Rally Coach Program Privacy Policy

Real Appeal®, Live Vape Free™, Quit for Life®, and Wellness™ Coaching are business divisions of RVO Health, LLC.  This Privacy Notice (the “Notice”) describes the types of personal information RVO Health collects about you through its operation of Real Appeal®, Live Vape Free™, Quit for Life®, and Wellness™ Coaching, how we use that information, who we disclose it to, and certain rights and options you may have regarding your personal information (any reference to “Real Appeal,” “Live Vape Free,” “Quit for Life,” and “Wellness Coaching” in this Notice means RVO Health).

This Notice applies to information we collect from you through the websites and mobile applications made available under the Real Appeal®, Live Vape Free™, Quit for Life®, and Wellness™ Coaching names, as well as when you communicate with us, interact with us, or otherwise provide us with information in our capacity as Real Appeal®, Live Vape Free™, Quit for Life®, and Wellness™ Coaching. You may be presented with other privacy notices during the course of interacting with us or using our services; this Notice supplements those other notices.

By using one of our websites or mobile applications, communicating with us, or otherwise interacting with us, you consent and agree to our collection, use, and disclosure of your personal information as described in this Notice.

Important Information About the RVO Health Brands

RVO Health owns and operates other business divisions that conduct their operations under other brands. You can learn more about each of our brands here: https://www.rvohealth.com/brands. This Notice does not describe how data is collected via the websites or mobile applications of our other brands.

When you are interacting with any RVO Health site or mobile application, please read the privacy notice that is made available to you via such site or mobile application to learn more about our data handling practices specific to that site or mobile application and operating business.

As discussed below, you should be aware that RVO Health makes your personal information available to each of its business divisions and operating brands, including the personal information that is the subject of this Notice.

Patient Records and Protected Health Information

This Notice is in addition to, and does not replace, our Notice of Privacy Practices, which explains how we use and disclose patients’ protected health information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). To the extent of a conflict between the terms of this Notice and the Notice of Privacy Practices with respect to any of your PHI, the Notice of Privacy Practices will control. Please review our Notice of Privacy Practices for complete information on the use and release of PHI. Speak with your provider about any concerns you may have regarding your medical records.

Personal Information We Collect or Receive About You

• Personal Information

For the purposes of this Notice, “personal information” is any information that, either alone or in combination with other information, identifies, relates to, or can be used to contact a particular individual. The types of personal information we may collect include the following categories.

• Contact information: First name, last name, email address, mailing address, and telephone number.
• Account details: If you create or register an account with us, your username, password, account number, and other account details that are requested as part of the account setup and management process (e.g., your preferences or areas of interest).
• Demographic information: When completing your user profile, interacting with a survey or tool, or when you otherwise choose to provide the information, your gender, birth date, marital status, employment status, parent status, race or ethnicity, military status, preferred pronouns, sexual orientation and sex life.
• Medical condition information: To the extent inferred from your interactions with one of our websites or mobile applications, or when you choose to provide such information as part of your account profile or otherwise (e.g., as part of our chat, games, or community features), information about your physical or mental health status, condition, or diagnosis, including treatments you are receiving, medications you are taking, the type of care you are seeking, medical or health-related interventions you have received or are interested in,  gender-affirming care information, diagnostic testing, and information related to your receipt of medical and health services, in each case, to the extent applicable.    
• Fitness, activity, and lifestyle information: To the extent inferred from your interactions with one of our websites or mobile applications, or when you choose to provide such information as part of your account profile or otherwise (e.g., through connection with a personal device or third-party app), information regarding dietary habits and exercise activities you engage in, such as the food and drinks you consume, fitness level, fitness activity, fitness goals, dietary preferences, lifestyle information (e.g., sleeping data, tobacco usage), body measurements (e.g., height, weight, and BMI), vital signs, symptoms, or health characteristics, steps and other physical activity data (e.g., swimming, biking, burned calories, heart rate), activity and fitness time data, mindfulness data, blood pressure, pulse and heart rate data, blood glucose data, blood oxygen levels data, and body temperature data, and other related information you choose to capture in notes or other fields within the Services.    
• Financial information: To the extent you use our services in connection with employer-provided benefits, remit payment for our services to a health plan or other insurance provider, or pay for our services using a health-related payment mechanism, such as a health savings account, the details of the mechanisms used to remit payment or ensure coverage for services. To the extent you make a purchase, payment card details, bank account details, or other payment information. Note, this information is collected and processed on our behalf by a third-party payment processor.
• Transactional data: Details about your transactions with us, including method of payment, relevant billing or shipping addresses, payments received, transaction history, and other information relating to the products or services purchased by you.
• User content: Comments, posts, photos, ideas, reviews, feedback, or other content that you submit or otherwise post or upload to any portion of our websites or mobile applications (e.g., an online forum, community chat, a comment section to an article or post), as well as calendar information, photos, or videos you make available or accessible through your device settings.  In some cases, this information may include or be associated with your account details and may be viewable by other users of the relevant website or mobile application.
• Marketing information: Details regarding promotional materials you may have requested or received from us, the services in which you are interested, your receipt of newsletters or other promotional communications, and information on your marketing or communication preferences.
• Precise geolocation information: In some cases, we may collect information from your mobile device that identifies the precise location of that device. Oftentimes, you will be prompted by the device manufacturer to consent to our collection of this information.
• Customer communications: Copies of communications or inquiries you have submitted to us, including through email, calls, chat functionalities on our websites or mobile applications, forms, social media, or other means. This includes information you provide in response to customer surveys, quizzes, sweepstakes, questionnaires, or intake forms.
• Device, usage, and preference information: Details regarding how and when you use our website, including the device used to connect to the website, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to the website, and information about your interaction with the website. We also collect information regarding the content viewed and issues queried while on our website or application (e.g., articles read or saved, pages visited, issues searched for, etc.).

We collect this information when you access, use, or navigate one of our websites or mobile applications, create an account with us or use an existing account to engage with one of our websites or mobile applications, fill in forms via one of our websites or mobile applications, request information from us, communicate with us (including by phone, email, chat, or otherwise), interact with any chatbot or similar features available via one of our websites or mobile applications, visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.

If you do not provide us with certain information, then the digital property you are using may not function as intended, or you may not be able to benefit or take advantage of certain features of our products or services. For example, if you do not provide us with your name and email address, you cannot create an account with us.

Where we have an ongoing relationship with you, and any of the data you have provided (e.g., your contact information) is no longer accurate, please inform us of this so we can amend our records accordingly.

Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”  cookie

• Automatically Collected Information

Like most website and mobile application operators, we use various technologies to collect certain types of information about the users of our digital properties. Note, the vendors that supply us pixels, tags, web beacons, cookies, and the other tracking technologies discussed below collect your personal information instantaneously and simultaneous to our collection of such information. They may also use such personal information for their own or others’ purposes.

The technologies we use on our websites and mobile applications include:

• Pixels, tags, web beacons, gifs, and similar code-based technologies.  These technologies are small pieces of code that run when a website or mobile application page or email is loaded. They are used to monitor the behavior of the visitor or email recipient—such as what icons were clicked or whether links in an email were opened—and gather analytics and details about the interaction.  For example, when you open our homepage, a pixel may run and generate information based on the visit (e.g., your IP address and what day and time you were on the homepage), and then this information is processed by us or our vendors. Pixels work in conjunction with cookies to let us know what portions of our digital properties are of interest to you and to help us provide you with tailored information. Even if you have disabled or turned off cookies (discussed below), the pixels, tags, and web beacons we use may still detect and collect certain information about your interaction with our website or mobile application; in other words, these kinds of technologies may disregard any cookie-prohibitive markers or signals.
• Cookies: Cookies are small text files that can be used by websites to make a user’s experience more efficient. Our website uses different types of cookies to, among other things, automatically recognize you when you return to our site, store information regarding your preferences, and analyze traffic to our site. Please note that where cookies are essential to the operation of our site, if disabled, you may not be able to enjoy certain features of the site. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.  We do not honor “Do Not Track” signals. Continue reading below to learn more about the Global Privacy Control
• Log Files and Device Identifiers.  We use log files to track actions occurring on digital properties and to collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
• Analytics.  Our digital properties may also deploy third-party analytics tools, such as Google Analytics.  You can find more information about how data is collected and processed in connection with the Google Analytics service at https://policies.google.com/technologies/partner-sites.  You can also read Google’s privacy policy at https://policies.google.com/privacy?hl=en.

The information collected through these technologies may be combined with personal information or aggregated with other information on website visits. We may share information about your use of our website with our advertising and analytics partners, who may combine it with other information that you previously provided to them.

If enabled for the jurisdiction from which you are accessing our website or mobile application, you can opt out of the processing of your personal information for targeted advertising purposes by configuring your settings through the “Privacy Settings” link in the website footer or mobile application menu accordingly or by enabling the Global Privacy Control on your browser or device (to learn more: https://globalprivacycontrol.org/). Your actions only apply to the browser or device you are using to interact with our website or mobile application and not to other devices or browsers.  If you clear your cookies or change your preferences on a particular browser or device, or use another browser or device to interact with our websites and mobile applications, you may need to opt out again.

Please see the Section titled “Your Choices About Your Personal Information” for more information about options you may have to configure pixels, tags, cookies, and similar technologies on our website or mobile application.

• Information from Other Sources

We may obtain both personal and non-personal information about you from other users of our website and services, business partners, suppliers, and other third parties and add it to other information we have collected.   For example, as mentioned above, RVO Health makes your personal information available to each of its business divisions and operating brands. Thus, we may receive personal information about you from another one of our business divisions or operating brands.

We may also receive personal information from your health plan or a healthcare provider. The types of personal information collected may include health, medical, or therapy information, as well as financial and insurance information.  

We may provide you the ability to log in to our websites or mobile applications through certain third-party accounts. When you use these single sign-on protocols to access our services, tokens from the sign-on protocol to help identify you in our system and confirm you successfully authenticated through the applicable sign-on protocol.

We, and the third parties we engage, may combine information we collect from you over time and across your online activity with information obtained from other sources. For example, we may purchase consumer data from a data broker and use that information to supplement the information we have collected about your activities directly.  This helps us improve the information’s overall accuracy and completeness and also helps us better tailor our interactions with you.

• Social Media

If you interact with us on any social media platform: (i) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Notice, and (ii) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts.  Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform.  We encourage you to review the privacy notices and settings of any social media platform with which you interact to help you understand their privacy practices.

How We Use Your Personal Information

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

• Making our products and services, including our websites and mobile applications, and their features and tools, available to you.
• Authenticating your credentials or facilitating any login to our systems or services, including through the use of single-sign-on options provided by third parties.
• Registering you for an account with our services, including matching an account for one brand with other accounts you have with our business.
• Managing our relationship with you, including entering into and fulfilling any transactions with you.  
• Facilitating and displaying advertisements from third parties on our websites or mobile applications, including, in some cases, ensuring the ad is relevant to your interests.
• Engaging in targeted advertising on other websites or mobile applications, even if those websites or mobile applications are owned by third parties.
• Allowing our other brands to communicate with you and deliver relevant information to you, including information about the products and services available from those brands.
• Operating our business, including engaging in accounting, auditing, invoicing, or reconciliation and collection activities, determining the effectiveness of our marketing or sales strategies or processes, managing our communications.
• Analyzing market and consumer trends and developing financial, product, or profile insights.
• Enhancing your experience on our website and mobile applications, including by identifying and displaying content that might be of interest to you and otherwise ensuring that our content is presented to you in a useful and effective manner.
• Communicating with you and responding to your inquiries and communicating regarding our services, the functionality of our websites and mobile applications, and other issues.
• Sending you informational communications and promotional solicitations, tracking your marketing preferences, and for our internal marketing purposes.
• Managing customer service issues, including issues relating to the performance of our services and customer feedback.
• Developing, updating, and improving our products and services (including our websites and mobile applications), our administrative processes that support our business, and customer experience, and otherwise improving our knowledge and insights regarding users.
• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the use of our websites or mobile applications or use of our products or services.
• Enforcing our agreements with you or our organizational partners and customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.
• Notifying you about changes to our services or material changes to this Notice.
• Providing you with surveys or otherwise soliciting feedback from you.
• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Personal Information” below.

Disclosure of Your Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or disclose it to third parties, to the extent permitted by applicable law.

