Privacy Policy

Scope and Purpose

This Privacy Policy describes the ways in which Vibrant, LTD (“we,” “our,” or “us”), collects, uses, and discloses information about you through our website https://vibrantgastro.com and in association with your acquisition, interaction with, and use of the Vibrant device (“Pod”) and its application (collectively, “the Services”). By using, acquiring, or interacting with the Services, you consent to the processing of your information as set forth in this Privacy Policy, now and as amended by us.

Vibrant also performs certain services and offers certain technology to health care providers. Patient information shared with Vibrant by these health care providers or received by Vibrant on their behalf will be used and disclosed consistent with the Health Insurance Portability and Accountability Act and our contracts with those providers and is not subject to this Privacy Policy.

What Information Do We Collect?

 Information You Provide – We collect any information that you provide via or in association with the Services. This includes information that you provide when: creating an account linked to your name and/or contact information (“Account”); contacting us with questions, comments or requests; or when requesting information from our website or other platforms. The information you provide us may include, but is not limited to:

• identifiers such as your name, physical address, email address, phone number, username, password, and other registration information;
• health-related information, such as health care provider details, insurance carrier, insurance policy and group numbers; clinical information you provide, Treatment adherence, and Provider communication messages;
• financial information, such as payment information;
• voice recordings, when you contact our customer care team; and
• demographic information, such as your age and gender.

Information We Collect Automatically – We automatically collect certain information from your computer, mobile device, or Pod when you use them in association with the Services. We collect this information via web logs and, as described further below, via web cookies and similar technologies. The information we collect automatically includes:

• identifiers such as your IP address, device identifiers, and network identifiers;
• internet and network-related information, such as content viewed, account logins, session times, features used, device type, browser type, network events, and interactions with emails, digital ads, and other electronic communications; and
• geolocation information as inferred from IP address or network connection information.
  • Precise Real-Time Location Information – The Services may, with your permission, access precise device location. The information may be uploaded to the company’s servers, the service provider’s servers, or it may be stored on your device. We use this information to provide you with certain features while improving and customizing our offerings. You can enable or disable access to this information at any time through your device settings. We do not collect precise location information via the Pod, but we collect general location information from the Pod to infer the time zone you are in.

Information Obtained from Third Parties – We and our service providers may collect information about you from third-party sources. We may obtain health- related information from your health care provider, your pharmacy, insurance companies, and pharmacy benefit managers (collectively, “Providers”). And we may obtain demographics, online identifiers, and information about your interests from data supplementation services and social media platforms.

Information Obtained through Apple Health – With your consent, our app may collect certain information, including step count data, from the Apple Health application. This data is securely stored in our cloud to help visualize your individual progress and for analytics purposes aimed at enhancing your treatment. We will use such data solely to provide you with personalized health insights and improve overall treatment strategies. These strategies may include analytics of combined patients’ data, which can be correlated with other clinical information collected by our Service. Please note that your use of Apple Health is subject to your acceptance of the Apple Health terms and conditions.

We may combine any of the information we collect. And we may use the information we collect to make inferences about your interests, preferences, or characteristics. We may alter the information we collect so that it no longer reasonably identifies you and use it for any purpose.

How Do We Use This Information?

We use the information we collect for a number of purposes, including, but not limited to:

• providing you with information about the Services and your use of them;
• operating the Services and our business, including providing you with the features available through the Services;
• communicating with you about the Services and in response to your inquiries;
• managing your Account;
• delivering marketing communications, promotional materials, and advertisements to you, including materials that we believe may be of interest to you based on your online activities (see the Cookies and Other Tracking Technologies section for additional information);
• maintaining the security of the Services, your information, and our business;
• conducting analytics to identify usage trends, assess and improve treatment methods, develop new treatments, improve the Services, assess the effectiveness of our marketing efforts, and improve your experience; and
• protecting our rights and the rights of others.

How Do We Share Information?

We disclose the information we collect as follows:

• For Treatment Purposes: We disclose information to Providers to help them provide and manage your treatment plan.
• To Third-Party Service Providers: We may engage other companies and individuals to perform certain business functions on our behalf. Examples include providing data hosting services, application development services, communication services, analytics services, and customer service These service providers may have access to information that we collect in order to perform services on our behalf.
• To Comply with Law or Legal Process: We may disclose information in order to comply with our legal obligations or as we deem reasonably necessary to address legal requests, such as to comply with a subpoena or other legal process, or to comply with government reporting obligations.
• To Protect Our Rights: We may disclose the information we collect to enforce or apply our Terms and other agreements; or protect the rights, property, or safety of our business, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit-risk reduction.
• In Connection with a Transaction: We may share or transfer your personal information in connection with an actual or contemplated merger, sale of our assets, financing, or acquisition of all or a portion of our business to another entity.
• With Your Consent: We may disclose your personal information for any other purpose with your consent.

Cookies and Other Tracking Technologies

With the exception of certain features of our online Services that may reveal sensitive financial or health-related information, Vibrant, our service providers, and certain third party advertising companies collect information about you and your devices using web cookies, tracking pixels, web beacons and other technologies (collectively, “Cookies”). Some third parties may collect information about you and your devices over time and across our and third- party websites and applications. We use the information to better understand how users interact with our online Services, to customize and improve user experiences with our online Services, and to deliver advertising based on inferences we and others make about your interests. Those ads may include ads for our products and services or for other companies’ products and services.

If you would like more information about such interest-based advertising or would like to opt-out of receiving interest-based advertising, visit the choices page offered by the Digital Advertising Alliance (“DAA”).

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie- enabled will not recognize you when you return to the website, and some website functionality may be lost.

We use Google Analytics, which uses Cookies to collect and analyze information about use of the online Services and report on activities and trends. Google Analytics may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Social media plugins and data: In addition, our online Services may use social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. When you visit the online Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. The social plugins also allow the social media website to share information about your activities on Vibrant with other users of their social media website. Vibrant does not control any of the content from the social plugins. For more information about social plugins from other social media websites, you should refer to those sites’ privacy and data sharing statements.

By visiting and/or using the online Services, you agree that we are not responsible for any acts or omissions by these social media service providers.

Do Not Track Policy: We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy.

Retention of Your Personal Information

We retain personal information for as long as reasonably necessary to achieve the purposes disclosed at the point of collection or in this Privacy Policy.

Information Security

We implement administrative, technical, and physical safeguards designed to safeguard the information we collect. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to and from the online Services over networks that we do not control, including the Internet and wireless networks.

Your California Privacy Rights (California’s Shine the Light law)

If you reside in California and have provided us information that identifies you, you may be entitled to request information once per calendar year about our disclosures of certain categories of certain information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing at the following address: [email protected].

Third Party Sites

We may provide links to websites and other third-party content that is not owned or operated by Vibrant. The websites and third-party content to which we link may have separate privacy notices or policies. Vibrant is not responsible for the privacy practices of any entity that it does not own or control.

If you provide any personal information through a third-party site, your interaction and your personal information will be collected by, and controlled by the privacy policy of, that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

Changes to this Privacy Policy

This Privacy Policy was last updated on June 4, 2024

If we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page and updating the date above. If we make any revisions that materially change the ways in which we use or share the information previously collected from you, we may give you the opportunity to consent to such changes before applying them to that information.

Contact Us

If you have any questions about this Privacy Policy or our use of your information, please contact us at [email protected]