Privacy Policy

Additionally, we may use your information for other legitimate interests as a business, such as data analysis, identifying usage trends, preventing or detecting fraud or abuses, determining the effectiveness of our promotional campaigns, and evaluating and improving our website, products, services marketing, and your experience.  We may use and store the information we collect in aggregated and anonymized form so that it is not associated with individual end-users and does not include personal information. We may de-identify your information in accordance with applicable law and industry standards, and use or share such de-identified information for lawful business purposes. We may further use any information for any purpose not prohibited by applicable law.  We will not use identifiable personal information without your consent.

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1. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

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We disclose personal data with your consent or as we determine necessary to complete your transactions or provide the services you have requested or authorized. Subject to the limitations described in the Protected Health Information section above, we may disclose your information to third parties in connection with the provision of our Service or as otherwise permitted or required by law. For example, without limitation, we may disclose your information in the following circumstances: 

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• Consent:  We may process your information if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests:  We may process your information when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract:  Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Financial Services and Payment Processing. When you provide payment data, for example to make a purchase, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services. 
• Legal Obligations:  We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests:  We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of Zealthy or others and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:  

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• Vendors, Consultants, and Other Third-Party Service Providers.  We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.  Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts.  We may allow selected third parties to use tracking technology on the website, which will enable them to collect data about how you interact with the website over time.  This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity.  Unless described in this Privacy Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
• Corporate Transactions.  We may share or transfer your information in connection with, or during negotiations of, any merger, divesture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred. 
• Third-Party Marketers/Advertisers.  We may use third-party advertising companies to serve ads when you visit the website.  These companies may use information about your visits to our website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about products and services of interest to you. For example, we may share identifying information with an advertising partner in order to deliver personalized advertising to you or for the purpose of delivering advertisements to other people with similar interests to you. This may include sensitive personal information such as health data or information about your medical condition and treatment to the extent it is not Protected Health Information. For example, if you view a webpage about hair loss treatments, we may provide that information to an advertising partner who will then deliver advertisements to you on different websites based on your viewing activity. 
• Other Users.  When you share personal information (for example, by posting testimonials or other content to the website, if applicable) or otherwise interact with public areas of the website, such personal information may be viewed by all users and may be publicly distributed outside the website in perpetuity.  
• Security, Safety and Protecting Rights. We will disclose personal data if we believe it is necessary to: 
  
  • Protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury to anyone; 
  • Operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or 
  • Protect the rights of property of ourselves or others, including enforcing our agreements, terms and policies. 

Third Party Analytics and Advertising Companies. Third party analytics and advertising companies also collect personal data through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data, as described in the “Cookies” section of this statement. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we may use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.Other third-party analytics and advertising providers we use on our websites include, for example:

Some of the data disclosures to these third parties may be considered a “sale” or “sharing” of personal information as defined under the laws of California and other U.S. states. Please see the “California Residents” subsection under Section 9 below for more details.

Please note that some of our services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy statements.

1. HOW LONG DO WE KEEP YOUR INFORMATION?

Zealthy may retain your personal information for as long as it believes is necessary for the purposes set out in this Privacy Policy as long as necessary to comply with its legal obligations (e.g. tax, accounting, or other legal requirements); and/or as long as needed to provide you with the Services. Zealthy may dispose of or delete any such information at any time except as set forth in any other agreement or document executed by Zealthy or as required by law. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Other third parties with whom we share your information have their own policies and procedures with respect to how long they may retain your information and how and when they dispose of or delete your information.

2. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate physical, technical and organizational security measures designed to protect the security of any personal information we process.  

We use reasonable care to protect your personal information provided by you to our website.  We will periodically review and modify, where appropriate, its information security policies and procedures.  

While we have in place security policies and procedures that seek to mitigate the risk of unauthorized access of your information, we cannot guarantee that the Internet is a secure medium.  You should never divulge your account username and/or password to anyone else.  Although we will do our best to protect your personal information, the transmission of personal information to and from our website is at your own risk.  Your information may be lost during transmission or may be accessed by unauthorized parties.  We do not accept any liability for direct or indirect losses with regard to the security of your personal information or data during its transfer via the internet.  Please use other means of communication if you think this is necessary or prudent for security reasons.

