Vivendi Health, LLC

Last Updated: September 26, 2023

INTRODUCTION

Welcome to Vivendi Health, LLC (“Vivendi Health”, “we”, “our”, or “us”). We are a distinguished health coaching and mentorship provider, committed to delivering high-quality, personalized healthcare guidance through a multidisciplinary team of skilled health professionals including neurologists, nutritional scientists, researchers, among others. Our objective is to foster a high-touch, collaborative environment between our experts and clients, ensuring tailored health strategies that align with our clients' unique health goals and circumstances.

Through these engagements, we are granted access to sensitive personal and health-related information necessary for rendering our bespoke services. We highly regard the privacy and security of our clients’ information and are dedicated to managing such data with the utmost integrity and in accordance with applicable legal and regulatory frameworks.

This Privacy Policy (“Policy”) is crafted to provide a clear understanding of how we collect, use, protect, and handle your personal information as you interact with us, whether personally, through our website, mobile applications, or other digital platforms under our operation (collectively referred to as the “Platforms”). The Policy also elucidates your rights and choices concerning your personal information and how you can access and update this information.

Your acceptance of the practices described in this Policy is crucial for us to serve you. Therefore, we encourage you to carefully read through this Policy, and should you have any inquiries or need clarification on any aspect herein, please feel free to reach out to us through the contact details provided in the "Contact Us" section below. By accessing or using our services and Platforms, you acknowledge and agree to this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein. If you do not agree with this Policy, we advise against using our services and Platforms.

INFORMATION WE COLLECT

Vivendi Health is deeply committed to providing personalized health coaching and mentorship services tailored to meet the unique needs of each client. In order to deliver on this commitment, we require a thorough understanding of our clients’ health and personal circumstances, which necessitates the collection and processing of detailed personal and health-related information. Herein below is an outline of the categories of information we may collect during your engagement with our services:

Personal Identification Information:

• First Name
• Last Name
• Email Address
• Residential Address
• Telephone Number

Health and Medical Information:

• Medical records inclusive of diagnostic tests, blood work results, and other related medical documentation.
• Medical procedures you are currently receiving or have received in the past.
• Correspondence and communications between you and your other healthcare providers (if shared by you with your Vivendi team). This could include direct correspondence between your Vivendi team and your other healthcare providers.
• Details of any medications, therapies, or treatments you are currently receiving or have received in the past.
• Health-related questionnaires and surveys we may administer to gain further insights into your health and wellness.

Personal and Sensitive Information: During the course of our coaching and mentorship sessions, we may gather various personal and sensitive information that you choose to share with us. This could encompass aspects of your lifestyle, family, work, stress levels, and other factors that may impact your health and well-being.

Technical and Usage Information: When you access our digital platforms, we may automatically collect certain technical information such as your IP address, browser type, device information, and usage patterns to improve the functionality and user experience of our platforms.

Payment Information: While we use ZenBusiness for invoicing and payment processing, we may have access to certain payment-related information necessary for the completion of financial transactions.

Communications: Any communications, feedback, or other interactions you may have with us via email, phone, or other communication channels.

Other Information: Any other information you may choose to provide to us in the course of utilizing our services.

The provision of certain personal and health-related information is mandatory for us to provide our services. Without such information, we may be unable to provide personalized coaching and mentorship.

INFORMATION USE

The primary aim behind the collection of your personal and health-related information is to extend personalized, superior health coaching and mentorship services to you. Your information aids us in gaining a comprehensive understanding of your health status, lifestyle, and goals, which are instrumental in tailoring our services to align with your unique needs effectively. Here are the specific purposes we allocate your information to:

Personalized Service Delivery: To provide personalized health coaching and mentorship services, develop tailored health and wellness plans, and track and monitor your progress towards achieving your health goals.

Communication: To foster effective communication between you and our team of health professionals, provide you with updates, information, and recommendations concerning your health and wellness, and to respond to your inquiries, requests, and feedback.

Operational Efficiency: To process your payments for our services through ZenBusiness, manage our relationship with you, maintain records of the services we render, and analyze and improve the quality, efficiency, and effectiveness of our services and digital platforms.

Legal Compliance and Risk Management: To comply with legal, regulatory, and professional requisites, enforce our terms and conditions, protect our rights, privacy, safety, or property, and/or that of our clients or others, and identify, prevent, and respond to fraud, unlawful or unethical activities, risks, and potential threats.

