Privacy Policy

This Privacy Policy (“Privacy Policy”) describes how DCV Emergency Physician, LLC, operating under the trade name VIDA (“VIDA,” “we,” “us,” or “our”), collects, uses, discloses, retains, and protects information in connection with our website, digital platforms, communications, and services.

This Privacy Policy applies to information collected through the Website and digital ecosystem, including VIDA Clínica Virtual, VIDA Notes, and The Health Recovery Toolkit, as well as through related forms, communications, and other online interactions. For purposes of this Privacy Policy, the website and related digital platforms are collectively referred to as the “Website”. The terms used and otherwise not defined herein will have the meaning ascribed to them in the Website Terms and Conditions.

This Privacy Policy does not replace the Medical Terms of Service applicable to Medical Services or the Notice of HIPAA Privacy Practices applicable to Protected Health Information (“PHI”).

OUR DIFFERENT OFFERINGS

We operate several distinct offerings under a common brand and philosophy.

VIDA Clínica Virtual. VIDA Clínica Virtual provides physician-led, individualized Medical Services, including evaluation, diagnosis, treatment, and clinical follow-up, as appropriate. Information collected in connection with Medical Services may include health information and may constitute PHI. The use and disclosure of PHI is governed by applicable law and our Notice of HIPAA Privacy Practices.

VIDA Notes. VIDA Notes provides general educational content concerning topics including PMDD, PME, perimenopause, hormonal health, supplements and the evidence behind them, nutrition, sleep, exercise, nervous-system regulation, and other lifestyle topics. Information collected when you read, subscribe to, or otherwise interact with VIDA Notes is generally governed by this Privacy Policy. VIDA Notes itself does not constitute Medical Services.

The Health Recovery Toolkit. The Health Recovery Toolkit (“Toolkit”) consists of paid, self-paced digital educational products. When you purchase or access a Toolkit, we may collect information necessary to process your purchase, provide access to the product, communicate with you about your purchase, and provide customer support. Purchasing or accessing a Toolkit does not establish a physician-patient relationship. Information associated with Toolkit purchases and use is generally governed by this Privacy Policy and not by the HIPAA Notice, unless the information independently constitutes PHI subject to HIPAA.

INFORMATION WE COLLECT

The information we collect depends on how you interact with us. We may collect the following categories of information.

You may provide information to us when you:

• visit or interact with the Website;
• create an Account;
• request or inquire about Medical Services;
• submit forms or information in connection with Medical Services;
• subscribe to VIDA Notes or another email list;
• purchase or access a Toolkit;
• contact us;
• communicate with us;
• participate in a survey, promotion, or other activity; or
• otherwise voluntarily provide information to us.

Depending on the interaction, this information may include:

• name;
• email address;
• telephone number;
• mailing or physical address;
• account credentials;
• date of birth;
• payment and transaction information;
• purchase history;
• communications and correspondence;
• preferences and subscription information;
• information necessary to provide customer support; and
• other information you choose to provide.

INFORMATION COLLECTED IN CONNECTION WITH MEDICAL SERVICES

If you request or receive Medical Services through VIDA Clínica Virtual, we may collect information necessary to evaluate, provide, coordinate, administer, and document those Medical Services. Depending on the circumstances, this may include:

• health history;
• symptoms;
• diagnoses;
• medications and supplements;
• allergies;
• laboratory or diagnostic information;
• treatment information;
• insurance information;
• information received from other healthcare providers; and
• other information relevant to your care.

Certain information collected in connection with Medical Services may constitute Protected Health Information (“PHI”) under HIPAA. Our use and disclosure of PHI is governed by the Notice of HIPAA Privacy Practices and applicable healthcare privacy laws. This Privacy Policy should therefore be read together with the HIPAA Notice when you receive Medical Services.

INFORMATION AUTOMATICALLY COLLECTED

When you visit or interact with the Website, we, and certain third-party service providers may, from time to time, automatically collect information about your device and interaction with the Website. This may include:

• IP address;
• browser type and version;
• operating system;
• device type;
• approximate geographic location;
• pages or content viewed;
• dates and times of visits;
• referring websites or sources;
• interactions with the Website;
• general usage information; and
• information collected through cookies, pixels, web beacons, local storage, and similar technologies.

This information (“Personal Information”) may be collected even if you do not create an Account or otherwise identify yourself directly.

HOW WE USE INFORMATION

From time to time, we may use and collect Personal Information to:

• operate the Website;
• create and manage Accounts;
• provide access to Digital Products;
• process purchases;
• provide customer support;
• facilitate requests for Medical Services;
• administer our relationship with you;
• Send transactional & administrative communications; account-related communications; purchase and Toolkit-related communications; appointment-related communications; policy and legal notices; responses to inquiries; and other communications you request or that are reasonably necessary to provide the applicable service;
• understand how users interact with the Website;
• analyze traffic and usage patterns;
• improve functionality and user experience;
• evaluate the performance of our content and services;
• develop and improve products and features;
• understand the effectiveness of marketing campaigns;
• protect the security and integrity of the Website;
• detect and prevent fraud, abuse, or unauthorized activity;
• investigate security incidents;
• enforce our agreements;
• protect our rights, safety, and property and those of others;
• comply with applicable laws and regulations;
• respond to lawful requests from governmental authorities;
• comply with legal processes;
• establish, exercise, or defend legal claims; and
• enforce our agreements and policies.

