Effective Date: July 23, 2019
1. Information We Collect
When you interact with us through the Services, we may collect PII and other information from you, as further described below:
a. PII That You Provide Through the Services
b. Other Information
When you utilize the Services, we may receive certain non-personally identifiable information (“non-PII”) about your use of the Services. Such information, which may be collected passively using various technologies, or via submission of data by fitness devices you have configured to work with the Services, cannot presently be used to specifically identify you. This may include certain PII which has been aggregated and/or sufficiently anonymized so that it cannot be used to specifically identify you; restricting such use to location information, gender, age and other anonymous and/or aggregate level data. We may store such information ourselves or it may be included in databases owned and maintained by our affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to the Services, the number of visitors to each page of the Services, and the domain names of our visitors’ internet service providers. It is important to note that no PII is available in this process; any PII which is used will be sufficiently anonymized so that it cannot be used to specifically identify you.
Cookies. A Cookie is a string of information that a website saves on a visitor’s computer or mobile device and that the visitor’s browser provides to the website operator each time the visitor returns. Our cookies help provide additional functionality to the Services and help us analyze usage of the services more accurately. For instance, our Services may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to the site.
Most web browsers will include a “help” section on the toolbar where you can learn how to receive notifications when you are receiving a new cookie and how to turn cookies off. We recommend leaving your cookies on in order to take advantage of some of the exciting features of our Services. Please be advised that disabling your cookies may result in the Services not functioning properly or not functioning at all.
c. Aggregated and Anonymized Personal Data
In an ongoing effort to better understand and serve our Services’ users, we may conduct research on our end user’s demographics, interests and behavior based on the PII and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregated data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
2. Our Use of Your PII and other Information
3. Our Disclosure of your PII and other information
There are certain circumstances in which we may share your PII with certain third parties without further notice to you, including as set forth below:
a. Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event of a sale, merger, reorganization, dissolution or similar event relating to all or a portion of our business or assets, PII may be part of the transferred assets.
We will assure that the resulting entity’s policies and procedures re PII meet or exceed those of our company.
In the event of a business transfer, all Veterans will be notified by email and/or text and given the options to:
(i) securely dispose of, transmit, or download their health information, or,
(ii) close their account.
b. Service Providers, Agents and Related Third Parties
We sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we may need to provide them with access to certain PII. However, we only provide them with the information that they will need to perform their specific function, and these third party service providers will only use your PII to perform the services requested by us.
Some of our Service Providers, Agents and/or Related Third Parties will only be relevant to you in the event that you have affirmatively chosen to utilize their offerings; if this is applicable, then you expressly consent to such Service Providers’, Agents’ and/or Related Third Parties’ privacy policies and/or terms of service as the case may be. We encourage you to consult the privacy policies and/or terms of service, as may be applicable, for Service Providers, Agents and/or Related Third Parties before choosing to utilize their offerings in order to understand their treatment of your information.
c. Legal Requirements
We may also disclose your PII if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
4. Your Choices
All such Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
7. Links to other websites
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline if they fail to meet those obligations. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any PII to us via the internet.
9. Data Integrity
12. Access to Information
We strive to keep your PII accurately recorded. Through the Services, we provide you with access to update your profile and revise your PII previously submitted to the Services.
13. Contacting us