Research and Development: To conduct research and analysis for enhancing our understanding of health and wellness trends, and improving our services, as well as solicit your participation in surveys, focus groups, or other feedback mechanisms to refine our offerings.

Marketing and Promotions: To provide information regarding our services, new features, promotions, newsletters, and other pertinent information, provided you opt to receive such communications.

Technical Support and Troubleshooting: To provide technical support, troubleshoot issues you may encounter while using our digital platforms, and ensure the security and optimal performance of our digital infrastructure.

Chatbot Integration & Security: Navigating through our chatbot’s operational design, we harness a complex chatbot system to enhance and streamline user engagement. Your individual data, once imparted, is securely anchored within a Google Sheet, creating a secured linkage exclusively between the data and the chatbot. This integrated operation employs a shielded Google service account, not only cementing the safety of the data but also amplifying the chatbot's proficiency in addressing inquiries related to your personal data. Constructed with a pronounced focus on user engagement, the system operates on a fully automated axis, ensuring an unblemished security framework and bespoke personalization, free from human interference.

Data Aggregation: To aggregate and/or anonymize data in a manner that it no longer identifies you, for the purposes of statistical analysis, research, or other business objectives.

Your trust is a top priority for us, and we are committed to managing your information responsibly and in a manner consistent with the high standards of confidentiality and professionalism that govern our practice.

INFORMATION SHARING AND DISCLOSURE

We are committed to upholding the highest standards of confidentiality and security regarding your personal and health-related information. We strictly adhere to a policy of not selling your data to any third parties. However, to provide you with our comprehensive services, there are circumstances under which we may disclose or share your information:

Service Delivery: We may share your information with our team of healthcare professionals, including neurologists, nutritional scientists, researchers, and when necessary, specialists in our professional network, to facilitate the provision of personalized health coaching and mentorship. We may also work with additional staff over time, some of which might have access to your information.

Third-Party Service Providers: We may engage third-party service providers to perform various functions on our behalf. These may include data storage, data analysis, technology support, and other processing services. We ensure that these third-party service providers adhere to stringent confidentiality and data security standards.

Legal Compliance and Law Enforcement: We may disclose your information if required by law, legal process, or if necessary to comply with requests from law enforcement or other governmental authorities.

Protection of Rights and Interests: We may disclose your information to protect the rights, property, or safety of Vivendi Health, our clients, or others, including to detect, prevent, or otherwise address fraud, security, or technical issues.

Business Transactions: In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, your information may be shared or transferred as part of that transaction, always under strict confidentiality terms. Remember, you always have the chance to remove your information from your profile.

Consent: We may share or disclose your information with your explicit consent or at your direction.

Any sharing of your personal information is conducted in a manner that is consistent with applicable laws and regulations, and with the aim of ensuring the continued confidentiality and security of your information.

THIRD PARTY SERVICES

In the process of delivering our comprehensive and personalized health coaching and mentorship services, we may engage the services of third-party providers to facilitate certain aspects of our service delivery. Such third-party services may include, but are not limited to, data storage, data processing, analytics, and other technical services which assist us in maintaining and improving the quality and efficiency of our offerings. Notably, we leverage the platforms of humanOS, Notion, ZenBusiness, Google Suite, Carbon Voice, Super, and other various technologies for specific functionalities that augment our service provision.

• humanOS: humanOS is a platform that we utilize for certain health data management and analytics functionalities. We recommend reviewing the privacy policy of humanOS for a more detailed understanding of their data handling practices, which is available here.
• Notion: Notion serves as an instrumental tool in organizing and managing information crucial to the operations of our services. For a deeper insight into how Notion manages and protects your data, you may review their privacy policy here.
• Super: Super facilitates the rapid creation and management of our website. Super handles the technical aspects of website management, allowing us to focus on delivering quality health coaching and mentorship. To understand how Super manages and protects data, we recommend reviewing their privacy policy here.
• ZenBusiness: We utilize ZenBusiness for invoicing and payment processing services, enabling seamless financial transactions between us and our clients. ZenBusiness’s platform allows for efficient invoicing and secure payment processing, ensuring a streamlined financial interaction. To understand how ZenBusiness manages and protects your data, we recommend reviewing their privacy policy here.