In addition, we may disclose your personal information to the following types of individuals or entities:

• Service providers we use to facilitate our business operations and administer our services. These parties have access to your personal information to perform specific tasks on our behalf. For example, our service providers include (i) IT and system administration providers, (ii) data storage and server providers, (iii) web hosting providers, and (iv) vendors to facilitate payments and payment processing.
• Individuals or organizations to whom you direct us to provide your information, for example a provider or local resource that you identify through our services and direct us to disclose your contact information to.
• Organizations with whom you have a relationship or are affiliated, such as your healthcare provider, insurance provider, or employer.  
• Other users of our services, if you choose to post or share content in forums, bulletin boards, or in connection with other community-oriented or social features of our websites or mobile applications.
• Vendors whose technologies we leverage to provide certain features of our websites or mobile applications, such as video players and chat software providers.
• Marketing and advertising vendors that may assist with lead generation, hosting information relating to customers and business partners and potential customers or business partners, marketing automation, advertisement placement and targeting, and marketing campaigns and communications. Examples of these vendors include Meta and LinkedIn.  
• Analytics vendors in order to understand our website traffic and usage patterns, optimize our website, track marketing conversions, and identify potential new customers or users.
• Our affiliates and related entities, investors, and operational partners.
• Our professional advisors, such as lawyers, accountants, and other similar advisors.
• Other parties for any purpose we disclose at the time you provide the information.

We may also disclose your personal information to:

• Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
• Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
• Protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and risk reduction.
• Enforce or apply the terms and conditions of our websites or mobile applications, any terms and conditions of purchase (to the extent applicable), and other agreements between you and RVO Health.

Note, the technology vendors we use to make our websites and mobile applications available to you may collect your personal information instantaneously and simultaneous with us collecting the same information.

Our Marketing Efforts

We may send you direct marketing communications from time to time via physical or electronic mail, including news, updates, and other announcements relating to our services and business activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe from our marketing communications using the functionality in the communication you have received or by contacting us at the information below.

You may also receive tailored advertisements when using one of our websites or mobile applications. Please review your device and browser settings to learn more about how you can control advertisements delivered via a web page or mobile application.

In some cases, we may send push notifications to your device. You can disable these notifications and adjust your notification preferences via your device settings.

Where permitted by applicable laws, we may send you informational or promotional communications via text or SMS message. Any data related to your opt-in to receive text or SMS communications will not be disclosed to third parties who are not authorized to reach out on RVO Health’s behalf.

Your Choices About Your Personal Information

A. Tracking Technologies and Advertising

Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies.  Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same.  Please note that if you disable or delete cookies, you may not be able to access or use certain features of our website.

The National Advertising Initiative also makes resources available to assist consumers in opt-out of certain tailored online ads, which you can access at https://optout.networkadvertising.org/?c=1.

We do recognize the Global Privacy Control (learn more at: https://globalprivacycontrol.org/). If you enable GPC, your preferences will only apply to the browser or device you are using to interact with our website or mobile application and not to other devices or browsers.  If you use another browser or device to interact with our websites and mobile applications, you may need to ensure the GPC is enabled to have your preferences recognized in connection with the browser or device you are using.

B. Marketing Communications and Emails

You may choose to opt out of marketing emails by using the “Unsubscribe” link found at the bottom of such emails. You can configure your device settings to disable push notifications. You can opt out of receiving promotional communications via text or SMS message by texting “STOP” or “OPT OUT” to the number provided. You can opt out of receiving certain communications by contacting us at the “Contact Us” information below.

C. Google Analytics

As discussed above, we use Google Analytics in connection with the website.  If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can access at https://tools.google.com/dlpage/gaoptout?hl=en-US.  You can find more information on how Google uses information it collects at https://policies.google.com/technologies/partner-sites.

D. Updating Your Information

We take reasonable steps to keep your personal information accurate and complete. You can access or update your personal information, including contact or account information, by contacting us at the “Contact Us” information below.

E. Declining to Provide Information

You can choose not to provide us with information we may request, but that may result in you being unable to use certain features of our websites or mobile applications, request information about our services, or initiate other transactions with us.

F. Do Not Track Mechanisms

Please note that our websites do not honor “Do Not Track” signals, and such signals will not impact the operation of our websites.  Do Not Track signals are different than the Global Privacy Control (more information about GPC can be found at https://globalprivacycontrol.org/).

Additional Information for California Residents

This section of our Notice applies solely to “consumers” as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), and describes our activities when we are acting as a business, as defined by the CCPA.

