by your privacy rights. For example, to provide our services to you, to improve our services, or to communicate with you about our services.
We need your information to perform a contract with you. For example, we may need information about users to perform our obligations under a contract for the services.
We have a legal obligation to collect your information. For example, to prevent or investigate illegal behavior in connection with the use of the services.
To protect the vital interests of any individual. For example in a medical emergency.

You can withdraw your consent to all processing or for individual processing activities, of your choice (to which you had given your consent), by sending an e-mail to privacy@virtualhp.com.

How We May Share Your Information

We may permit our agents, vendors, consultants, and other service providers to access information we collect about you through the Platform to carry out work on our behalf. These third-party service providers use the personal information to which they have access to fulfill the purposes for which we shared that information.

We also may share your information:

If we are required to do so by law, regulation, or legal process (such as in response to a subpoena or court order or similar government request for information);
To respond to requests by government agencies, including law enforcement authorities;
When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity;
To enforce our policies, or to protect legal rights, property, or safety;
With third parties, to investigate or address possible criminal or fraudulent activity; or
In the event of a joint venture, partnership, merger, or other collaboration with another

We reserve the right to transfer any information we obtain through the Platform in the event we sell or transfer all or a portion of our business or assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction, including negotiations of such transactions).

Information Security

We maintain appropriate administrative, technical, and physical safeguards designed to help protect personal information collected or received through the Platform. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through the Platform.

Links to Other Websites

We may provide links to other websites or services for your convenience and information. Websites that are operated by entities not affiliated with VHP may have their own privacy policies or notices, which we strongly suggest you review. VHP is not responsible for the content or privacy practices of any linked websites that we do not control.

Platform Support Groups and Online Forums

The Platform features forums, including online support groups and virtual semi-private group fitness classes (collectively, the “Forums”), that allow registered users to communicate with one another through online audio conferencing. When you voluntarily elect to participate in a Forum, your account information and records will be available to the moderator of the Forum, but not to the other participants. Your identity will not be disclosed to your fellow users in the Forum unless you choose to disclose that information yourself. Please note, however, that your voice and words will be audible to all participants in the Forum. Accordingly, any information you share in this context will be available to your fellow users, who may not adhere to this Privacy Notice and could disclose the information you share to unknown third parties. You should think carefully about whether you wish to disclose information that may identify you when you participate in a Forum. Please be aware that even if you do not say your name, sharing certain details about yourself may make it possible for others to deduce your identity.

Social Features

The Platform may include features that are designed to permit interactions that you initiate between the Platform and third-party websites or services, including third-party social networks (“Social Features”). An example of a Social Feature is enabling you to “like” or “share” content on other websites or services.

If you use Social Features on the Platform, both VHP and the third-party services that operate those Social Features may have access to certain information about you and your use of both our Platform and theirs. The information we collect in connection with your use of Social Features is subject to this Privacy Notice. The information collected and stored by the third parties remains subject to those third parties’ privacy practices, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third-party websites or services.

Children’s Privacy

This Platform is not intended for, nor targeted to, children under 13, and we do not knowingly or intentionally collect information from children under 13. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law.

Information for Users Residing in California

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA. Much of the personal information that Virtual Health Partners collects is exempt from the CCPA because it is protected under federal and/or state health information privacy laws. The section below sets forth Virtual Health Partners’ practices and consumers’ rights regarding non-exempt personal information that Virtual Health Partners collects.

Consumers with disabilities may access this notice by emailing support@virtualhp.com or calling 877-586-1733.

Personal Information We Collect, Disclose for a Business Purpose. We collect the categories of personal information about California consumers identified in the chart below. As further set forth in the chart below, in the past 12 months, we have disclosed California consumers’ personal information to third parties for business or commercial purposes.