In addition to the platforms mentioned above, please be aware that we may employ other software solutions in the administration of your account, including but not limited to:

• Google Suite: Google Suite provides us with a suite of productivity and collaboration tools to efficiently manage various aspects of our operations, ensuring seamless communication and collaboration within our team.
• Google Cloud Service: Google Cloud Service is utilized to host and securely store data, enhancing data accessibility and reliability while maintaining robust data security measures.
• Carbon Voice: Carbon Voice enhances our communication capabilities by facilitating efficient voice communication with our clients, ensuring a smooth and responsive client experience.
• Messenger or a messaging app of your choosing: We are flexible in accommodating your preferred messaging platform, allowing for convenient and secure communication between you and our team.
• Microsoft Outlook Email: Microsoft Outlook Email serves as a dependable email communication tool for our team, ensuring prompt and secure communication with our clients.

It's imperative to highlight that while these third-party service providers have access to certain personal information necessary for performing their services, they are obligated to maintain the confidentiality and security of your information and are strictly prohibited from using it for any other purpose.

We are not responsible for the actions or omissions of third-party service providers with regard to the data they manage. We cannot be held liable for any damages, claims, or other liabilities arising from any unauthorized access or use, data breaches, or other security incidents involving these third-party service providers. We encourage you to acquaint yourself with the privacy policies of these third-party services to have a comprehensive understanding of how your data is handled outside the direct purview of Vivendi Health. Nonetheless, we remain dedicated to enforcing stringent data protection standards in all collaborative engagements to safeguard your privacy and ensure a seamless service experience.

THIRD PARTY LINKS

Our Platforms may contain links to external websites, platforms, or other resources provided and maintained by third parties (“Third Party Links”). These Third Party Links are provided for your convenience and informational purposes only, and do not signify endorsement, authorization, or affiliation by Vivendi Health, LLC with respect to the content, services, or products provided on or through these third-party platforms.

No Control Over Third Party Links: Please be aware that Vivendi Health, LLC does not exercise control over the content, privacy policies, or practices of these third-party platforms. The inclusion of any Third Party Links on our Platforms does not imply any warranty, endorsement, or representation regarding the accuracy, efficacy, security, or authenticity of the information and resources provided on such third-party platforms.

Privacy and Data Security Risks: Engaging with Third Party Links may expose you to privacy and data security risks, as these external platforms may have privacy policies and data handling practices that differ significantly from ours. We strongly advise reviewing the privacy policies, terms of use, and other relevant documentation of any third-party platform you choose to visit via the Third Party Links provided on our Platforms.

Disclaimer of Liability: Vivendi Health disclaims any liability for any harm, loss, or damages of any kind incurred as a result of your use of or reliance on the content, goods, or services available on or through such third-party platforms. Your use of Third Party Links and interactions with third-party platforms are solely at your own risk.

User Awareness: We encourage our users to exercise caution and to be fully aware of the potential risks when engaging with third-party platforms through the Third Party Links provided on our Platforms.

Notification: If you find any Third Party Links on our Platforms that you believe to be objectionable or harmful, please notify us immediately using the contact details provided in the "Contact Us" section below, and we will take the necessary actions to address your concerns.

DATA RETENTION

At Vivendi Health, we are committed to retaining your personal and health-related information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Retention Period: The duration for which we retain your personal information will depend on the nature of the services provided, the type of information, and the purposes for which the information is processed. We maintain a data retention policy which we apply to the information in our care, guided by applicable legal and regulatory requirements.

Data Minimization: We adhere to the principles of data minimization and storage limitation, ensuring that your personal information is adequately, relevantly, and limitedly stored with regard to the purposes for which they are processed.

Retention for Legal and Regulatory Compliance: There may be legal and regulatory requirements necessitating the retention of certain personal information for specified periods. In such cases, we will retain the information in strict accordance with these requirements.

Retention Approach: We grasp the intrinsic value and significance of the data you entrust us with. Thus, unless prompted by you, we opt to retain the data shared with us. Should you decide to discontinue as a Vivendi client, we inherently preserve your profile for two pivotal reasons: (1) Retaining your data enables sustained access to your personalized chatbot, ensuring uninterrupted services even if our professional ties are paused, and (2) Experience shows that clients, after a hiatus, often reinitiate their association with Vivendi. By preserving profiles, we ensure a seamless resumption. However, if a holistic profile deletion is on your agenda, kindly direct an email to us, expressly requesting the removal of your personal health data from our archives.

Your rights with respect to your personal information, including the right to access, correction, deletion, or transfer, are detailed in the “User Rights” section of this Privacy Policy. If you have any concerns or inquiries regarding our data retention practices, we encourage you to reach out to us via the contact details provided in the "Contact Us" section below.

CHILDREN’S PRIVACY

Vivendi Health takes the privacy and protection of children's information very seriously. Our Platforms and services are not directed towards, nor intended for use by, individuals under the age of 18. We do not knowingly collect, use, or disclose personal information from children under the age of 18 without obtaining the requisite consent from their parent or guardian as required by law.

No Deliberate Collection: Vivendi Health, LLC does not deliberately solicit or collect personal information from individuals under the age of 18. If we discover that we have inadvertently collected personal information from a child under 18, we will take prompt action to delete such information from our records.

Parental Consent: In situations where it becomes necessary to collect personal information from children under the age of 18, we will ensure to obtain verifiable parental or guardian consent as stipulated by applicable laws and regulations.

Notification and Verification: Parents or guardians will be notified and required to provide consent prior to the collection, use, or disclosure of their child's personal information.

Parental Access and Control: Parents or guardians who have provided consent for the collection of their child's personal information may review, modify, or request the deletion of such information at any time. Furthermore, they can refuse further collection or use of their child's information by contacting us.

If you believe that we might have collected personal information from a child under 18 without proper consent, we urge you to contact us immediately using the contact information provided in the "Contact Us" section below.

COOKIES AND WEB BEACONS

At Vivendi Health, we prioritize creating a streamlined and user-friendly digital experience for our clients. Part of achieving this objective involves utilizing cookies and web beacons on our digital platforms, which are managed through Super. These technologies play a crucial role in enhancing the functionality and performance of our platforms, making your interaction with our services more personalized and efficient.

Definition: Cookies are small text files that are placed on your device by websites that you visit. They are used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Similarly, web beacons are small graphic images or other web programming code (also known as "1x1 GIFs" or "clear GIFs") that may be included in our web pages and messages.

Utilization: The utilization of cookies and web beacons facilitates a tailored experience by remembering your preferences, improving your navigation, and tracking your website usage to enhance our service delivery.

Control: You have the ability to manage and control the use of cookies on your device. However, please note that if you choose to block or delete cookies, this may affect the functionality and your use of our website.

Third-Party Cookies: Our digital platforms, built on Super, may include third-party cookies, which are cookies set by parties other than Vivendi Health. You may refer to Super’s Privacy Policy for a detailed description of how cookies are utilized and how you can manage them.

Policy Reference: For an in-depth understanding of how cookies and web beacons are utilized on our platforms, and how you can manage your preferences, we recommend reviewing the Cookie Policy section within Super’s Privacy Policy, available here.

Your Consent: By using our digital platforms, you consent to the use of cookies and web beacons as described herein and within Super’s Privacy Policy.

BREACH NOTIFICATION

In the unfortunate event of a data breach that compromises your personal information, we are committed to notifying you and the relevant authorities promptly, in accordance with the applicable legal and regulatory requirements.

Notification Procedures: In the event of a data breach that results in a risk to your rights and freedoms, we will notify you without undue delay and, where feasible, within 72 hours of becoming aware of the breach. Our notification will include pertinent information about the nature of the breach, the data involved, the likely consequences, and the measures we have taken or propose to take to address the breach and mitigate its possible adverse effects.

Communication Channels: We may communicate breach notifications through email, telephone, or any other contact information you have provided to us. We may also publicize a notice on our website or through other public communication channels if necessary, to ensure you are well informed.

Engagement with Authorities: We will also report data breaches to the relevant supervisory authorities in line with legal obligations, providing all necessary information and cooperating fully to ensure the mitigation and prevention of any similar occurrences in the future.

Preventative Measures: Post-breach, we will conduct a thorough investigation to understand the cause and take all necessary steps to bolster our security measures, minimizing the chances of future breaches.

Your Responsibilities: We also encourage you to engage in safeguarding your data by using strong, unique passwords, and exercising caution when sharing sensitive information, to contribute to the overall security of your data.