CALIFORNIA NOTICE AT COLLECTION

In simply accessing one of our websites or mobile applications, the following applies. If you create an account or interact with us in other ways (e.g., by filling out forms on our website or mobile application), please continue reading below to learn more about the personal information we collect, and how we use and disclose such information.

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RVO Health “shares” (as that term is defined by the CCPA) the following categories of personal information to various marketing and advertising vendors for the purposes of serving you with targeted advertisements, either on behalf of us or third parties.

• Identifiers, such as your IP address, device ID, browser ID, mobile ad ID, or other unique or personal online or electronic identifier associated with the means by which you access the website or mobile application
• Internet activity, such as browsing details, search details, information about your interaction with the website, application, or advertisement, including page views, clicking tendencies, and time spent on a page, and other similar event or session data
• To the extent revealed by the pages you interact with, articles or features you view, your search terms, or how you otherwise choose to navigate one of our websites or mobile applications, information that concerns your health or information that concerns your sex life or sexual orientation

To request that RVO Health opt you out of the sharing of such information, or to limit our use and disclosure of your sensitive personal information for targeted advertising purposes, please email legal@rvohealth.com or by enable the Global Privacy Control on your browser or device (to learn more: https://globalprivacycontrol.org/). These actions only apply, however, to the browser or device you are using to interact with our website or mobile application and not to other devices or browsers.  If you clear your cookies or change your preferences on a particular browser or device, or use another browser or device to interact with our websites and mobile applications, you may need to opt out again.

CALIFORNIA PRIVACY NOTICE

To learn more about our practices in connection with the collection, processing, and disclosure of personal information relating to California consumers, continue to read below.

A. Personal Information We Collect and Disclose

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  For the purposes of the CCPA and this section, personal information does not include certain regulated information, such as protected health information that is collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act, or public information.

In the past 12 months, RVO Health has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business or commercial purposes described below.
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CATEGORIES OF PERSONAL INFORMATION
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SENSITIVE PERSONAL INFORMATION
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From time to time, RVO Health may be required to disclose your information to governmental authorities for the purpose of complying with applicable laws and regulations or in response to legal process. We may also disclose your personal information to third parties in connection with the sale of our business or assets, or any merger or similar corporate matter, when your personal information is part of the assets involved in such transaction.

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B. Applicable Retention Periods

For each category of personal information identified above, we will retain your personal information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this section. The criteria used to determine our retention periods include (i) to fulfill the purpose for which the information was collected, (ii) for as long as we have an ongoing relationship with you, and (iii) as required by a legal obligation to which we are subject.

C. Categories of Sources of Personal Information

RVO Health collects these categories of personal information from the following categories of sources:

• Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms on one of our websites or mobile applications, creating an account with us, engaging in transactions with us, such as the purchase of a subscription or service, signing up to receive promotional or information communications from us, communicating with us about our services, or otherwise directly providing the information to us.  
• Technology-based collection: We also collect certain information from you automatically when you visit, use, or navigate our websites and mobile applications. RVO Health collects certain identifiers (such as IP addresses, device IDs, mobile ad IDs) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as described in the “Automatically Collected Information” section of our Notice above.
• Collection via social media: We may collect personal information about social media users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number, if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.). The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by customers, where applicable.
• Third-party collection: On occasion, we may obtain consumer data from brokers or marketing vendors. We use this personal information to supplement the personal information we collect from you directly for our marketing and advertising purposes. We also receive personal information from consumers’ employers, when our services are being used in connection with a workplace benefit.

D. Business or Commercial Purposes for Collecting and Disclosing Personal Information

We collect and disclose the personal information described above for the following business or commercial purposes:

• Making our products and services, including our websites and mobile applications, and their features and tools, available to you.
• Authenticating your credentials or facilitating any login to our systems or services, including through the use of single-sign-on options provided by third parties.
• Registering you for an account with our services, including matching an account for one brand with other accounts you have with our business.
• Negotiating, entering into, and managing our relationship and agreements with you, including fulfilling any purchases or transactions with us.  
• Facilitating the display of advertisements from third parties on our websites or mobile applications, including, in some cases, ensuring the ad is relevant to your interests.
• Engaging in targeted advertising on other websites or mobile applications, even if those website or mobile applications are owned by third parties.
• Allowing our affiliates and related brands to communicate with you and deliver relevant information to you, including information about their products or services.
• Operating our business, including engaging in accounting, auditing, invoicing, or reconciliation and collection activities, determining the effectiveness of our marketing or sales strategies or processes, managing our communications.
• Analyzing market and consumer trends and developing financial, product, or profile insights.
• Providing and optimizing your experience on our website and mobile applications, including ensuring that our content is presented to you in the most effective manner.
• Communicating with you and responding to your inquiries and communicating regarding our services, the functionality of our websites and mobile applications, and other issues.
• Sending you informational communications and promotional solicitations, tracking your marketing preferences, and for our internal marketing purposes.
• Managing customer service issues, including issues relating to the performance of our services and customer feedback.
• Developing, updating, and improving our products and services (including our websites and mobile applications), our administrative processes that support our business, and customer experience, and otherwise improving our knowledge and insights regarding users.
• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the use of our websites or mobile applications or use of our products or services.
• Enforcing our agreements with you or our organizational partners and customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.
• Notifying you about changes to our services or material changes to this Notice.
• Providing you with surveys or otherwise soliciting feedback from you.
• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
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E. Sensitive Personal Information

As described above, RVO Health uses and discloses certain “sensitive personal information” (as defined by the CCPA). In some cases, we use or disclose sensitive personal information to perform the services reasonably expected by a consumer who requests such services, to prevent, detect, and investigate security incidents, resist fraudulent or illegal actions, or to verify or maintain the quality of our services.  In connection with the foregoing, the information is collected or processed without he purpose of inferring characteristics about you, so we treat the information like “personal information” for CCPA purposes.  

RVO Health also uses and discloses sensitive personal information for other business purposes, where the law allows, such as for the purposes of providing tailored advertisements to consumers. Subject to any applicable exceptions or limitations, you can direct RVO Health to limit the use and disclosure of your sensitive personal information for these purposes as follows:

Please review the “Exercising Your Right to Opt-Out of ‘Shares’ and to Limit the Use and Disclosure of Your Sensitive Personal Information” section below for instructions on how to direct us to limit use and disclosure of your sensitive personal information.

F. Sale or Sharing of Personal Information

In the past 12 months, RVO Health has “shared” (as that term is defined by the CCPA) the following categories of personal information to various marketing and advertising vendors for the purposes of serving you with targeted advertisements, either on behalf of us or third parties.

• Identifiers, such as your IP address, device ID, browser ID, mobile ad ID, or other unique or personal online or electronic identifier associated with the means by which you access the website or mobile application.
• Internet activity, such as browsing details, search details, information about your interaction with the website, application, or advertisement, including page views, clicking tendencies, and time spent on a page, and other similar event or session data.
• To the extent revealed by the pages you interact with, articles or features you view, your search terms, or how you otherwise choose to navigate one of our websites or mobile applications, information that concerns your health or information that concerns your sex life or sexual orientation.

Please review the “Exercising Your Right to Opt-Out of ‘Shares’ and to Limit the Use and Disclosure of Your Sensitive Personal Information” section below for instructions on how to opt out of “shares.”

RVO Health does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.  

G. Your Rights Under the CCPA

Subject to exceptions, the CCPA provides California residents with the rights discussed below.  For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

1. Right to Know.  You have the right to request that we provide you certain information about our collection and use of your personal information during the past twelve (12) months (or longer, as permitted by the CCPA).  Specifically, you may request that we disclose (in whole or part):

• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• The business and commercial purposes for collecting (or selling or sharing, if applicable) your personal information;
• The categories of third parties to whom we disclose (or sell or share, if applicable) your personal information;
• The specific pieces of personal information we collected about you;
• If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party; and
• If applicable, the categories of personal information that we sold, and for each category, the categories of third parties whom such information was sold.  

As noted above, you have the right to request that we provide copies of the specific pieces of personal information we collected about you.  If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically.  If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible.  Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.

1. Right to Request Deletion.  You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
2. Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
3. Right to Opt-Out of Sales or Sharing. You have the right to request that we opt you out of the “selling” or “sharing” of your personal information for the purposes of cross-context behavioral advertising. We do not “sell” any personal information; but we do engage in “sharing.”
4. Right to Limit Use or Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use and disclosure of your sensitive personal information for certain purposes, where the law allows and subject to applicable exceptions or limitations.

