Teladoc Health Engagement Center Privacy Policy

Last updated: August 1, 2024

Introduction

Teladoc Health, Inc., on its own behalf and its affiliates and/or wholly owned subsidiaries including but not limited to Livongo Health, Inc., myStrength, Inc., Best Doctors, Inc., HealthiestYou, Inc., Advance Medical, Inc., InTouch Technologies, and Teladoc Health Medical Group, P.A. (collectively referred to as "Teladoc", "we", "us", or "our"), provides Clients (“Clients”) with access to self-serve marketing materials and tools through the Engagement Center (“Engagement Center”).

This Privacy Policy applies to visitors of engagementcenter.com and campaigncreator.com ("Website"). For the purposes of this Disclaimer, "you" and "your" means you as the visitor of the Website.

Scope of this Web and Mobile Privacy Policy

This Privacy Policy describes the types of Personal Information we collect from visitors of the Website. Additionally, this Privacy Policy provides our practices for using, maintaining, sharing, and protecting it. Lastly, it describes the rights and choices you may have with respect to your Personal Information and how you may contact us.

This Privacy Policy does not apply to information collected from visitors of Teladoc Health’s member-specific public and authenticated websites including but not limited to, login pages and registration pages, such as teladochealth.com,member.teladoc.com/signin, or livongo.com.

California and Virginia residents should read the information available in Section 9 below about the categories of personal information to be collected from them and the purposes for which the personal information will be used.

This Privacy Policy is not a contract and does not create any contractual rights or obligations.

 

1. TYPES OF PERSONAL INFORMATION

While using our Website, you may provide us with certain information about you.

We may automatically collect information using cookies and other tracking technologies (see below).

Personal Information that we collect through your use of the Website may include IP Address and User ID. We may use that Personal Information and link it to Internet or other electronic network activity information to provide the Website services. You may also provide member names, addresses, phone numbers, and emails only if you wish to use certain Website services such as member marketing mailers or member marketing emails.

2. HOW WE COLLECT PERSONAL INFORMATION

We may collect Personal Information using the following methods:

  • Directly from you when you provide it to us (such as information you enter during registration).
  • From third parties, such as analytics tools.
  • Automatically through tracking technologies such as cookies, pixels, and log files, including over time and across our own and third-party websites or other online services.

"Cookies" are small files that a website stores on a user's computer or device. The Website may use cookies for various purposes, including to keep the information you enter on multiple pages together. Some of the cookies we use are "session" cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Websites and to limit the amount of redundant data that is downloaded during a single session. We also may use "persistent" cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our services. We and third parties may use session and persistent cookies for analytics purposes, as described herein. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies (see below). As required under applicable laws, we will obtain your consent necessary for utilizing cookies or similar tracking technologies.

Our Website may use Google Analytics, a vendor's service that uses cookies, web beacons, web pixels and/or similar technology to collect and store information about your use of the Website. You can learn more about Google Analytics' privacy policy and ways to opt out from Google Analytics tracking by visiting Google Analytics' website.

For more information about how we use Personal Information and the ways you may be able to manage it, see below.

3. HOW WE USE YOUR INFORMATION

We may use your Personal Information for the following purposes:

  • Operate, maintain, supervise, administer, and enhance the Website, including monitoring and analyzing the use of content on the Website.
  • To complete the activity you specifically asked for, e.g., developing marketing material.
  • Aggregate information for analytics and reporting.
  • Respond to law enforcement requests and court orders and legal process and carry out our legal and contractual obligations and enforce our rights.
  • Authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Websites and safety of users.
  • Develop, test, improve, and demonstrate the Website.
  • Any other purpose with your consent.

4. HOW WE SHARE YOUR INFORMATION

We may share Personal Information with third parties and service providers in certain circumstances or for certain purposes, including:

  • For business purposes. We may share your Personal Information with vendors and service providers, including our data hosting and data storage partners, analytics providers, technology services and support, and data security. We also may share Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
  • With affiliates within our corporate group. We may share your Personal Information with any subsidiaries or affiliates within our corporate group.
  • Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
  • In the context of a transaction. We may share your Personal Information in connection with an asset sale, merger, bankruptcy, or other business transaction.
  • For other business reasons. We may share your Personal Information to enforce any applicable Legal Disclaimer, and to ensure the safety and security of the Websites and/or our users.

