Vitality Internet Privacy Statement
Relationships are built on trust. One of the most important elements of trust is respect for an individual’s privacy. Vitality values our relationship with you, and we take your personal privacy seriously.
We are committed to ensuring that users of this website understand this website’s privacy practices. This Internet Privacy Statement will outline:
- What personal information we may collect
- How we may utilize that personal information
- Who may have access to the personal information
- How we protect the personal information within the secure infrastructure of this website
This Internet Privacy Statement applies to this website, the services provided and the information collected.
If you have questions or concerns about this Internet Privacy Statement or the privacy practices of this website, please contact the Vitality Privacy and Security Committee, Vitality Group, 200 W. Monroe Street, Suite 1900, Chicago, IL 60606.
Attn: Frank Fatigato
200 W. Monroe St., Suite 1900
Chicago, IL 60606
Vitality Group has elected the EU Data Protection Authorities (DPAs) as its independent recourse mechanism available to ensure users that Vitality is consistently in compliance with the Privacy Shield Privacy Principals. Users may contact the appropriate DPA by visiting http://ec.europa.eu/justice/data-protection/bodies/index_en.htm.
Under limited circumstances, an arbitration option is available to an individual to determine, for residual claims, whether Vitality Group has violated its obligations under the Principles as to that individual, and whether any such violation remains fully or partially unremedied.
Commitment to Confidentiality
Confidentiality is a top priority at Vitality. We are committed to maintaining the highest level of confidentiality with all of the information we receive from this website’s users. This Internet Privacy Statement assures you that the information you share with Vitality is kept confidential and fully secure.
Links to other websites may be available to provide you with additional useful information and services. Links that take you off this website are clearly labeled. Vitality is not responsible for the privacy policies or actions of those who control other websites. We encourage you to look for and review the privacy policies of any website you visit.
Vitality may also partner with third parties and provide links to their websites to offer you additional information and services. You may see both the Vitality logo and the third party’s logo on these third-party websites. Users of these websites should be aware of who is collecting personal information and whose Internet Privacy Statement applies before providing personal information. Vitality may not have control over third-party partners’ use of your information.
Collection and Use of Personal Information
Users of this website have the option to provide certain personal information. This personal information may be required in order to receive services and administration of your incentive based wellness program. By providing such information, you are agreeing that Vitality may store, process and review such information. We may use this personal information for the purposes for which it was collected.
We collect certain personally identifiable information from our users at different places within this website. Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, mail address, telephone number, etc. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and address).
We may use the voluntarily provided contact information to notify website users of updates, products, services or upcoming events. Website users who do not wish to receive such notifications via email can choose to opt out of receiving such information. It is our policy that email messages will contain an “unsubscribe” feature, along with instructions on how to execute the unsubscribe function.
We recognize that when website users choose to provide personal information, they trust that we will protect their privacy and will provide them with choices about how that information is shared. Vitality will not sell, trade or rent the personal information that you provide unless required to do so by law.
There are instances in which Vitality may disclose your personal information to our agents, third-party partners, affiliates and subsidiaries to enable them to perform functions on our behalf. These business functions may include order or service fulfillment, email campaign provider, and/or credit card processing service. These companies are only permitted to share, store and/or use personal information for contracted business purposes. Vitality acknowledges that under the EU-US Privacy Shield liability may arise if its agents or third-party vendors process personal information in a manner inconsistent with the Privacy Shield Principals.
Vitality may also share with your employer or plan sponsor offering Vitality the minimum necessary information for your employer to administer your incentives. Such information may include, but is not limited to your Vitality Status level (such as Silver or Gold), or whether or not you have completed your Vitality Health Review or Vitality Check. Again, Vitality will share information only to the extent needed for plan administration, such as calculation of health plan premium discounts, health club dues subsidies, or other arrangements for which such information is relevant.
With your express authorization and consent, we may share more detailed information with your benefit administrator in support of the administration of your employer’s benefit structure. Agreeing to these terms and conditions is not your express authorization. When appropriate, while you are logged into the Power of Vitality website, you will be presented with a specific electronic authorization form on which you may or may not provide your consent. Such authorization can be revoked at any time by navigating to your My Accounts page within the Power of Vitality website.
We may share your personal information when we believe that such action is necessary to:
- Fulfill an enforceable government request
- Conform with the requirements of the law or legal process
- Protect or defend our legal rights or property, this website, or other users
- Protect your health and safety or the health and safety of this website’s users or the general public
Subject to certain exceptions, users of this website have the ability to access, correct, or delete information about themselves that Vitality Group holds.
Technology Use on This Website
Information about you and your use of this website is collected through the use of session cookies. Session cookies are small text files that are stored within your computer. These files are used to facilitate your navigation throughout this website.
Persistent cookies are small computer files that are transferred to your computer’s hard drive. These stored files are used in the generation of data that is fed to a contracted third party for website usage analysis. Reports created using this information will provide Vitality with a better understanding of the use of this website. You may choose one of three different levels of data collection associated with the use of the persistent cookie. Transfer to Persistent Cookie Opt-out Options for more information. Information stored within both session and persistent cookies are not tied to your personally identifiable information.
To gauge the effectiveness of this website, we may collect non-personal information about our website users. This information may include, among other things, your: IP address, browser type, internet service provider (ISP), domain names, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the website, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically collected data to personal information.
Internal Security Procedures
Information that you share on the website is kept strictly confidential and fully secure. Your encrypted (encoded) information is protected using “Secure Socket Layers (SSL)” as it passes between your browser and this website. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Only authorized persons are permitted to access your personal information. All authorized persons must abide by security, privacy, and confidentiality agreements, rules and laws.
If you send questions or comments to an email address listed within this website or via a contact form located within this website, we will share your correspondence with a Vitality associate most capable of addressing your questions and concerns. We will retain your communications until we have done our very best to provide you with a complete and satisfactory response. Ultimately, we will either discard your communication or, in some cases, archive it. We will not keep your email address for secondary purposes. All information and correspondence you share with us will be handled in the strictest confidence.
We may agree that email has become a standard communication tool used by many different parties. Unfortunately, by design standard Internet email is not secure. For that reason, please do not use unsecured email to communicate information to us that you may consider to be confidential.
California Privacy Rights
Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing by contacting Vitality at the contact information listed at the bottom of this Internet Privacy Statement.
Internet Privacy Statment Changes
This Internet Privacy Statement is effective as of June 2011 and was last updated in September of 2016. This Internet Privacy Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.
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200 West Monroe St. Suite 1900
Chicago, IL 60606