VIDA Notes and educational communications. If you subscribe to VIDA Notes or another Website email list, we may use your email address to send you newsletters, educational content, and related communications in accordance with your preferences and applicable law. You may unsubscribe from promotional or newsletter communications at any time using the unsubscribe mechanism included in the communication.

Marketing. Where permitted by applicable law, we may use Personal Information to communicate with you about our services, products, educational content, programs, promotions, or other offerings that may be relevant to you. You may opt out of certain marketing communications in accordance with applicable law as described below.

COOKIES AND SIMILAR TECHNOLOGIES

We, and certain third-party service providers use cookies and similar technologies, including pixels, web beacons, local storage, and related technologies. These technologies may be used for several purposes.

Strictly Necessary Technologies. These technologies support essential Website functionality, security, navigation, and access to certain features.

Analytics Technologies. Analytics technologies help us understand how Visitors use the Website, including traffic patterns, pages viewed, interactions, and other usage information. We may use third-party analytics services, including services such as Google Analytics, to support these purposes.

Functionality Technologies

These technologies may remember preferences and settings, such as language or other Website preferences.

Advertising and Marketing Technologies

We may use advertising and marketing technologies, including technologies such as Meta Pixel, Google Ads, or similar tools, to:

• measure advertising and campaign performance;
• understand interactions with our advertisements;
• deliver or evaluate relevant advertising;
• understand how Visitors arrive at the Website; and
• support marketing and audience measurement.

The specific technologies used by us may change from time to time.

Where required by applicable law, we will provide appropriate notice and obtain any required consent before using certain cookies or similar technologies. You may be able to control cookies through your browser settings and, where available, through a Website cookie-management mechanism. Disabling certain cookies may affect Website functionality.

HEALTH-RELATED INFORMATION AND PRIVACY

We operate in the women's health space. As a result, users may choose to interact with the Website in ways that reveal information about their health interests or circumstances. For example, a Visitor may read content concerning PMDD, perimenopause, hormonal health, supplements, sleep, or other health topics. The fact that you visit or interact with a particular page or educational resource does not by itself mean that we have created a medical record for you or established a physician-patient relationship with you. Information that is collected in connection with Medical Services and constitutes PHI is governed by the Notice of HIPAA Privacy Practices. Information collected through the broader Website, including VIDA Notes and The Health Recovery Toolkit, is generally governed by this Privacy Policy.

HOW WE SHARE PERSONAL INFORMATION

We may disclose Personal Information to third parties when reasonably necessary for the purposes described in this Privacy Policy. These third parties may include:

Service Providers

Companies that provide services to us, including, but not limited to:

• website hosting;
• technology and infrastructure;
• customer support;
• communications;
• email distribution;
• analytics;
• marketing;
• security;
• scheduling;
• payment processing; and
• other administrative or technical services.

Payment Processors

Payments for products or services may be processed through third-party payment processors. Payment processors may collect and process payment information directly in accordance with their own privacy policies.

Marketing and Analytics Providers

We may share information with analytics, advertising, and marketing service providers as necessary to support our advertising, measurement, analytics, and communications activities, subject to applicable law and your available privacy choices.

Clinical Service Providers

In connection with Medical Services, we may use third-party vendors and service providers to support clinical, administrative, technological, or operational functions. Where information constitutes PHI, its use and disclosure is governed by applicable law and the Notice of HIPAA Privacy Practices.

Legal and Regulatory Disclosures

We may disclose information when required or permitted by law, including to:

• comply with legal processes;
• respond to lawful governmental requests;
• protect rights, safety, and property;
• investigate fraud or security incidents; or
• establish, exercise, or defend legal claims.

Business Transfers

To the extent we are involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, Personal Information may be transferred as part of that transaction, to the extent permissible by applicable law.

THIRD-PARTY WEBSITES AND SERVICES

The Website may contain links to third-party websites, platforms, services, and/or resources. Those third parties may have their own privacy policies and terms of use. We do not control the privacy practices of independent third parties and therefore, we are not responsible for their policies or practices. We encourage you to review the privacy policy of any third-party service before providing information to that service.

EMAIL/MARKETING COMMUNICATIONS

If you voluntarily provide your email address to us, including by subscribing to VIDA Notes, we may use your email address to provide the communications associated with your subscription. You may unsubscribe from marketing or newsletter communications by using the “unsubscribe” mechanism included in those communications. You may continue to receive certain transactional, administrative, security, legal, or service-related communications even after opting out of marketing communications where those communications are necessary or permitted. Clinical communications relating to Medical Services are addressed separately in the Medical Terms of Service and Notice of HIPAA Privacy Practices.

PERSONAL INFORMATION YOU CHOOSE TO MAKE PUBLIC

To the extent the Website permits you to publicly post a review, comment, testimonial, or other information, anything you voluntarily make public may be accessible to others. You should exercise caution before publicly sharing information concerning your health, medical history, or other sensitive information. Do not publicly post Protected Health Information or other confidential medical information. We do not require you to publicly disclose health information in order to use VIDA Notes or The Health Recovery Toolkit.