 

We also may disclose deidentified information. Note that if you make any Personal Information publicly available on the Websites, anyone may see and use such information.

5. COOKIES AND INFORMATION USED FOR ADVERTISING

The information our Website may collect is not used to advertise or market to you. The Website’s tracking technology are used solely to administer the website and its functions, and provide analytics on how the Website is used and can be improved. 

Teladoc Health maintains a cookie preference center which allows you to customize your cookie preferences when visiting the Website.

If you have further questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

6. SECURITY OF PERSONAL INFORMATION

We take steps to secure Personal Information through administrative, technical, and physical safeguards designed to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.

7. RETENTION OF PERSONAL INFORMATION

We generally retain records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements. When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature, and sensitivity of the Personal Information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements.

·       User accounts without activity for 90 days will become void. Users will have to reach out to Teladoc to regain access.

·       Member lists are one-time use only. Users cannot re-access member lists after they’ve been uploaded and used once.

Because we maintain our Website to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or put beyond use where deletion is not possible.

8. INTERNATIONAL USERS

The Website is controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of our Website may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal data as the one in which you reside. However, we will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored/accessed.

9. NOTICE TO CALIFORNIA AND VIRGINIA RESIDENTS

If you are a California resident, certain Personal Information that we collect about you is subject to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

If you are a Virginia resident, certain Personal Information that we collect about you is subject to the Virginia Consumer Data Protection Act (VCDPA).

Please note that these laws may not apply to, among other things,

  • Information that is lawfully made available from federal, state, or local government records;
    • Consumer information that is deidentified or aggregated;
    • Protected health information that is collected by a covered entity or business associate governed by HIPAA; or
  • Medical information maintained by a provider of health care governed by California's Confidentiality of Medical Information Act (CMIA).

Collection of Personal Information

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household—this type of information is referred to as “Personal Information,” and includes personal information as defined by CCPA/CPRA as well as personal data as defined by the VCDPA.

Personal Information does not include de-identified or aggregate information; publicly available information that is lawfully made available from federal, state, or local government records; and information covered by certain sector-specific privacy laws. Teladoc collects the following categories of Personal Information about consumers (and to the extent such Personal Information is subject to the CCPA/CPRA, these categories were collected in the preceding 12 months):

  • Identifiers, Internet Protocol (IP) address, user ID, device identifier. We may collect your name, email address, phone number, and address only if you provided it to us via a form on the Website.
  • Commercial information, business contact information if you have provided it to us via a form on the Website, including name, company name, email address, telephone, and job title.

 

Teladoc does not collect or share Personal Information on the Websites from any person we know to be under the age of 16.

Teladoc does not collect Sensitive Personal Information, as those terms are defined under the CCPA/CPRA and the VCDPA, of consumers who visit our public Website.

Teladoc collects Personal Information from the following categories of sources:

  • Directly and indirectly from you, including through your interaction with the Website
  • Automatically through tracking technologies. Please note, if you have enabled a Global Privacy Control on your browser, our Website is configured to recognize and respect those preferences with respect to Personal Information that falls under the CCPA/CPRA. See Section 2 for additional detail.

We may use your Personal Information for the following purposes:

  • Operate, maintain, supervise, administer, and enhance the Website, including monitoring and analyzing the use of content on the Website.
  • To complete the activity you specifically asked for, e.g., developing marketing material.
  • Aggregate information for analytics and reporting.
  • Respond to law enforcement requests and court orders and legal process and carry out our legal and contractual obligations and enforce our rights.
  • Authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Websites and safety of users.
  • Develop, test, improve, and demonstrate the Website.
  • Any other purpose with your consent.

Teladoc will retain and/or archive Personal Information for a period of time no longer than required by applicable law or no longer than is necessary and proportionate to achieve purposes compatible with the context in which the Personal Information is collected. Teladoc will not further process Personal Information in a manner incompatible with the purposes noted above.

