Privacy Policy

This privacy policy was last updated on 12 February 2024.

We are Vira Health, Inc. (along with its affiliates, “Vira Health” or “We” or “Our” or “Us”). We are committed to protecting and respecting your privacy and continuing compliance with the evolving legal and regulatory standards for privacy and data protection applicable in the jurisdictions where we conduct our activities.

This privacy policy (the “Privacy Policy”) explains how we use your personal data collected through our website, wellness app, and associated services. Please read this Privacy Policy carefully to understand our practices regarding your personal information and how we will handle your personal information.

This website is intended for use only in the United States of America. If you use the website or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) by using the website or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.
If you have any questions about this Privacy Policy, including any requests relating to your legal rights, please contact us at privacy@vira.health.

 

HOW DO WE USE YOUR PERSONAL DATA?

“Personal Data” means all information that relates to an individual or information that can be used to identify a person, both directly (e.g., your name or your photograph) and indirectly (e.g., a medical insurance number or your position in a company). Vira Health collects and processes Personal Data from the following sources and for the purposes indicated:

• When you create an account. If you create an account with our website, we will collect information including your name, password and email address. We collect these details to fulfill our contractual obligations to you.
• When you complete a menopause assessment. If you complete a menopause assessment through our website, we will collect information including your name, date of birth, medical history, current menopause symptoms, family history, lifestyle and photo ID. We collect this information to fulfill our contractual obligations to you and where we process your health information based on your explicit consent so that we can provide you with healthcare services from a healthcare professional, including tailored menopause plan and support. You can withdraw your consent at any time by contacting us privacy@vira.health.
• When you make a payment. When you make a purchase, you may be asked to supply certain information relevant to the transaction, including, without limitation, your payment card number and expiration date, your billing address, your shipping address, your phone number and/or your email address.
• When you provide a testimonial. If you provide us with a testimonial or story we may publish this or otherwise use it for our internal business purposes. We will anonymize any public testimonials and we process this information as it is in our legitimate interests to promote our business and improve our services. If we publish your story or testimonial in a way that identifies you we will only do so with your consent and if it contains your health information with your explicit consent. If you would ever like us to remove your testimonial or story from our website, please contact us at privacy@vira.health and we’ll of course remove this.
• When we de-identify your personal data. In some circumstances we and our sub-contractors may carefully de-identify your personal data so that it can no longer be associated with you, and we and they may use this de-identified information indefinitely without notifying you. We use this de-identified data to (i) complete research in the public interest, such as to analyze trends in menopause symptoms and treatments to develop our products and services and support other similar programs around the world, including using the data in blogs and academic articles and (ii) to meet our reporting requirements.
• When you attend one of our events or any third party events. When you attend one of our events (whether in person or online e.g. via Zoom), we will usually collect your name and email address. We collect this information because it’s in our legitimate interests to know who’s attending our events. Where you provide us with your personal data at a third party event where we are also in attendance, we will process this under our legitimate interest to promote our business and follow up on your expression of interest in our group.
• When you apply for a job with us. When you enter into the recruitment process with us we may collect your name, contact details, recruitment information (e.g. right to work documentation and references), qualifications, accreditations, and any additional information we may receive from our recruitment partners. We will use your personal data to assess your suitability for our available roles before taking steps at your request to enter into a contract with you. Where we process your right to work documentation, we will do so to comply with our legal obligations.
• When you contact us. When you contact us either by phone or email with general queries, we will usually collect your name, contact details and information relating to your query, because it is in our legitimate interest to make sure we can properly respond to your query.
• When you visit our website. When you visit our company websites, we may collect various data linked to virtual identities assigned to visitors when they access our websites through cookie-based technologies. This data is used for various purposes, including site analytics and first-party marketing. In certain cases, these virtual identities are linked to the real-world identities of visitors when you provide your Personal Data. This allows Vira Health to tailor marketing messages to you, inclusive of information that is likely to be of interest to you. Web visitors may visit Vira Health’s website without providing any Personal Data. If a web visitor chooses to contact Vira Health and provide Personal Data, Vira Health will use it for the purpose for which it has been submitted to Vira Health, e.g., to respond to a request for information or to apply for an open position with Vira Health. Vira Health may also use Personal Data provided by web visitors who are patients for marketing and promotional purposes.
• When we use vendors. Vira Health interacts with various third parties and records certain Personal Data of their staff to be able to conduct activities together and for the performance of any vendor-related contracts.
• Newsletters. When we send you our newsletters because you have opted-in to receive them, we rely on your consent to contact you. If you have not opted-in and we contact you by email, we do this because of our legitimate interest to promote our business. You can unsubscribe from our updates at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing privacy@vira.health.
• On social media. When you connect with us on social media including on Twitter, Instagram and LinkedIn we will collect and look after your handle, name and email address under our legitimate interest to respond to your comments and queries promptly.
• Technical information when you use our website or app. When you consent, we collect information about how you use our website. We use this information to improve our website and to better understand how people use it. More detail on the information we collect and how we do this is set out in our cookie policy below.
• To continue to provide our services to you in the event our business is sold. In order to ensure we can continue to provide our services to you by a prospective buyer, we may process your personal data where we have a legitimate interest to do so. If you object to our use of your personal data in this way, the buyer of our business may not be able to provide services to you.

