ACNEALLY ONLINE PRIVACY POLICY

Last revised: April 18, 2020

1.    INTRODUCTION

The purpose of this Privacy Policy is to describe how Vtmna, Inc. (“AcneAlly”), collects, uses and shares information about you through our website located at www.AcneAlly.com (the “Site”). AcneAlly respects your privacy and is committed to protecting it as outlined in this Privacy Policy. If you do not agree with our policies and practices, you may not use our services. By accessing or using our services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our services after we make changes is deemed to be acceptance of those changes. Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

While this Privacy Policy describes how we collect, use, and disclose your information, it does not address any PHI submitted by you in relation to services by AcneAlly, which is covered by the Notice of Privacy Practices: https://www.AcneAlly.com/privacy-practices

 

Our Privacy Policy explains:

·       Information That We Collect

·       How We Use and Share Your Information

·       Access to Your Information and Choices

·       Security of Your Information

·       California Privacy Rights

·       Consent to Processing of Personal Data in United States

·       Changes to Our Privacy Policy

·       Questions and How Contact Us

 

 

Scope; Third Party Sites. This Privacy Policy applies only to information we collect at and through the Site. Our Site also contains links to third party sites that are not owned or controlled by AcneAlly. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

Terms of Use. Please note that your use of our Site, and your information, is also subject to our Terms of Use.

2.    INFORMATION THAT WE COLLECT

Information You Provide to Us

We collect information you provide to us, for example when you transmit information to our Site, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us or use our Site in commerce. This information may include:

·       Name

·       Address

·       Email address

·       Telephone number

·       Payment information (credit card or debit card number, expiration date and credit card security code)

·       Date of birth

·       Portions of social security number

·       Information listed on your driver’s license or other identification

Please note AcneAlly does not practice medicine or provide medical care. We do not provide or intend to provide answers to medical-related questions. Furthermore, if you sign up to use our service you may also be asked to submit certain confidential information during the sign-up process, as well as demographic and other information relevant to diagnosis and treatment, such as lifestyle and general medical history (e.g. conditions, allergies, medications etc.). You will be able to send confidential messages and communicate with a doctor regarding your diagnosis and treatment. AcneAlly will keep messages transmitted through the Site private and confidential to its reasonable ability. The information that we collect varies depending upon how you use our Services. When you request evaluation, you will need to provide us with health-related information (“Protected Health Information” or “PHI”) that a Physician will need to properly provide medical services. We will not use any PHI for any other purpose not in accordance with this Agreement, or any other Agreement between you and AcneAlly, without your written authorization, or unless otherwise permitted or required by law. You may revoke, in writing, any such authorization at any time, except to the extent we have taken action in reliance thereon.

Your use of the Site may also include collection of information from your mobile device. For example, the Site may request your permission to collect location data and/or may request access to multimedia (photos or videos) stored on your mobile device. You have the option of declining collection of geolocation data, but this may limit your ability to participate in certain activities through the Site. If you do not wish for your location data to be shared with AcneAlly, please respond accordingly when prompted on your mobile device, or visit your mobile device settings. Multimedia will only be collected from your device if you affirmatively select it to upload to the application (i.e. you choose an image or video to store within the Site). Multimedia will not be shared with other Site users (with the exception of your profile photo, to the extent such feature is offered, which will appear in your user profile).

 

Information We Collect Automatically Through Your Use of our Site

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity.

Information Collected Through Cookies and Similar Technologies

We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you. (See, “Advertising” below.)

No Information from Individuals Under the Age of 18

We support and comply with the Children’s Online Privacy Protection Act (COPPA) if you are under the age of 18, please do not attempt to register with us at this Site or provide any personal information about yourself to us. A parent or legal guardian above the age of 18 will be responsible for providing information related to the minor and for paying for the visit requested for the minor.

SPECIAL NOTICE FOR USERS OF THE SITE: IF YOU ELECT TO MAKE YOUR PROFILE (OR THAT OF A MINOR OR FAMILY MEMBER) VIEWABLE BY HEALTHCARE PROFESSIONALS or PROVIDERS, ALL INFORMATION THAT YOU INCLUDE IN THAT PROFILE MAY BE VIEWED BY THE SAME. YOU SHOULD NOT ENTER ANY INFORMATION IN THE PROFILE THAT YOU (OR ANOTHER PERSON) WISH TO REMAIN CONFIDENTIAL. A HEALTHCARE PROFESSIONAL OR PROVIDER WILL NOT BE ABLE TO CONTACT YOU EXCEPT THROUGH THE PERSONAL CONTACT INFORMATION YOU PROVIDE THROUGH THE SITE.

3.    HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information. We collect information from you and use the information to:

·       provide products and services that you order using the Site;

·       register and service your online account;

·       provide information that you request from us;

·       contact you about our services or information you requested;

·       process credit card and debit card transactions;

·       allow you to participate in interactive features of our services;

·       comply with requirements of the iPLEDGE program;

·       send you promotional materials or advertisements about our products and services, as well as new features and offerings;

·       enforce our Terms of Use or other legal rights and remedies;

·       carry out Business Intelligence (as the term is defined in the Terms of Use). For the avoidance of doubt, Business Intelligence shall not include PHI specifically identifiable to any patient.

·       administer surveys, sweepstakes, promotions and contests;

·       provide interest-based targeted advertising to you; and,

·       serve any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

 

 

Sharing with Third Parties.

Healthcare Providers. We share your personal information with various healthcare affiliates, government agencies and their associates, doctors and relevant medical staff in connection with your diagnosis and treatment.

Vendors and Services Providers. We may provide information to third-party vendors and service providers that help us operate and manage our Site, process orders, and fulfill and deliver products and services that you purchase or request from us. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

Corporate Affiliates. We may share your personal information with our corporate affiliates which are subject to this policy and applicable law.

Advertising. We may use how you browse and shop in order to show you ads for AcneAlly or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our site or third-party sites not owned by AcneAlly.

We belong to ad networks that may use your browsing activity across participating websites to show you interest-based advertisements on those websites. Currently, our Site does not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity.

Social Media. If you use third-party services, such as Facebook, Google, or Twitter, through the Site, to login to the Site, or to share information about your experience on the Site with others, these third-party services may be able to collect information about you, including information about your activity on the Site, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.

Public Posts and Activities. If you choose to engage in public activities on the Site, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in these public areas. Any user posting in these public areas understands and acknowledges that there is no expectation of privacy for the information in these public areas.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

4.    ACCESS TO YOUR INFORMATION AND CHOICES

You can access and update certain information we have relating to your online account by signing into your account and going to the Account section of our Site. If you have questions about personal information we have about you or need to update your information, you can contact us or call us at (202) 743-3767.

5.    SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through our Site may not be encrypted, and we strongly advise you not to communicate any confidential information through these means.

6.    CALIFORNIA PRIVACY RIGHTS

Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once (1) per calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).

To obtain this information, please send an email message to team@vtmna.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

7.    CONSENT TO PROCESSING OF PERSONAL DATA IN UNITED STATES

This Site is intended for use only by residents of the U.S. If you are a citizen of the European Economic Area (EEA) or other jurisdiction outside of the U.S., please note that in order to provide our Site, products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

8.    CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review. You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

9.    QUESTIONS AND HOW TO CONTACT US

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please contact us by email at team@vtmna.com, call us at (202) 743-3767, or contact us by US postal mail at the following address:

Vtmna, Inc.

7712 Falstaff Rd

McLean, VA 22102

Telephone: (202) 743-3767

Email: team@vtmna.com