Lastly, while we strive to use reasonable physical, technical and administrative measures to protect information under our control, you must keep your account password secure and your account confidential, and you are responsible for any and all use of your account. If you have reason to believe that the security of your Account has been compromised, please notify us immediately in accordance with the “Contact Us” section below. 

3. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 13 years of age. The Service is not designed or intended to attract, and is not directed to, children under thirteen (13) years of age.  If we obtain actual knowledge that we have collected personal information through the Platform from a person under thirteen (13) years of age, we will promptly delete such information from our systems and take all necessary steps to prevent further collection.  If you become aware of any data we have collected from children under age 13, please contact us at legal@getzealthy.com.

Our Service is generally intended for use by individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. Individuals who are between the ages of thirteen (13) and eighteen (18) (or such older age of majority) may use the Service if a parent or legal guardian provides consent to such use in accordance with the requirements set forth in our Terms and Conditions and the Service.

Furthermore, if you are under sixteen (16) years of age, then you (or your parent or legal guardian if you are under age 13) may at any time request that we remove content or information about you that is posted on the Platform. Please submit any such request ("Request for Removal of Minor Information") to either of the following:

By mail:

Zealthy, Inc., Attn: Compliance Officer, 30 Irving Pl., Floor 7, New York, NY 10003, with a subject line of "Removal of Minor Information.” 

If you send by mail, please send by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking.

By email:

legal@getzealthy.com, with a subject line of "Removal of Minor Information"

For each Request for Removal of Minor Information, please state "Removal of Minor Information" in the email or letter subject line, and clearly state the following in the body of the request:

• The nature of your request
• The identity of the content or information to be removed
• The location of the content or information on the Platform (e.g., by providing the URL)
• That the request is related to the "Removal of Minor Information"
• Your name, street address, city, state, zip code and email address, and whether you prefer to receive a response to your request by mail or email 

We will not accept any Request for Removal of Minor Information via telephone or facsimile. Zealthy is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled, or incorrectly sent.

Please note that we are not required to erase or otherwise eliminate, or enable erasure or elimination of such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Zealthy to maintain the content or information; when Zealthy maintains the content or information on behalf of your Providers (as defined in our Terms and Conditions) as part of your electronic medical record; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when Zealthy anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Zealthy’s voluntary practices concerning the collection of personal information through the Service from certain minors, and is not intended to be an admission that Zealthy is subject to the Children's Online Privacy Protection Act, the Federal Trade Commission's Children's Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

4. WHAT ARE YOUR PRIVACY RIGHTS?

Account Information:  If you would at any time like to review or change the information in your account or terminate your account, you can contact us at support@getzealthy.com. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.  However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions of Use, and/or comply with legal requirements.

Opt Out of Email Marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below.  You will then be removed from the marketing email list. Please note, however, that we will still need to send you service-related emails that are necessary for the administration and use of your account.  To otherwise opt-out, you can contact us at support@getzealthy.com.

With regard to personal information that you have provided under this Privacy Policy, you may exercise your opt-out choices available to you (if any and where applicable) by contacting us directly. 

There are certain browser and platform controls that may be available to you in order to opt-out from or otherwise control targeted advertising as described below. You can use the opt-out controls offered by the organizations our advertising partners may participate in, which you can access at:

• NAI (http://optout.networkadvertising.org)
• DAA (http://optout.aboutads.info/)
  

You can use the other cookie or mobile ID controls described below.

These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, you will need to take these actions from those systems to set applicable controls for those systems.

Some privacy laws define “sale” broadly to include some of the disclosures described in Section 5 above. To opt-out from such data “sales” you can email support@getzealthy.com.

