What This Privacy Policy Covers

This Privacy Policy outlines the procedures by which Vital Quest Journey and its affiliated entities (collectively referred to as “Vital Quest Journey”) may collect, utilize, and disclose your Personal Data when you engage with or utilize our Services. “Personal Data” encompasses any information that specifically identifies or pertains to an individual, and it includes data referred to as “personally identifiable information” or “personal information” according to relevant data privacy laws, rules, or regulations.

It is important to note that this Privacy Policy does not extend to the practices of third parties or companies beyond the ownership or control of Vital Quest Journey or individuals not under our management. Additionally, Protected Health Information, as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the HIPAA Privacy Rule, collected by the Practice (as defined herein) and providers with whom Vital Quest Journey contracts to facilitate medical visits through the Vital Quest Journey platform is not covered by this Privacy Policy. While Vital Quest Journey currently contracts with these medical groups (referred to as the “Practice”), it’s worth mentioning that the medical groups we engage with may undergo changes over time.

The following Details contained below detail how Vital Quest Journey and the Practice may handle your Protected Health Information. If you disagree with these terms, available below, we recommend refraining from accessing or utilizing Vital Quest Journey services.

Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW YOUR PROTECTED HEALTH INFORMATION MAY BE USED AND DISCLOSED WHEN YOU USE SERVICES PROVIDED THROUGH VITAL QUEST JOURNEY AND ITS AFFILIATED PRACTICES AND PROVIDERS. “Providers” are professionals contracted or employed by independently owned professional practices that collaborate with Vital Quest Journey to offer specific healthcare services. The Practices may disclose Protected Health Information (or “PHI”) (as defined by HIPAA) to Vital Quest Journey in connection with its role as a business associate and for use consistent with this Notice. In this Privacy Notice, Vital Quest Journey, the “Practices and Providers, collectively, may be referred to as, “Vital Quest Journey,” “us,” “we,” or “our”).

Vital Quest Journey is dedicated to safeguarding the privacy of your Protected Health Information (PHI). In compliance with legal obligations, we commit to: (a) furnish you with this Notice outlining our legal responsibilities and privacy practices regarding your PHI; (b) adhere to the terms of the currently effective Notice; and (c) inform you in case of a breach involving your PHI. Furthermore, we are obligated to provide you with details on: (i) how we may utilize and disclose your PHI; (ii) your privacy rights; and (iii) our responsibilities concerning the usage and disclosure of your PHI.

It’s essential to clarify that this Notice does not serve as an authorization. Instead, it delineates how we, our business associates, and their subcontractors may use and disclose your PHI for purposes such as treatment, payment, or health care operations, and as allowed or mandated by law. Additionally, it outlines your rights to access and control your PHI.

USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION

A. Routine Uses and Disclosures of Protected Health Information

Vital Quest Journey is authorized under federal law to utilize and disclose Protected Health Information (PHI) for specific purposes, such as treatment, payment, and health care operations. Generally, your permission is not required for these uses or disclosures in accordance with applicable laws. The following examples illustrate the types of routine uses and disclosures of PHI that we are allowed to make without seeking your permission. While this list is not exhaustive, it provides insight into the routine uses and disclosures permitted without your explicit consent.

For Treatment: We maintain a record of your PHI, encompassing lab results, diagnoses, medications, your response to medications or other therapies, and information acquired during the provision of our Services. We may use and disclose this information and other PHI to deliver, coordinate, and manage your treatment, as well as to apprise you of treatment alternatives and other health-related benefits, products, and services that may be of interest to you. Additionally, we may share this information and other PHI with healthcare professionals (including Providers) and/or other third parties to facilitate, coordinate, and oversee the delivery of your healthcare. For instance, we may disclose your PHI to a pharmacy for prescription fulfillment, to a laboratory for test orders, or to another specialist for consultation.

For Payment: As necessary, we may use and disclose your PHI to facilitate billing and obtain payment for the healthcare services rendered to you. Your PHI may be shared with healthcare providers (including Providers), health plans, and healthcare clearinghouses for their payment-related activities. For instance, we may leverage and disclose PHI about you to receive payment for our services, manage your account, and fulfill our obligations under your health plan.

