Privacy Policy

1. Introduction

VitalCheck Wellness, Inc. (VitalCheck Wellness) operates ClearToStart, a clinical-clearance program that coordinates pre-employment, pre-placement, training, and educational health-clearance services — including tuberculosis screening, antibody titers, vaccinations, physical examinations, and drug screening — for home care agencies, healthcare staffing firms, nursing and allied-health programs, and other healthcare organizations. VitalCheck Wellness also supports the VitalCheck Doctors In Your Office program by arranging appointments at workplaces, other designated locations, and through telemedicine with physicians, physician assistants, nurse practitioners, and other licensed healthcare providers. A provider may be employed by VitalCheck Wellness where permitted by law, engaged independently, or employed by a hospital, medical practice, or clinic.

These programs are a collaboration among VitalCheck Wellness, hospitals, independent medical practices, patient service centers, and individual healthcare providers. Participating providers furnish preventive healthcare, behavioral-science services, coaching, wellness examinations, vaccinations, diagnostic testing, occupational and educational health-clearance screening, and related services. VitalCheck Wellness provides administrative services and proprietary technology to each program and may act as a business associate under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) for participating healthcare providers.

VitalCheck Wellness also manages and transmits health-history forms, screening results, and other health-related information to participating providers, program sponsors, and individuals through its patient portal and agency dashboards. It provides access to its proprietary technology platform and related websites — including cleartostart.com, vitalcheckwellness.com, and the patient portal at ehr.getvitalcheck.com — mobile applications, services, and tools (collectively, the Services).

This Privacy Policy explains how VitalCheck Wellness collects, uses, stores, and shares information through Services that display or reference this policy. It does not govern third-party websites or digital services, including those of business partners, even when they are accessible through the Services. Those third parties maintain their own privacy practices.

By using the Services, you acknowledge the practices described in this Privacy Policy and consent to the collection, use, and sharing of information as described here. If you use the Services for another person or an organization, you represent that you are authorized to accept this policy on that person's or organization's behalf.

2. Information We Collect

2.1 Personal Information

Some Services require information that identifies you or could reasonably be used to identify you. The categories may include:

• · Contact information, including name, email address, postal address, and telephone number.
• · Demographic information, including date of birth, gender, and ZIP code.
• · Insurance information, including carrier, plan, member, group, and payer identifiers.
• · Medical and health information, including providers visited, reasons for visits, appointment dates, medical history, test information, and information you choose to share.
• · Account and identity information, including usernames, passwords, Social Security number when required, and other unique identifiers.
• · Information included in messages, forms, surveys, questionnaires, emails, and letters you submit to us.

You may use portions of the Services without providing all requested information. Features that depend on particular information may be unavailable if you do not provide it.

2.2 Billing, Collection, and Payment Information

When VitalCheck Wellness processes an insurance claim or payment on behalf of a healthcare provider, VitalCheck Wellness or an appointed payment-processing partner may collect insurance, billing, and payment information. A payment processor's handling of information is also governed by its own terms and privacy policy.

2.3 Traffic and Device Data

When you use the Services, we may automatically collect technical and usage information such as IP address, domain server, device type, browser, operating system, referring source, approximate geolocation, pages viewed, interaction data, and related statistics. Depending on applicable law, some of this information may be treated as personal information.

2.4 HIPAA and Protected Health Information

Certain identifiable demographic, health, and health-related information collected in connection with healthcare services may be protected health information (PHI) under HIPAA. This includes information VitalCheck Wellness receives from or for a healthcare provider that has furnished healthcare services to you.

When VitalCheck Wellness acts as a healthcare provider's business associate, it may use and disclose PHI only as permitted by the applicable provider agreement, HIPAA, other applicable law, and any authorization or consent you sign. If a consent, treatment authorization, insurance authorization, or other program-specific document conflicts with this policy regarding PHI, the program-specific document controls for that PHI.