Vira Health does not collect information through our websites from individuals who are known to be designated as children under respective applicable data privacy laws, and no part of our online presence is directed to any minors.

 

WHO DO WE SHARE YOUR DATA WITH?

1. Business partners, researchers, suppliers and subcontractors for the performance of the contract we enter into with them and for the advancement of high quality menopause care. Your medical care will be provided by OpenLoop physicians, with whom we will share the information from your online assessment, so that they can provide medical services.
2. Analytics and search engine providers to assist us with the improvement and optimization of our site, as further described in the Cookies and Other Online Tracking Technologies Section.
3. Promotional events, we do not sell data for marketing purposes. We may share your data with an event organizer. We will always tell you before (usually on the event registration form) and you will be given the chance to opt-out before we do this.
4. Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to meet any legal requirement, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
5. Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.

 

HOW IS MY DATA PROTECTED?

Vira Health will take commercially reasonable and appropriate measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into consideration the risks involved in the processing and the nature of the Personal Data.

Vira Health websites may contain links to websites outside of Vira Health. Linked websites are not under the control of or endorsed by Vira Health. This Privacy Policy does not apply to linked websites outside the Vira Health organization. It is recommended that visitors review the privacy policy of each individually linked website.

 

HOW LONG DO WE KEEP YOUR DATA FOR?

We will only retain your personal data for as long as we need it to fulfill the purposes we collected it for and we will periodically review the personal data in our reviews to ensure we are only holding what is necessary.  We may be required to keep your data for longer in order to be able to comply with our legal, accounting or regulatory requirements. Please note where we are relying on your consent to hold your personal data, you can withdraw this consent at any time and we can delete your data.

 

QUESTIONS, COMMENTS AND MORE DETAIL

Your feedback and suggestions on this policy are welcome. Vira Health may revise this Privacy Statement by updating this posting.  Personal Data will be handled in accordance with the policy in effect at the time it is collected.

We’ve worked hard to create a policy that’s easy to read and clear. But if you feel that we have overlooked an important perspective or used language which you think we could improve, please let us know by email at privacy@vira.health.

If you’d prefer, you can always get in touch with us by mail to our registered office at Vira Health Inc., 1257 Worcester Rd #1046 Framingham, MA 01701

 

COOKIES AND OTHER ONLINE TRACKING TECHNOLOGIES

Our sites use cookies to distinguish you from other users of our sites. This helps us to provide you with a good experience when you browse our sites and also allows us to improve our sites.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide your consent.

Vira Health uses the following types of cookies on our sites:

• Strictly Necessary Cookies, which are needed for the website to operate as reasonably expected by you.
• Functional or Preference Cookies, which remember your name or choices.
• Performance or Analytic Cookies, which collect passive information about your use of the website.
• Advertising or Targeting Cookies, which are used to make advertising messages more relevant and personalized to you based on your inferred interests.

Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:

• First-Party Cookies: You can enable, disable, or delete cookies through the browser you are using to access our services. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our website, and/or parts of the website may not work properly for you. You can find more information about how to change your browser cookie settings at https://www.allaboutcookies.org. 
• Third-Party Cookies: You can disable cookies from third parties by using your browser settings or, if available, directly opting-out of cookie collection with the third-party cookie service provider via their website. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs.