Bravo Wellness Privacy Statement

Effective Date: December 1, 2016

 

This Privacy Statement (“Statement”) applies to this website and the websites and mobile applications of Bravo Wellness and its subsidiaries and affiliates (collectively “we”, “us” or “our”) that display this Statement (each a “Site” and collectively, the “Sites”). By visiting the Sites, you are consenting to our collection, use, disclosure, retention, and protection of information about you and devices you use as described in this Statement.

Bravo Wellness works with health insurance companies, employer-sponsored health plans and other organizations that are concerned about your health and wellbeing (“Sponsors”) as well as employers to provide health and wellness programs (“Programs”). Programs may involve assessing the impact that behaviors and habits have on your general health and address general health information, nutrition, exercise and other healthy habits.

This Statement applies only to participants in our Programs and visitors to the Site. Our Sites are not directed to children under the age of 13. We do not knowingly collect personal information from children under age 13. This Statement does not apply to anonymized or aggregated data that does not allow us or third parties to identify or contact you.

 

1. What Information Does Bravo Wellness Gather?

Information You Give Us. We may collect and retain any information from you or your devices provided to us when you visit a Site, including when you:

  • register for a Program;
  • enter information about yourself in connection with a Program;
  • communicate with us, such as to provide feedback, request support, or ask for additional information;
  • subscribe to content we offer, such as newsletters, alerts, etc.;
  • schedule an onsite screening; and
  • use the messaging capabilities of the Site.

We may collect information from you such as: your and your spouse’s name, date of birth, the last four digits of your social security number, mailing address, telephone numbers and email address. In addition, we may also collect health-related information such as medical history, lifestyle information, and healthcare provider information.

Information Provided to Us By a Sponsor or Employer. When you are eligible to participate in a Program, a Sponsor or employer may provide us with information about you such as: your and your spouse’s name, social security number, date of birth, gender, mailing address, telephone number, health coverage details, your work location and employee ID.

Information Provided to Us by Your Healthcare Provider or Third Party Lab. When you participate in a Program-related event at your employer or ask a healthcare provider or lab to complete a form provided by us to collect your health-related measurements, we may receive information such as your biometric data and blood test data and results.

Protected Health Information. Some of the information we collect is defined as “Protected Health Information” and protected by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH) or their implementing regulations (collectively, the HIPAA Rules). Protected Health Information includes individually identifiable information, such as your name, that is combined with medical or health insurance-related information that is collected or maintained by a Sponsor or medical provider.

Automatically Collected Information. We may collect information automatically when you visit our Sites, such as:

  • your IP address;
  • the type of browser, devices and operating systems you use;
  • identifiers associated with the device(s) you use to access our Sites;
  • the pages you visit, including dates and times;
  • if you navigated from or navigate to another website, the address of that website; and
  • information regarding your internet service provider.

In addition, we may collect information about your activities on our Sites through the use of cookies, clear GIFs or web beacons, local shared objects or Flash cookies, or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as Metrics Tools. For example, we use the Google Analytics platform to gather and analyze data regarding the use of our Sites.

We may allow third parties to use Metrics Tools on our Sites. The information collected by Metrics Tools may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. For information regarding Google’s use of the data we collect on our Sites, visit https://www.google.com/policies/privacy/partners/. Information collected by Metrics Tools may be used on this Site or on other websites or services, including those that may not be operated by us.

Information from Other Sources. We may obtain information about you from affiliates, partners, and other third parties. This information may include address information from publicly available databases to verify your address before we send you mail the U.S. “Do Not Call” database to verify your preferences in that database and aggregate data sources such as the U.S. census or other statistical databases that contain information about people who are demographically similar to you (e.g., age, geography). We may combine the information we obtain from third parties with information that we or our affiliates have collected about you.

 

2. How Does Bravo Wellness Use Information About Me?

We and others acting on our behalf may use the information that we collect or receive to operate our business, including our Sites, as described below:

Operate and Support our Programs and Sites. We use the information that we gather in order to operate our Sites. For example, we may use the information that we collect or receive to provide support and assistance that you request or to diagnose or address technical problems in the operation of our Sites. If you establish an account with us, we may use information about you to manage or support your account and to determine your eligibility to participate in our Programs, provide you with our services and tailor our services to you.

Improving and Evolving our Sites and Programs. We constantly evaluate and improve our Sites and Programs, including developing new products or services and use the information we gather to do so.

Other Contacts. We may contact you through telephone, postal mail, text messages or email for other purposes, as permitted by law. Bravo will never sell your information or contact you in an effort to sell you a product or service.

 

3. When Does Bravo Wellness Share Information?

We only share information about you as described or permitted by this Statement, unless you consent to other sharing. We may further limit the way we share your information according to the direction of your Sponsor and any privacy policy that they may ask as to comply with. Our transfers of information to third parties are covered by the agreements we have with our Sponsors. We may share information about you in the following ways:

Healthcare Providers. We may share information with your healthcare providers and any clinics or organized healthcare organizations with whom they are associated.

Other Participants. Your Sponsor may ask us to create wellness-based contests between you and other participants. If you participate in these contests, we may share limited information about you with other participants. For example, if you enter a contest based on the number of cups of coffee you drink per day, other participants may see your name, that you are participating in the contest and the number of cups of coffee you drink. Your information will not be available unless you enter the contest.

Sponsors. Under U.S. laws, we may share Protected Health Information and biometric information with Sponsors for plan administration purposes and the coordination of your care.

Your Employer. We will not share your Protected Health Information with your employer for employment-related purposes. We may only share the information needed to administer plan and deliver Programs. For example, we may share the number of points you have earned by participating in a Program or a related contest.

Corporate Affiliates. We may share information with our corporate affiliates for their everyday business purposes to provide services. We may also participate in joint ventures with others and we may share information as permitted by this Statement as part of that joint venture.

Third-Party Service Providers. We may share your information with our third party service providers who provide Program-related services such as coaching. We may also employ other companies and individuals to perform functions on our behalf. Examples include sending postal mail and e-mail, removing repetitive information from participant lists, analyzing data and providing marketing assistance. They have access to personal information needed to perform their functions, but may not use it for other purposes.

Business Transfer. We may share information we have collected from you in connection with the sale or merger of our business or the transfer of assets.

Protection of Ourselves and Others. We may use and share the information we gather to enforce our rights and protect our property and those of our affiliates, customers and members of the public, to comply with applicable law, legal process, legal advice and for preventing fraud, theft, and injury to you, us or others.

 

4. What Choices Do I Have Regarding My Information?

You may limit and control the information provided to us in a number of ways. You may not be able to use all features of our Sites or Programs if you limit the information you share with us.

You may unsubscribe from promotional emails from us by following the unsubscribe link included in each such email.

You may also have additional rights with respect to Protected Health Information as may be explained in your Sponsor’s “Notice of Privacy Practices.” Please contact your Sponsor for that Notice.

Your browser and your device may provide you the option to limit the use of cookies or other Metrics Tools. You should consult documentation for your browser or device for more information.

 

5. How Can I Access and Update My Information?

If you have registered for an account at our Sites, you may access, update and change certain information we have collected about you by logging in to your account and updating your information or by calling us. Because we collect information about you from a variety of sources, we may ask you to contact the source of the information to correct that information. For example, you may need to contact your healthcare provider to correct a laboratory test result that you feel is inaccurate.

 

6. How Does Bravo Wellness Address California Privacy Rights?

California Civil Code Section 1798.83 entitles California users to request information concerning the disclosure of certain personal information to third parties for the third parties’ direct marketing purposes. California users who wish to request further information in compliance with this law may contact us as specified in the “How to Contact Us” section below.

As of the Effective Date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information regarding your online activities over time and across third party websites or online services.

 

7. How Does Bravo Wellness Protect the Security of the Personal Information it Collects?

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) or other cryptographically secure encryption protocols and by storing your information in physically secured environments. In addition, we use administrative, technical, and physical security designed to safeguard personal information in our possession. If you believe that information about you has been subject to unauthorized disclosure, please let us know by emailing Privacy@BravoWell.com.

 

8. Third Party Links

Our Sites may contain links to other websites that are not owned or controlled by Bravo Wellness. The provision of such links is for your convenience and does not signify our endorsement of such sites or their content. We have no control over and are not responsible for the privacy policies governing those other websites or the content displayed on those websites.

 

9. How Does Bravo Wellness Provide Updates to this Statement?

When we make changes to this Statement, we will update this web page and change the Effective Date listed above.

 

10. How To Contact Us Regarding Privacy Issues

You can contact us with questions or comments about our privacy practices or this Statement by emailing us at Privacy@BravoWell.com or you can contact us at:

Bravo Wellness

One International Place

20445 Emerald Parkway Dr. SW

Suite 400

Cleveland, OH 44135

1-855-208-1819