It may take up to ninety (90) days for your opt-out choices to be fully effective across all our systems and third-party service providers, though we will begin processing your request promptly upon receipt. Our systems may require time to update, and promotional mailings, by e- mail or otherwise, using personal information shared before your opt-out may already be in process. Thus, you might continue to receive promotional materials upon the personal information you have provided under this Privacy Policy for up to ninety (90) days.

California Residents. If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information, including: 

• Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this statement by clicking on the above links.
  
• Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by emailing us at support@getzealthy.com.
  
• Rights to Request Correction or Deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to correct or delete, email us at support@getzealthy.com.
  
  
• Right to Opt-Out/“Do Not Sell or Share My Personal Information.” You have a right to opt-out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA.
  
  Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data sharing described in this privacy statement may be considered a “sale” or “sharing” under those definitions. In particular, we let advertising and analytics providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (browsing, clicks, app usage), device data, and geolocation data through our sites and apps when you use our online services, but do not “sell” or “share” any other types of personal information. If you do not wish for us or our partners to “sell” or “share” personal information relating to your visits to our sites for advertising purposes, you can make your request by clicking on the “ ” link at the bottom of the page or using a Global Privacy Control. If you opt-out using these choices, we will not share or make available such personal information in ways that are considered a “sale” or “sharing” under the CCPA. However, we will continue to make available to our partners (acting as our service providers) some personal information to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising.
  
  We do not knowingly sell or share the personal information of minors under 16 years of age.
  
• Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law.
  
  To opt-out from such additional purposes, please contact support@getzealthy.com.
  
  

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.

Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA. 

Additionally, under California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.  If you are a California resident and would like to make such a request, please contact us by mail at Zealthy, Inc. Attn.: California Privacy Rights, 30 Irving Pl., Floor 7, New York, NY 10003, or by email at support@getzealthy.com.

If you are under 18 years of age, reside in California, and have a registered account on our website, you have the right to request the removal of unwanted data that you publicly post on the website.  To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.  We will make sure the data is not publicly displayed on the website, but please be aware that the data may not be completely or comprehensively removed from our systems.

Nevada Residents.  Zealthy does not sell, rent, or lease your personally identifiable information to third parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you may do so by emailing us at support@getzealthy.com.

International Residents. Our Service is hosted in the United States and intended for visitors located within the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then you acknowledge and consent that you are transferring your personal information outside of those regions to the United States for storage and processing, and that such transfers will be conducted in accordance with applicable data protection laws including, where applicable, the EU Standard Contractual Clauses or other appropriate transfer mechanisms. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including personal information, on or to the Service, you consent to such transfer, storage, and processing. Further, you acknowledge that your continued use of the Service is governed by U.S. law and regulation, this Policy and our Terms of Service. 

If you are a resident in the European Union and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.  You can find their contact details here: https://ec.europa.eu/info/law/law-topic/data-protection_en.

5. BROWSER OR PLATFORM CONTROLS 

Cookie Controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. 

Global Privacy Control. Some browsers and browser extensions support the “Global Privacy Control” (GPC) or similar controls that can send a signal  to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal. 

Do Not Track. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized.  As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

Mobile Advertising ID Controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs. 

Email Web Beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that hose those images. 

Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, whether the request is unreasonable or excessive, or where otherwise permitted by applicable law. 

Finally, please note that this Privacy Policy applies only to your “personal information,” which is separate from “medical information” or “protected health information” as defined under HIPAA and other applicable healthcare privacy laws. For information about how we handle your medical information or protected health information, please refer to our Notice of Privacy Practices. 

6. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

We may update this Privacy Policy from time to time.  The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.  If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.  We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

7. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

If you have questions or comments about this Privacy Policy, you may email us at support@getzealthy.com

By clicking “I Agree,” checking the agreement box or a related box to signify my acceptance, using other acceptance protocol presented through the Website, App or Service, or otherwise indicating acceptance, I, _______________________________,  acknowledge that I have read, understand and agree to this Policy and consent to receive telehealth services. 

I acknowledge and understand that I will digitally receive a copy of this Policy (you have the ability to print, PDF, copy/pase, or screenshot a copy of this Policy).