Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.
The purpose of the ViviCompanion and ViviCircle applications (the “Apps”) are not for medical treatment. The Apps comply with the Food & Drug Administration wellness exemption that states that software that is intended “for maintaining or encouraging a healthy lifestyle and is unrelated to the diagnosis, cure, mitigation, prevention, or treatment of a disease or condition” is not a device under section 201(h) of the Federal Food, Drug and Cosmetic Act.
Collection and use of information
Personal information is data that can be used to identify or contact a single person. Certain personal information and non-personal information, as described below, may be collected from or about you through these Apps.
If you decide to download and use the Apps, below are examples of the types of information that we collect and how we use it.
What information we collect
When you download the Apps, whether you use them in the context of a formal treatment program, medical or healthcare services (individually or collectively, “Provider Services”) or outside of any such Provider Services, the following categories of information (which may include some personal information) may be collected from or about you through the Apps:
- Contact information such as your name, email address, state of residence, and phone number.
- Demographic information, such as your age, gender, and race.
- Self-reported medical history and information, such as your height/weight, prior medical diagnosis and testing (e.g., diagnosis of depression or type of addiction), current and previous use of certain medications (e.g., buprenorphine), certain family history (e.g., history of addiction) and health habits (e.g., smoking). This information may be collected through in-app or other health surveys that you may be asked to complete.
- Sensor information, such as heart rate, heart rate variability, sp02, respiration, activity, movement, location, etc.
- Technical data, which in many cases is non-personal information, i.e., data in a form that does not, on its own, permit direct association with any specific individual. Technical data includes, for example, information about your app usage (e.g., when the Apps were first launched), app version and installation information, and technical data about your device, such as operating system and model. These Apps do not respond to browser “Do-Not-Track” signals.
- Adverse event information, such as a concern, adverse event, alert, or other reportable matter arising during App usage.
- Location data.
- Activity, exercise, engagement and other data and information to determine the state, status and condition.
If you receive a notification and follow the call to action, the following categories of information (which may include some personal information) may also be collected:
- Blood Alcohol Content levels associated with the use of the breathalyzer report data (if you are asked to take a breathalyzer test).
- Various information associated with forms of ecological momentary assessments, clinically valid surveys or other types of surveys or questionnaires.
- Contact information for your clinician, sponsor or family member (your “Care Circle”) (if you are asked to contact via phone or text).
- Additional information collected by or provided to the Business Associate, such as symptoms experienced at the time of a notification, or symptoms and medical condition provided or observed by the Business Associate.
- Additional self-reported medical history and information as described above.
- Session information, such as the times and durations of your voice and video calls, and texts, with your health care provider (the “Provider”) or Care Circle member, if applicable.
- Other information that the Apps may add from time to time.
How we use your information
Your personal information, such as your contact information, may be used for purposes such as:
- To associate you to a Provider, as you move in and out of episodes of care, including determining your eligibility for participation with a Provider.
- To enable services and support a Provider.
- To contact you with surveys or other messages through in-app notifications, email, or otherwise.
- To allow a sponsor or family member to monitor you as part of the Care Circle.
- To associate and determine short-term and long-term outcomes.
Your dis-identified information and data may be used for purposes such as:
- To aggregate and provide statistical data for various uses
- To conduct and support refinement to algorithms and machine learning techniques
- To evaluate various vitals rates across populations and at various activity levels
- To develop health-related products and improvement activities
- For other research purposes
- To issue research findings and related reports, which will not identify you
Disclosure to Third Parties
ViviHealth, Providers and Business Associates may share your information with companies who provide services and are allowed to share your information under the terms of HIPAA, the HIPAA Security Rule and associated regulations. These companies are obligated to protect your information.
Your personal information may also be disclosed to the following third parties:
- Government and Regulatory authorities, such as the U.S. Department of Health and Human Services, the Food and Drug Administration, and other federal or state government agencies.
- Law enforcement or other third parties pursuant to valid legal process such as a subpoena, litigation or court order. We may also disclose information about you if we determine that for purposes of national security, or other issues of public importance, disclosure is necessary or appropriate.
- Others, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Protection of Your Information
Retention of Personal Information
Your use of the Apps is voluntary. You may decide not to use the Apps and remove them from your device at any time. If you decide to stop usage, we will not delete the information that we have already collected and we may continue to use it, but we will stop receiving any new information and data about you and will stop contacting you.
The usage of the Apps require those to be age 13 and older. These Apps are not intended for children under the age of 13. If we learn that we have collected the personal information of a child under 13, we will take steps to delete the information as soon as possible. Notwithstanding the foregoing, if a Business Associate or parent chooses to provide due authorization pursuant to a Consent to ViviHealth’s Collection, Use and Disclosure of Your Child’s Information of the Apps and such consent is formally verified, then the child may use the Apps.
ViviHealth 11711 Domain Drive, Suite 1374, Austin, TX 78725 USA