Disclosure of Personal Information in the Preceding 12 Months

Teladoc discloses Personal Information with the following categories of third parties and has disclosed the following categories of Personal Information for a business purpose, for commercial purpose, to comply with the law, in the context of a transaction, or for other business reasons:

Personal Information

Third Parties

Identifiers

We may disclose IP address, device ID, or online identifier to service providers, internet service providers, and/or data analytics providers. Before using analytics or targeting cookies, the Website deploys a banner seeking your consent, or opt-in to the use of such cookies.

Commercial Information

Service providers

Internet or other electronic network activity information

Service providers, internet service providers, and/or data analytics providers.

You may have the following rights regarding your Personal Information maintained by Teladoc:

  • Request to know and access the Personal Information we collect, use, and disclose;
  • Request deletion of Personal Information;
  • Request to Opt-out of the sale or sharing of Personal Information;
  • Right to Limit Use and Disclosure of Sensitive Personal Information and
  • Not receive discriminatory treatment by Teladoc for exercising these rights.

 

The rights described below are limited to those provided under the CCPA/CPRA and VCDPA to the applicable residents of those states. The specific rights may vary based on whether the CCPA/CPRA or VCDPA applies, and should you have any questions regarding your rights, please contact us as per the information in Section 14.

Requests to Know and Access

You may have the right to request that we disclose to you the following information:

  • Categories of Personal Information that Teladoc has collected about you, disclosed about you for a business purpose, or sold or shared;
  • Categories of sources from which the Personal Information is collected;
  • Categories of third parties with whom Teladoc shares or to whom Teladoc sells Personal Information;
  • The business or commercial purpose for collecting and selling Personal Information; and
  • Specific pieces of Personal Information that Teladoc has collected about you.

 

Instructions for submitting a verifiable request are provided below. You may only make a request for access twice within a 12-month period.

Requests to Delete

You may have the right to request that we delete Personal Information associated with you, subject to applicable law and certain exceptions.

Instructions for submitting a verifiable request are provided below.

Request to Correct Inaccurate Personal Information

You may have the right to request that Teladoc corrects Personal Information that is inaccurate.

Instructions for submitting a verifiable request are provided below.

Requests to Opt Out of the Sale or Sharing of your Personal Information

You may have the right to submit a request to opt out of any sale or sharing of your Personal Information or the processing of your Personal Information for purposes of targeted advertising. However, Teladoc does not sell your Personal Information and does not use or share Personal Information collected from users of our public websites to engage in targeted advertising unless you have opted-in to such use. And, in the last 12 month, Teladoc has not "sold" or "shared" Personal Information (as those terms are defined under the CCPA/CPRA).

Instructions for submitting a verifiable request are provided below.

How to Exercise Your Rights

To submit a request to exercise any of your rights, please complete and submit the Webform found here. You can also call the Privacy Officer at: (855) 213-6709 (toll free).

As required under applicable law, we must take steps to verify your request before we can provide Personal Information to you, delete Personal Information, or otherwise process your request. To verify your request, we may require you to provide your name, physical address, email address, contact information, and information about your account or previous transactions with us. If you have only visited our public Websites and did not provide any Personal Information to us via a web form or through the registration process, we will need you to provide us with your IP address or device ID in order for us to determine if we have that information. We will not be able to determine if we have your IP address or device ID from your name, physical address, email address, contact information, or account information.

We will further verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as your date of birth or government identifier, in order to protect against fraudulent requests.

We will deliver Personal Information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the Personal Information to you electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information from one entity to another without hindrance.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us by the information provided in the "How to Contact Us" section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require verification of the agent's authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity.

Right to Nondiscrimination

You have the right to be free from discriminatory treatment for exercising the privacy rights conferred by applicable law, including not being: denied goods or services; charged different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provided a different level or quality of goods or services; or suggested that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

10. UPDATING THIS PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes in our privacy practices. It is your responsibility to review the Privacy Policy from time to time to view any such changes.

 

11. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at [email protected] or contact us at:

Chief Privacy Officer
Teladoc Health
5th Floor, Ste 5A,
2 Heritage Drive,
North Quincy, MA 02171S

(855) 213-6709 (toll free)