Records of Breaches: We will document any data breaches, including the facts relating to the breach, its effects, and the remedial action taken, ensuring a robust trail of accountability and continual learning from such incidents.

Feedback Loop: We value your feedback and would appreciate any concerns or suggestions on improving our data security measures. Engaging with us will only augment our joint efforts in maintaining a secure and trustworthy environment.

CALIFORNIA CONSUMER PRIVACY ACT

If you are a resident of California, you may have additional rights under the California Consumer Privacy Act (CCPA) concerning your personal information.

Information Disclosure: Upon a verifiable consumer request, and to the extent required by law or within our operational constraints, we may provide information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which such information is collected, the business or commercial purpose for collecting such information, and the categories of third parties with whom we share this information.

Deletion Rights: You retain the right to request the deletion of your personal information held by us. We will endeavor to process such requests in a timely manner, subject to legal and operational considerations.

Third-Party Disclosures: If applicable, we will provide information regarding any third-party disclosures, including the categories of personal information disclosed to third parties and the business purpose of such disclosure, in adherence to the legal frameworks.

Contact for CCPA Inquiries: For any inquiries or concerns regarding your California privacy rights, you are encouraged to contact us using the contact details provided in the "Contact Us" section below.

Updates: We may update this CCPA provision to reflect any changes in our practices, operational necessities, or legal requirements. Any updates will be communicated through this Privacy Policy, and we encourage you to review this section periodically to stay informed on our adherence to the CCPA and other privacy-related frameworks.

USER RIGHTS

We prioritize your privacy and are committed to ensuring that you have clarity and control over your personal information. Below outlines the rights you may have concerning your personal information, pursuant to applicable laws and regulations:

Access: You have the right to request access to the personal information we hold about you. Upon a verified request, we will furnish you with a copy of your personal information within legal and operational constraints.

Rectification: Should the personal information we hold about you be inaccurate or incomplete, you have the right to request its correction or completion.

Deletion: You may request the deletion of your personal information under specific circumstances, which we will honor to the extent required by law and operational feasibility.

Restriction and Objection: You may have the right to request the restriction of processing or to object to the processing of your personal information under particular circumstances.

Consent Withdrawal: If processing is based on your consent, you may withdraw it at any time, without affecting the legality of processing based on consent before its withdrawal.

To exercise any of these rights, or if you have inquiries regarding your rights, please contact us using the information provided in the "Contact Us" section below. We may require verification of your identity before acting on your request. We aim to respond to all legitimate requests within one month, although complex or numerous requests may require more time. We will notify you if this is the case.

AMENDMENTS

Vivendi Health reserves the right to amend, alter, or update this Privacy Policy at any time to reflect changes in legal frameworks, regulatory requirements, or operational practices. Such amendments shall be effective immediately upon the posting of the updated Privacy Policy on our Platforms.

We commit to communicating any significant changes to this Privacy Policy through the email address you have provided us or by placing a prominent notice on our Platforms. We may also summarize the changes at the beginning of the Privacy Policy for your convenience, providing a clear and accessible summary of the substantial amendments.

We strongly encourage you to review this Privacy Policy periodically to stay informed about how we are protecting and managing your personal information. Your continued use of our services following the posting of changes to this Privacy Policy will constitute your acceptance of any and all amendments.

Should you have any concerns or objections to any amendments made to this Privacy Policy, you reserve the right to discontinue the use of our services and Platforms.

The date of the last amendment to this Privacy Policy will be indicated at the top of this page, providing a clear reference to the Policy’s latest version.

CONTACT US.

Your privacy is of utmost importance to us at Vivendi Health, LLC. Should you have any questions, concerns, or comments regarding this Privacy Policy, or if you wish to exercise any of your rights outlined herein, we invite you to get in touch with us through the following channels:

• Email Address: privacy@vivendihealth.com

We are committed to addressing your inquiries with professionalism and diligence. We aim to respond to all communications in a timely manner, striving for a response within 48 to 72 hours during our regular business hours, Monday through Friday, 9:00 AM to 5:00 PM EST.

Please note, for the protection of your privacy and security, we may need to verify your identity before responding to your requests, to ensure a secure and confidential communication.

We look forward to assisting you and appreciate your trust in Vivendi Health, LLC to manage your personal and health-related information with the highest level of care and professionalism.