H. Exercising Your Right to Know, Request Deletion, or Correct Inaccurate Information

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by completing sending an e-mail to: legal@rvohealth.com with the subject line: “CCPA Request,”.  Your request must include your name, email address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information.  If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request.  In order to protect the privacy and data security of consumers, the verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

You may only make a verifiable consumer request to know twice within a 12-month period.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  We may also request that you provide additional information if needed to verify your identity or authority to make the request.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request.  

The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days.  If we require more time, we will inform you of the reason and extension period in writing.  We will deliver our written response via e-mail.  Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For requests to know specific pieces of information collected about you, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another.  We will not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.  

I. Exercising Your Right to Opt-Out of “Shares” and to Limit the Use and Disclosure of Your Sensitive Personal Information

You can request to opt-out of the “sharing” of your personal information or otherwise direct us to limit the use and disclosure of your sensitive personal information as follows:

• For information collected from you through our use of automatic technologies on our websites or mobile applications: If enabled for the jurisdiction from which you are accessing our website or mobile application, you can opt out of the sharing of your personal information or direct us to limit our use and disclosure of your sensitive personal information by configuring your settings through the “Privacy Settings” link in the website footer or mobile application settings menu accordingly or by enabling the Global Privacy Control on your browser or device (to learn more: https://globalprivacycontrol.org/). Your actions only apply to the browser or device you are using to interact with our website or mobile application and not to other devices or browsers.  If you clear your cookies or change your preferences on a particular browser or device, or use another browser or device to interact with our websites and mobile applications, you may need to complete the action again.
• For information collected from you using other means (e.g., account profile information): You can submit a request to opt out the sharing of your personal information or direct us to limit our use or disclosure of your sensitive personal information by emailing us at legal@rvohealth.com.

The CCPA requires us to comply with the above requests as soon as feasibly possible, but no later than fifteen (15) business days from the date the request is received. No verification is required; however, we may deny a request if we have a good-faith, reasonable, and documented belief that the request is fraudulent. In the event we deny a request for this reason, we will inform the consumer that we are not complying with the request and provide an explanation of why we believe the request is fraudulent.

Requests may be made using an authorized agent, if the consumer provides the agent with written permission signed by the consumer to act on the consumer’s behalf. We may deny a request if the applicable agent does not submit proof that it has been authorized by the consumer to act on the consumer’s behalf.

Once a consumer makes the request, we will honor such request for at least twelve (12) months before asking the consumer to reauthorize certain personal information usage. Additionally, if a consumer initiates a transaction or attempts to use a product or service that requires certain uses of personal information, we may inform the consumer that the transaction, product or service requires the use or disclosure of the consumer’s personal information and provide the consumer instructions on how to opt it or consent.
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J. Our Commitment Not to Discriminate

Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:  

• Denying you goods or services.
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Providing you a different level or quality of goods or services.
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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K. Data Disclosures for Direct Marketing Purposes

California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

Additional Information for Nevada Residents

Under Nevada law, Nevada “consumers” may request that certain “operators” of internet sites and online services refrain from the “sale” of their “covered information” to third parties (as such terms are defined under Nevada law). If you are a Nevada resident and wish to exercise this right, please submit a request to opt out of the sale of your personal information to legal@rvohealth.com.   Nonetheless, you may contact us at the information below to make a request under the laws of the state of Nevada. .

Additional Information for Residents of Other U.S. States

The laws of the jurisdiction where you reside (e.g., Delaware, Oregon, Iowa, Nebraska, New Jersey, New Hampshire, Texas, Virginia) may afford you certain rights with respect to your personal information.

A. Personal Information We Collect and Process

In many ways, the information contained in the “Additional Information for California Residents” section above is applicable for residents of other U.S. states. For example, the sections above entitled, “Personal Information We Collect and Disclose,” “Categories of Sources of Personal Information,” and “Business or Commercial Purposes for Collecting and Disclosing Personal Information,” describe the categories of personal information processed by us, the purposes for processing, the categories of personal information disclosed to third parties, and the categories of third parties to whom we disclose personal information.

The laws of some U.S. states regulate the handling of “sensitive personal information” or “sensitive data.” For example, information that reveals an individual’s racial or ethnic origin or information about a person’s sexual orientation or sexuality is often considered “sensitive personal information.” The portions of our “Additional Information for California Residents” section above that discuss “Personal Information We Collect and Disclose” and “Sensitive Personal Information” describe the types of sensitive personal information we collect and process.

B. Your Personal Information Rights

Subject to exceptions, the laws of your state of residence may provide you the right to:

• Confirm whether we are processing your personal information and/or to access such data;
• Update or correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information;
• Delete personal information provided by or obtained about you;
• Obtain a copy of the personal information provided to or processed by us, in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means;
• Obtain a list of the third parties to whom we have disclosed personal information;
• Be free from discrimination for exercising any of the rights described in this section; and/or
• Opt out of the sale of your personal information, the processing of your personal information for the purposes of targeted advertising, or the use of your personal information for automated decision-making or automated profiling in furtherance of decisions that produce legal or similarly significant effects.

We do not engage in automated profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers. As a result, the right to opt out of such activities may not be available.

With respect to sensitive personal information, where we are providing you a product or service that you have specifically requested from us, or we are taking steps to comply with applicable laws, or we are otherwise taking steps to perform a contract to which you are a party, we may collect and process your sensitive personal information without your consent. If we collect or use your sensitive personal information for other purposes, however, we will obtain your consent for such processing, where the law requires us to do so. Where consent is the basis for processing your sensitive personal information and where law permits, you have the right to withdraw your consent to such processing.

• For sensitive personal information collected from you through our use of automatic technologies on our websites or mobile applications: You can withdraw your consent to processing for certain purposes by emailing legal@rvohealth.com or by enabling the Global Privacy Control on your browser or device (to learn more: https://globalprivacycontrol.org/). Your actions only apply to the browser or device you are using to interact with our website or mobile application and not to other devices or browsers.  If you clear your cookies or change your preferences on a particular browser or device, or use another browser or device to interact with our websites and mobile applications, you may need to withdraw consent using these tools again.
• For sensitive personal information collected from you using other means (e.g., account profile information): You can withdraw your consent to processing for certain purposes by emailing us at legal@rvohealth.com.

We do process personal information for targeted advertising purposes and, under certain states’ laws, our disclosures to our advertising and marketing vendors may be considered a “sale” of personal information.  

• For personal information collected from you through our use of automatic technologies on our websites or mobile applications: You can opt out of the processing of your personal information for targeted advertising purposes by emailing legal@rvohealth.com or by enabling the Global Privacy Control on your browser or device (to learn more: https://globalprivacycontrol.org/). Your actions only apply to the browser or device you are using to interact with our website or mobile application and not to other devices or browsers.  If you clear your cookies or change your preferences on a particular browser or device, or use another browser or device to interact with our websites and mobile applications, you may need to opt out again.
• For personal information collected from you using other means (e.g., account profile information): You can submit a request to opt out of the processing of your personal information for targeted advertising purposes by emailing us at legal@rvohealth.com.

In the event we decline your request, depending on the applicable law, you may have the right to appeal the decision. You can do so by contacting us at legal@rvohealth.com. You may also be entitled to report the matter to the appropriate regulator in your state.

Data Retention

We retain personal information for as long as necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements.  We also consider any specific limitation periods under applicable law.

Information Security

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification.  Please be aware that no data transmission over the Internet is 100% secure.  While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Data Location

You understand and agree that information about you may be stored or processed by information technology systems located in the United States or jurisdictions that may have laws that differ from the laws of your country of residence or the jurisdiction in which you reside.

Links to Third-Party Websites

Our websites and mobile applications may contain links to third-party digital properties (e.g., social media sites). Such third-party digital properties have separate privacy policies that you should review. We cannot and do not take responsibility for the content of linked websites or those companies’ data-handling practices.

Privacy of Children Online

Our websites and mobile applications are intended for use by a general audience. We do not knowingly collect the personal information of any individual under the age of 13. If you believe we have collected the personal information of a child under 13, please email us at legal@rvohealth.com.

Changes to the Privacy Notice

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Notice from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements.  

Please note that we may change this Notice from time to time.  If there are changes to our Notice, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the website after any changes is deemed to be acceptance of those changes.  Accordingly, we encourage you to check the Notice periodically for updates.

Contact Us

If you have any questions regarding our information handling practices, you may contact us at:

Email: legal@rvohealth.com
Postal Address:
RVO Health, LLC, 1101 Red Ventures Drive, Fort Mill, SC  29707

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