USER GENERATED CONTENT

To the extent the Website permits users to submit content, testimonials, reviews, comments, images, or other materials, the applicable terms governing that content will be disclosed through the Website Terms and Conditions or the applicable consent process. Nothing in this Privacy Policy grants us a general license to use your submitted content for advertising or promotional purposes. Should we seek to use a user's testimonial, image, statement, or other content for promotional purposes in a manner requiring permission, we will obtain the applicable permission or authorization.

DATA RETENTION

We retain Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, including, but not limited to:

• provide and administer services;
• maintain Accounts;
• process transactions;
• provide customer support;
• comply with legal and regulatory obligations;
• resolve disputes;
• enforce agreements;
• maintain security; and
• protect our legal rights.

The length of time information is retained will depend on the nature of the information, the purpose for which it was collected, applicable legal requirements, and other relevant circumstances. Information maintained as part of a patient's medical record may be subject to different retention requirements under applicable healthcare laws and regulations. Medical records and PHI are addressed further in the Notice of HIPAA Privacy Practices.

PAYMENT INFORMATION

We use third-party payment processors to process transactions. Where payment information is collected directly by a payment processor, the payment processor may process that information in accordance with its own privacy policy and applicable security standards. We do not intend to store full payment-card information, such as full card numbers or CVV codes, on its own systems where the payment processor handles such information directly. No electronic transmission or storage system can be guaranteed to be completely secure.

SECURITY

We maintain administrative, technical, physical, and organizational safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, or destruction. However, no electronic system, transmission, storage method, or security measure can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect information, we cannot guarantee absolute security. Security requirements applicable specifically to PHI are also governed by applicable healthcare privacy and security laws and the Notice of HIPAA Privacy Practices.

SECURITY INCIDENTS AND DATA BREACHES

If we determine that a security incident or breach has affected Personal Information, we will provide notifications as required by applicable law. The timing, content, and method of notification will depend on the nature of the incident and applicable legal requirements. If a breach involves PHI, additional notification requirements may apply under HIPAA and other applicable laws. Those requirements are addressed through the applicable HIPAA framework and the Notice of HIPAA Privacy Practices.

YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you live and applicable law, you may have rights concerning your Personal Information. These may include the right to:

• request access to Personal Information we maintain about you;
• request correction of inaccurate information;
• request deletion of certain Personal Information;
• request information about how Personal Information is collected or used;
• opt out of certain marketing communications;
• opt out of certain targeted advertising or similar activities where applicable;
• request portability of certain information where required by law; and
• exercise other rights provided by applicable law.

Certain exceptions and limitations may apply. For example, requests concerning PHI and medical records may be subject to different rules and should be directed through the process described in the Notice of HIPAA Privacy Practices. To submit a privacy request, contact us at: vidaclinicavirtual@gmail.com. We may need to verify your identity before completing certain requests. We will not discriminate against you for exercising a privacy right to the extent prohibited by applicable law.

MARKETING AND TARGETED ADVERTISING CHOICES

You may opt out of certain marketing communications by using the unsubscribe mechanism included in our communications. Depending on applicable law and the technologies we use, you may also have the ability to opt out of certain targeted advertising, sale, sharing, or similar activities. Where required by applicable law, we will provide an appropriate mechanism to exercise those choices. Browser-based privacy signals or preference mechanisms may also be recognized where required by applicable law.

CHILDREN'S PRIVACY

Our services are not directed to children under the age of 13. We do not knowingly collect Personal Information from children under 13 through the Website without appropriate authorization. If you believe that a child has provided Personal Information to us in a manner that violates applicable law, please contact us at: vidaclinicavirtual@gmail.com. Where required by law, we will take appropriate steps to address such information.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, services, or applicable legal requirements. When we make changes, we will update the “Last Updated” date at the bottom of this Privacy Policy. Where required by applicable law, we will provide additional notice of material changes. Your continued use of the Website following the effective date of an updated Privacy Policy will be subject to the revised Privacy Policy to the extent permitted by applicable law.

CONTACT US

If you have questions about this Privacy Policy or wish to submit a privacy request, please contact: vidaclinicavirtual@gmail.com. For questions or requests concerning PHI or medical records, please use the contact information provided in the Notice of HIPAA Privacy Practices.

RELATIONSHIP TO OUR OTHER LEGAL DOCUMENTS

Our legal documents are intended to work together, with each addressing a different aspect of the Website ecosystem: Website Terms and Conditions govern your general use of the Website and its non-clinical offerings. Medical Terms of Service govern the provision of Medical Services through VIDA Clínica Virtual. Privacy Policy governs our collection and use of Personal Information as described in this Privacy Policy. Notice of HIPAA Privacy Practices describes how we may use and disclose PHI and the rights available to patients under HIPAA. These documents should be read together. Nothing in this Privacy Policy is intended to replace, limit, or modify rights or obligations that apply under the Medical Terms of Service, the Notice of HIPAA Privacy Practices, or applicable law.