Categories of Personal Information	Collected in the last 12 months:	Categories of sources from which information is collected:	Business or commercial purposes for collection, use, and sharing:	Disclosed for business purposes to the following categories of third parties:
Personal and online identifiers (such as first and last name, email address, or unique online identifiers)	Yes	Consumers, activity trackers	All purposes listed below.	All categories listed below.
Categories of information described in Section 1798.80(e) of the California Civil Code (such as physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information)	Yes	Consumers	All purposes listed below.	All categories listed below.
Characteristics of protected classifications under California or federal law (such as race or gender)	Yes	Consumers	All purposes listed below.	All categories listed below.
Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered)	Yes	Consumers	All purposes listed below.	All categories listed below.
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)	Yes	Consumers	All purposes listed below.	All categories listed below.
Biometric information (such as call recordings)	Yes	Consumers	All purposes listed below.	All categories listed below.
Geolocation information	Yes	Consumers	All purposes listed below.	All categories listed below.
Sensory information (such as audio, electronic, visual, thermal, olfactory, or similar information)	Yes	Consumers	All purposes listed below.	All categories listed below.
Professional or employment-related information	No	All categories listed below.	All purposes listed below.	All categories listed below.
Education information	No	All categories listed below.	All purposes listed below.	All categories listed below.
Inferences drawn from the above information about your predicted characteristics and preferences	Yes	All categories listed below.	All purposes listed below.	All categories listed below.
Other information about you that is linked to the personal information above	No	All categories listed below.	All purposes listed below.	All categories listed below.

Categories of Sources. We collect this personal information from the following categories of sources:

Consumers;
Activity trackers that are linked to the Platform;
Service providers;
Health care providers;
Affiliates not under the Virtual Health Partners brand; and
Business partners of Virtual Health

Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Notice. These commercial and business purposes include, without limitation:

Our commercial purposes, including marketing, advertising, and enabling commercial
Our business purposes as identified in the CCPA, which include:
- Auditing related to our interactions with you;
- Legal compliance;
- Detecting and protecting against security incidents, fraud, and illegal activity;
- Debugging;
- Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
- Internal research for technological improvement;
- Internal operations;
- Activities to maintain and improve our services; and
- Other one-time

Recipients of California Personal Information. We sell the categories of personal information designated above to the categories of third parties listed below:

None

We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes:

Service providers;
Affiliates not under the Virtual Health Partners brand;
Internet service providers;
Data analytics providers; and
Operating systems and platforms.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding personal information about you, subject to certain exceptions and limitations:

The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected personal information about you, our purposes for collecting or selling personal information about you, the categories of personal information about you that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
The right to request that we delete the personal information we have collected from you or maintain about you.
The right to opt out of our sale(s) of personal information about Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

By phone 877-586-1733
Online at privacy@virtualhp.com

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum your first and last name, email, phone number, date of birth, city, state & country.

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by emailing support@virtualhp.com with proof of delegation of authority.

Minors’ Right to Opt In. We do not sell the personal information of minors under 16 years of age

The median number of days within which VHP substantively responded to California consumers’ requests to know, requests to delete, and requests to opt out in the previous calendar year is 0 days.

Your Choices

You may unsubscribe from receiving promotional emails from us by following the instructions provided in those email communications. Please note that even if you opt out of receiving promotional communications from us, we may continue to send you non-promotional emails, such as communications regarding our ongoing relationship with you.

Many web browsers provide options to allow you to stop accepting new cookies, or to disable existing cookies. Please be aware that if you disable the cookies on your device, you may not be able to use certain features of the Platform or other websites. In addition, disabling cookies may invalidate opt outs that use cookies to recognize devices that have opted out.

Information for Users Outside the United States

If you are visiting us from outside the United States, please be aware that information we collect will be transferred to and stored on our servers in the United States. By using the Platform, you acknowledge and consent to the transfer and processing of your personal data in the United States as described in this Privacy Notice. Please be aware that the data protection laws and regulations applicable to your personal data transferred to the United States may be different from the laws in your country of residence.

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Notice and requesting your consent the next time you login to the Platform. We encourage you to review this Privacy Notice whenever you use the Platform to stay informed about our information practices.

How to Contact Us

If you have questions regarding this Privacy Notice you may email us at privacy@virtualhp.com or write to us at:

Virtual Health Partners Attention: Privacy Inquiry 353 3^rd Ave, #365

New York, New York 10010