3. How We Collect Information

We collect information when you interact with the Services and, where permitted, from participating providers, employers or program sponsors, insurers, laboratories, and other third parties. Collection may occur when you:

• · Create or update an account or profile.
• · Schedule an appointment and complete medical-history, consent, or authorization forms.
• · Use interactive tools, communications, telemedicine, or patient-portal functions.
• · Provide information in free-form text fields, surveys, questionnaires, or support requests.
• · Use a mobile application or permit device-based functions such as notifications or location services.
• · Visit a website or application that uses cookies, analytics, web beacons, logs, or similar technology.
• · Contact us by email, telephone, web form, or another channel.

4. Tracking Tools and Browser Choices

4.1 Cookies, Analytics, and Similar Technology

The Services may use cookies, web beacons, log files, analytics tools, mobile-device identifiers, and similar technologies to maintain sessions, remember preferences, support authentication, prevent fraud, understand use of the Services, and improve performance. Website analytics may measure visits, pages viewed, referring sites, clicks, scrolling, and related interaction data. Analytics used on public website pages are not intended to include patient data.

Third-party analytics and advertising partners may place or read their own cookies or identifiers, subject to their policies. Where interest-based advertising is used, partners may use information about online activity to select advertising. VitalCheck Wellness does not authorize partners to use PHI for behavioral advertising.

4.2 Cookie and Mobile Choices

Most browsers and mobile devices allow you to restrict cookies, identifiers, or location access. Blocking these technologies may prevent some Services from functioning. Industry opt-out tools may limit certain interest-based advertising but do not stop all collection necessary for security, analytics, or operation of the Services.

4.3 Do Not Track

Because there is no uniform industry standard for browser Do Not Track signals, the Services may not respond to every such signal. We will honor legally required browser-based preference signals where applicable.

5. How We Use Information

We may use personal information to:

• · Provide, operate, administer, maintain, and improve the Services and the program.
• · Arrange appointments, transmit forms and records, support clinical workflows, and communicate with participating providers.
• · Verify insurance information, support claims and payments, and respond to billing questions.
• · Respond to requests, correspondence, questions, complaints, and support needs.
• · Send appointment reminders, account notices, service messages, and information you request.
• · Customize the user experience and, where permitted, provide information about VitalCheck Wellness services.
• · Combine information received from permitted third parties with information already maintained about you.
• · Conduct analytics, quality improvement, fraud prevention, security monitoring, and investigations.
• · Comply with law, legal process, professional obligations, and contractual requirements.

Information that is not personal information or PHI, including information that has been de-identified or aggregated in accordance with applicable law, may be used for analytics, quality improvement, service development, and other lawful purposes.

6. How We Disclose Information

We may disclose information as follows:

• · To the healthcare providers involved in your appointment, care, testing, or requested service.
• · To other healthcare providers or health-information organizations when you request or authorize a referral, exchange, or coordination activity, or when otherwise permitted by law.
• · In an emergency when disclosure is permitted or required to protect health or safety.
• · To service providers that perform hosting, communications, billing, payment, insurance verification, analytics, data storage, security, customer support, and other operational functions for us under appropriate obligations.
• · To insurers and benefit administrators for eligibility, benefits, claims, payment, and cost-sharing activities.
• · To a successor or potential successor in connection with a merger, acquisition, financing, reorganization, sale of assets, or other change of ownership, subject to applicable law.
• · When required by law, regulation, subpoena, court order, or legal process; to protect rights, property, health, or safety; to investigate fraud or security events; or to enforce agreements.

VitalCheck Wellness does not sell email addresses. We do not sell PHI. We may share non-PHI contact information with vendors or partners only for authorized operational or communication purposes and subject to applicable law.

Information is stored and processed on systems located in the United States and is subject to applicable United States law.

7. Public Information

Information you intentionally post in a public review, discussion, or forum may be visible to and collected by others. Do not disclose personal or medical information in a public area unless you intend it to be public.

8. Storage and Security

We use administrative, technical, and physical safeguards designed to protect personal information during transmission and storage. These safeguards may include encryption, access controls, monitoring, backups, and workforce and vendor requirements. No system can guarantee absolute security.

If we learn of an incident involving personal information, we will investigate and provide any notice required by applicable law and contractual obligations.

9. Your Information and Account Choices

Registered users may be able to review or update profile information through their accounts. To request access, correction, deletion, or account closure, contact us using the information below. We may verify your identity before completing a request and may retain information when required for healthcare records, legal compliance, fraud prevention, dispute resolution, audit, security, or enforcement purposes.