For Health Care Operations: Your PHI may be utilized or disclosed to support the business activities of the Practices. These activities encompass, but are not limited to, reviewing our treatment and services, enhancing the services we offer, training and assessing the performance of our staff in delivering services, and providing customer service. Furthermore, we may use your PHI to assess and enhance services provided by our business associates, including those offering data assessment and management, and other services for or on our behalf, such as Vital Quest Journey.

B. Uses and Disclosures That May Be Made Without Your Authorization or Opportunity to Object

Vital Quest Journey may utilize or disclose your PHI in the following situations without seeking your authorization and without providing you an opportunity to object.

Required by the Secretary of Health and Human Services: We may be obligated to disclose your PHI to the Secretary of Health and Human Services for the purpose of investigating or determining our compliance with the requirements of the HIPAA Privacy Rule.

Required By Law: Your PHI may be used or disclosed to the extent mandated by federal, state, or local law.

Public Health: We reserve the right to disclose your PHI for public health activities, such as tracking diseases and/or medical devices. This may involve making disclosures to a public health authority or other government agency authorized by law to collect or receive such information (e.g., the Food and Drug Administration). These activities typically include: (a) preventing or controlling disease, injury, or disability; (b) reporting births and deaths; (c) reporting child abuse or neglect; (d) reporting reactions to medications or issues with products; (e) notifying individuals of product recalls; or (f) notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition. If we possess genetic testing information about you, we will release that information only to the state departments overseeing our work or if required by law to disclose such information.

Health Oversight: We retain the option to disclose PHI to a health oversight agency for activities sanctioned by law, including audits, civil, administrative, or criminal investigations, inspections, licensure or disciplinary actions, civil, administrative, or criminal proceedings or actions, or other activities essential for overseeing the health care system, government benefit programs, or entities subject to government regulations or civil rights laws. Oversight agencies encompass government entities responsible for overseeing the health care system, government benefit programs, other government regulatory programs, and civil rights laws.

Abuse or Neglect: In instances where you have experienced abuse, neglect, or domestic violence, we may disclose your PHI to a government agency authorized to receive such information. Additionally, we may disclose your PHI to a public health authority authorized by law to receive reports of child abuse or neglect.

Judicial and Administrative Proceedings: Your PHI may be disclosed in response to an order from a court or administrative tribunal and, under certain circumstances, in response to a subpoena, discovery request, or other lawful process.

Law Enforcement: We may disclose your PHI, provided that applicable legal requirements are met, for law enforcement purposes, such as providing information to the police about the victim of a crime.

Coroners and Funeral Directors: Your PHI may be disclosed to a coroner, medical examiner, or funeral director if necessary to perform their legally authorized duties. This may include identifying a deceased person, determining a cause of death, or as authorized by law.

Organ Donation: If you are an organ donor, we may disclose your PHI to organ, eye, or tissue donation or procurement organizations as necessary to facilitate organ, eye, or tissue donation, procurement, or transplantation.

Research: In specific situations, we may use and disclose your PHI for internal and external research purposes. This includes efforts to develop and enhance our services and products. Under certain circumstances, we may also disclose your PHI to organizations dedicated to supporting medical research or those focused on discovering, investigating, or curing diseases.

Serious Threat to Health or Safety: Your PHI may be disclosed if we believe it is necessary to prevent a serious threat to the health or safety of an individual or the public. This disclosure would be made to someone we reasonably believe is capable of preventing or mitigating the threat.

Specialized Government Functions: Under appropriate conditions, we may disclose PHI for purposes related to military or national security concerns. This includes activities such as a determination by the Department of Veterans Affairs of your eligibility for benefits. If you are a member of the armed forces, we may release PHI about you as required by military command authorities. Additionally, we may disclose PHI about foreign military personnel to the relevant foreign military authority.

National Security and Intelligence Activities: Your PHI may be disclosed to authorized federal officials for intelligence, counterintelligence, protection of the President, other authorized persons, or foreign heads of state. This is done for the purpose of determining your security clearance and other national security activities authorized by law.

Workers’ Compensation: We may disclose your PHI to workers’ compensation carriers or your employer if you sustain an injury at work. This disclosure is authorized by, or as necessary to comply with, workers’ compensation laws and similar programs. If you prefer workers’ compensation not be notified, alternative insurance or payment information must be provided.

For Appointment Reminders and Health-Related Benefits and Services: Your demographic PHI may be used to contact you for appointment reminders or to suggest potential treatment options or alternatives that may be of interest to you.