Notify us promptly if account credentials or devices are lost, stolen, or used without authorization.

10. Links to Other Websites

The Services may link to websites and services that VitalCheck Wellness does not control. A link does not constitute endorsement of that third party's privacy or security practices. Review the third party's policies before providing information.

11. California Privacy Rights

This section supplements the rest of this Privacy Policy and applies only to California residents, as required by the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA).

Much of the health information VitalCheck Wellness collects and uses in connection with clinical-clearance and wellness services is protected health information (PHI) governed by HIPAA and, where applicable, California's Confidentiality of Medical Information Act. The CCPA does not apply to that PHI; the Notice of Privacy Practices, not this section, describes how that information is used and disclosed and the rights that apply to it. This section addresses other personal information VitalCheck Wellness collects, such as website and account information, business and agency contact information, and billing information that is not PHI.

Categories of Personal Information

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA: identifiers (such as name, email address, postal address, telephone number, account username, and IP address); customer records information (such as insurance, billing, and payment details); commercial information (such as services requested and appointment history); internet or other electronic network activity information (such as the browsing and interaction data described in Section 2.3); geolocation information (approximate, derived from IP address); professional or employment-related information (for agency and provider contacts); and inferences drawn from the categories above. Some of the health and medical information described in Section 2 is sensitive personal information under the CCPA but, to the extent it is PHI, is addressed by the Notice of Privacy Practices rather than this section.

Sources, Purposes, and Disclosures

The sources, business and commercial purposes, and categories of third parties to whom personal information is disclosed are described in Sections 3, 5, and 6 of this Privacy Policy, which apply equally to this section.

Sale or Sharing of Personal Information

VitalCheck Wellness does not sell personal information for money. As described in Section 4.1, some public website pages may use third-party analytics or advertising technology that the CCPA could treat as "sharing" identifiers and internet-activity information for cross-context behavioral advertising. You may opt out of any such sharing, and of any future sale, on our Your Privacy Choices page or using the methods described below. We honor the Global Privacy Control and other opt-out preference signals recognized under California law as a valid request to opt out of sale and sharing.

Retention

We retain each category of personal information for as long as necessary to provide the Services, complete a requested clearance or program file, fulfill the purposes described in Section 5, and satisfy applicable legal, tax, accounting, and healthcare recordkeeping obligations, after which it is deleted or de-identified in accordance with our records-retention procedures.

Your California Privacy Rights

Subject to certain exceptions, you have the right to:

• · Know the specific pieces and categories of personal information we have collected about you, the sources, the purposes, and the categories of third parties with whom it has been disclosed, sold, or shared.
• · Delete personal information we have collected from you.
• · Correct inaccurate personal information we maintain about you.
• · Opt out of the sale or sharing of your personal information.
• · Limit the use and disclosure of sensitive personal information to the purposes permitted by the CCPA.
• · Not be discriminated against for exercising any of these rights.

To exercise these rights, contact us at privacy.office@getvitalcheck.com or (800) 828-0730. We will verify your identity before responding, using information already on file with us or, if necessary, additional identifying details. You may designate an authorized agent to make a request on your behalf; we may require proof of the agent's authorization and, for certain requests, that you verify your own identity directly with us. We will respond within the time required by law.

We do not knowingly sell or share the personal information of consumers we know to be under 16 years of age.

California's "Shine the Light" law (Civil Code Section 1798.83) permits California residents to request certain information about disclosures of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes. If this changes, we will update this Policy and provide the disclosure Shine the Light requires.

12. Changes and Contact Information

We may update this Privacy Policy. The revised version will be posted with a new effective or revision date. When required, we will provide additional notice of material changes. Continued use of the Services after an applicable effective date constitutes acknowledgment of the revised policy to the extent permitted by law.

Questions or privacy requests may be directed to:

VitalCheck Wellness, Inc.
Attn: Privacy Office and Compliance
241 West 37th Street, Suite 402
New York, New York 10018
Email: privacy.office@getvitalcheck.com
Telephone: (800) 828-0730

Also see: Notice of Privacy Practices · Terms of Use