For Marketing Activities: We may use your PHI to contact you in an attempt to encourage you to purchase or use a product or service. However, if we receive any direct or indirect payment for such communication, we would require your prior written permission unless the communication (a) only describes a drug or medication currently prescribed for you, and our payment for the communication is reasonable, or (b) is made by one of our business partners in accordance with our written agreement with that partner.

Inmates: If you are an inmate of a correctional facility, we may use or disclose your PHI to that facility. This applies if we created or received your PHI while providing care to you. The disclosed information may include details necessary for the correctional facility to furnish you with healthcare, protect your health and safety, the health and safety of others, or the safety and security of the institution.

Business Associates: We reserve the right to disclose your PHI to individuals or entities performing functions, activities, or services for us or on our behalf that necessitate the use or disclosure of PHI. To safeguard your health information, we require these business associates to appropriately protect your information.

De-identified Information: Your PHI may be de-identified for any of the purposes outlined above. De-identified PHI, in accordance with HIPAA standards, is no longer protected under HIPAA and may be used and disclosed for any lawful purpose, including certain research-related purposes.

C. Uses and Disclosures That May Be Made either With Your Agreement or the Opportunity to Object

Unless you specifically object, either wholly or partially (which you can do at any time), Vital Quest Journey may disclose your PHI to a member of your family, a relative, a friend, or any other person you identify (verbally or in writing) as being involved in your care or the payment for your healthcare. This disclosure would be limited to PHI directly related to that person’s involvement in your healthcare. If you are unable to agree or object to such disclosure, we may disclose the information that we deem necessary and in your best interest, based on our professional judgment. Additionally, we may use or disclose your PHI to notify or assist in notifying a family member, personal representative, or other person responsible for your care of your location or general condition.

D. Uses and Disclosures of Protected Health Information Based upon Your Written Authorization

Psychotherapy Notes: For most uses and disclosures of psychotherapy notes, we must obtain your written authorization.

Marketing: Your written authorization is required for most marketing purposes involving the use and disclosure of your PHI (as defined by HIPAA), except as noted above.

Sale of PHI: Your written authorization is necessary for any disclosure of your PHI constituting a sale of PHI.

Other Uses: Uses and disclosures of your PHI not described above, or not otherwise permitted by HIPAA, will be made only with your written authorization unless permitted or required by law. If you provide written authorization to release your PHI, you may revoke that authorization in writing. Revocation will cease any future release of your PHI but will not alter what was released pursuant to the valid authorization.

To the extent mandated by law, when using or disclosing your PHI, or when requesting your PHI from another covered entity, we will make reasonable efforts not to use, disclose, or request more than a “limited data set” (as defined by HIPAA) of your medical information. If necessary, we will request no more than the minimum amount of medical information needed to accomplish the intended purpose of the use, disclosure, or request, taking into consideration practical and technological limitations.

E. We Utilize an Electronic Health Record for the Creation, Storage, and Maintenance of Your Medical Record.

To enhance the quality of your medical care, Vital Quest Journey employs an electronic health record (“EHR”) for the creation, storage, and maintenance of your medical record. The EHR enables us to exchange your PHI with other Providers who have treated you and also utilize the EHR. However, this occurs only when the purpose for seeking your PHI is to provide you with treatment, obtain payment for your medical treatment, or perform other administrative tasks permitted by our privacy policies and law. Providers will refrain from sending or receiving your PHI through the EHR for any other purposes.

II. YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION

You hold certain rights regarding your PHI, as outlined below.

A. You have the right to review and obtain copies of portions of your PHI. If you wish to inspect or receive a copy of your PHI within a designated record set (e.g., medical and billing records), you must submit a written request. You can request your PHI in either paper or electronic format. We are obligated to provide such PHI within 30 days after receiving your written request (or a shorter period if directed by state law) with the possibility of a 30-day extension if necessary. A reasonable fee may be charged to cover duplication, mailing, and other related costs incurred by us in fulfilling your request. There are circumstances in which we may deny your request for access to your PHI. In such cases, we will inform you of the reasons for the denial. For example, we may deny your request if we believe the disclosure would jeopardize your life or that of another person. Depending on the circumstances, you may have the right to have this decision reviewed.

B. You have the right to request restrictions on how we use or disclose your PHI. You may request limitations or restrictions on the PHI we use or disclose about you for treatment, payment, or health care operations. Additionally, you can request limits on the PHI we disclose about you to someone involved in your care or the payment for your care, such as a family member or friend. Your request must specify the desired restriction and to whom it should apply. We are not obligated to agree to a requested restriction except in cases where we must agree not to disclose your PHI to your health plan if the disclosure (a) is for payment or health care operations (not treatment purposes) and is not otherwise required by law, and (b) relates to a health care item or service for which we have been fully paid out-of-pocket. If we agree with (or are required to honor) your request, we will document any limits in writing and adhere to them, except in emergency situations. You may not restrict any use or disclosure of your PHI if we are legally mandated to release such information.

C. You have the right to request confidential communications from us through alternative means or at an alternative location. You can request that we communicate with you in a specific way (e.g., email instead of regular mail) or at a particular location (e.g., sending information to your work address instead of your home address). We will accommodate reasonable requests as long as we can easily provide the information in the requested format. Any additional costs incurred will be your responsibility for payment.

D. You have the right to request the correction or update of your PHI. If you believe there is an error in your PHI or that important information is missing, you may request that we correct or add the missing information. This can be done as long as we maintain the PHI. You must submit the request and provide the reasons in writing. We will respond to your request within 60 days (or a shorter period if directed by state law), with a possible 30-day extension if necessary. If we approve your request, we will make the changes to your PHI, inform you of the modifications, and notify others who need to be aware of such changes or amendments. If we determine that your PHI is accurate and complete, we may deny your request. In case of denial, we will provide a written explanation stating the reasons and outline your right to file a written statement of disagreement. If you choose not to file a written statement of disagreement, you have the right to request that your request and our denial be attached to all future uses or releases of your PHI.

If you are a California resident, you have the right to submit a 250-word addendum about anything in your record with which you disagree. Upon your request, we will include this addendum in your medical record. We may add a written rebuttal to the addendum and provide you with a copy of this rebuttal.

E. You have the right to receive a list of instances and recipients to whom we have disclosed your PHI (an “accounting of certain disclosures”). This list will exclude disclosures made for treatment, payment, and health care operations purposes, or any disclosures made directly to you. You may request one free accounting within any 12-month period, and we may charge for additional requests in the same 12-month period. We will notify you of any charges, and you are free to withdraw or modify your request in writing before incurring any charges. We will respond to your request within 60 days (with a potential 30-day extension if necessary). Additionally, we will notify you, as required by law, if there has been any breach of your PHI.

NO WAIVER

Vital Quest Journey will never compel you to waive your rights under the HIPAA Privacy Rule or the HIPAA Breach Notification Rule as a condition for receiving services or treatment.

CHANGES TO THIS NOTICE

We retain the right to amend this Notice and adjust our privacy practices outlined herein at any time. Any alterations or modifications to this Notice will apply to all of your records that we created or maintained in the past and to any records that we may create or maintain in the future. The most up-to-date version of our Notice will always be accessible on our website at vitalquestjourney.com

Personal Data

We may gather Personal Data about you from various sources:

  1. You
    • When you provide information directly to us by:
      • Creating an account or using our interactive tools and Services.
      • Linking your activity tracker or wireless-enabled wearable technology device (such as a Fitbit or Apple watch) to the Services to track metrics like sleep minutes per day.
      • Providing information in free-form text boxes through the Services or in responses to surveys or questionnaires.
      • Sending us an email or other electronic message.
    • When you use the Services and information is automatically collected:
      • Through Cookies (as defined in the “Tracking Tools, Advertising, and Opt-Out” section below).
      • If you use a location-enabled browser, we may receive information about your location.
      • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device to provide you with Services, such as information about when you are logged on and available to receive updates or alert notices.
  2. Third Parties
    • Vendors
      • We may use analytics providers to analyze how you interact and engage with the Services.
      • Third parties may assist us in providing customer support.
      • Vendors may provide information to generate leads and create user profiles.
    • Employers
      • If your employer offers the Services as a benefit of employment, we may receive specific information from them about you to enable your account and/or facilitate the provision of or payment for the Services.
    • Affiliates
      • Information about your participation in the Services may be received from our affiliates, such as professional health care providers, dietitians, or nutritionists (including the Practice and Providers).
    • Advertising Partners
      • Information about you may be received from vendors assisting us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements, or communications.
    • Social Networks
      • If you provide your social network account credentials to us or sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Our Commercial or Business Purposes for Collecting Personal Data

  1. Providing, Customizing, and Improving the Services
    • Creating and managing your account or other user profiles.
    • Processing orders or other transactions; billing.
    • Providing you with the products, services, or information you request.
    • Meeting or fulfilling the reason you provided the information to us.
    • Providing support and assistance for the Services.
    • Improving the Services, including testing, research, internal analytics, and product development.
    • Personalizing the Services, website content, and communications based on your preferences.
    • Fraud protection, security, and debugging.
    • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
  2. Marketing the Services
    • Marketing and selling the Services.
    • Showing you advertisements, including interest-based or online behavioral advertising.

Corresponding with You

  • Responding to correspondence we receive from you, contacting you when necessary or requested, and sending you information about Vital Quest Journey or the Services.
  • Sending emails and other communications according to your preferences or that display content we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

  • Fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property, or safety of you, Vital Quest Journey, or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without updating this policy.

How We Share Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties described in this section. Depending on applicable state law, some of these disclosures may constitute a “sale” of your Personal Data. Additional information is provided in the state-specific sections below.

Service Providers: These parties help us provide the Services or perform business functions on our behalf. They include:

  • Hosting, technology, and communication (including email) providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.
  • Data analytics providers.
  • Payment processors. Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment. Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.

Advertising Partners: These parties help us market our services and provide you with other offers that may be of interest to you. They include:

  • Ad networks.
  • Marketing providers.

Analytics Partners: These parties provide analytics on web traffic or usage of the Services. They include:

  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.

Business Partners: These parties partner with us in offering various services. They include:

  • Businesses that you have a relationship with.
  • Companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access, or Authenticate:

  • Third parties you access through the services.
  • Social media services.
  • Other users.

Legal Obligations: We may share any Personal Data we collect with third parties to assist in “Meeting Legal Requirements and Enforcing Legal Terms” as described in “Our Commercial or Business Purposes for Collecting Personal Data” above.

Business Transfers:

  • All your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should such an event occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data:

  • We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including analyzing, building, and improving the Services and promoting our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you and remember your preferences (for example, your choice of language or region).
  • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
  • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/.

Information about Interest-Based Advertisements:

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based on a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure by using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

Calibrate Services are only available to individuals age 18 or older and we do not knowingly collect or solicit Personal Data about children under 13 years of age. If you are a child under the age of 13, do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as soon as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, contact us at support@vitalquestjourney.com

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us support@vitalquestjourney.com

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

  • The categories of Personal Data that we have collected about you.
  • The categories of sources from which that Personal Data was collected.
  • The business or commercial purpose for collecting or selling your Personal Data.
  • The categories of third parties with whom we have shared your Personal Data.
  • The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or to complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (as defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (first and last name and email address, and you may be asked to provide your telephone number or address), and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) are excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Vital Quest Journey does not receive remuneration from third parties for your Personal Data and has not over the last 12 months. To our knowledge, we do not sell any Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under this Privacy Policy, the CCPA, or other applicable law. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under this Privacy Policy, the CCPA, or other applicable law. However, we may offer different tiers of Services as permitted by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@vitalquestjourney.com

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@vitalquestjourney.com with the subject line “Nevada Do Not Sell Request” and providing us with your full name and the email address associated with your account.

Connecticut, Colorado, Utah and Virginia Resident Rights

If you are a resident of Connecticut, Colorado, Utah, or Virginia, you may have the right to opt-out of the sale of certain Personal Data to certain third parties. You can exercise this right by contacting us at support@vitalquestjourney.com with the subject line “Do Not Sell Request” and providing us with your state of residence, full name, and the email address associated with your account.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time; when we do, we will post the updated Privacy Policy on the Calibrate website. Please check the revision date at the top of this Privacy Policy to see if it has been updated since you last reviewed it. The updated Privacy Policy will be effective immediately upon posting on the Calibrate website; if you continue to use the Services after the Privacy Policy has been updated, that means you agree to all of the changes. If you object to any update of the Privacy Policy, your sole recourse is to stop using the Services.

Customer Service Information

Refund and Terms of Purchase: Zero Refunds for consultation. Client can cancel up to 48 hours after ordering with a written email to support@vitalquestjourney.com. After 48 hours payments are non-refundable.