About This Policy
Value Care of Florida, LLC and its subsidiaries, divisions, and affiliates (sometimes referred to as “Value Care,” “Company,” “us,” “we,” or “our”) adopted this privacy policy (“Policy”) to describe our policies and practices concerning the personal information we collect about you through our mobile websites, mobile apps, blogs and website (collectively, “Site”). Value Care is committed to the privacy and security of the personal information we collect.
Please read this Policy carefully before using the Site or submitting personal information to us. By accessing or visiting the Site, you indicate your understanding that the collection, use, disclosure, and retention of your personal information is subject to the terms of this Policy If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this Policy, please do not provide us with such information.
This Policy does not apply to third-party websites accessible through our Site or other applications.
1. Personal Information We Collect
As described below, we may collect or have collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy
- Identifiers – such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Other elements – such as name, signature, characteristics or description, address, telephone number, education, bank account number, credit card number.
- Characteristics of protected classifications under California or federal law – such as race, religion, and age.
- Commercial information – such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Education information – such as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
- Biometric information – such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity.
- Geolocation data – such as location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information – such as identifiable information obtained about you from voicemail messages, while speaking with our service representatives, including on the telephone, and captured by video cameras.
- Professional or employment-related information – such as information on job applications, information needed during onboarding for payroll and benefits, and information needed for evaluating performance.
- Sensitive Information. Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health; and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.
2. How Long We Retain Your Personal Information
We retain your personal information for as long as necessary to provide you services/potential services and in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you.
To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements, etc.
3. Your Choices Regarding Your Personal Information
You can always limit the information you provide to us, but if you choose not to provide certain requested information, you may be unable to access or receive some of the services, offers, and information we offer through the Site.
4. Purposes We Collect and Use Personal Information
We collect and use your PI for the following business or commercial purposes. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.
- To communicate with you.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders, transactions or requests for information, verifying customer information, processing payments, providing analytics services, or providing similar services.
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
- To engage in marketing and advertising activities; contact you and/or provide you with email alerts and other notices concerning our products, services, events, or news that may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. Of course, if at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.
- To ensure your information is accurate and to personalize our communications to you. For example, we may aggregate your personal information with data from various sources for purposes of keeping information up to date. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal or share and use it as described elsewhere in this Policy.
- To carry out our obligations and enforce our rights, including those arising from any contracts entered into with you for billing, payment, and collections.
- To review, improve, and monitor our website, applications, online services, and overall consumer experience, including to provide customization to meet the specific needs.
- For testing, research, analysis and product and service development. We may use data, including public feedback and surveys, to conduct research and for the development of the Site and the services, products, and information we provide.
- To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
- As described to you when collecting your personal information.
- As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
5. Disclosures of Personal Information
We may disclose your personal information to our affiliates/owners, services providers and contractors who help us provide the products and services, such as, shipping, payment processing, marketing and advertising, email, text and other communications, applications, sales, business and inventory support, photography, and website, software, platform, cloud, data storage and other technical services, advertising and social networks and data analytics providers, professional services organizations, such as auditors and law firms, and government entities, including licensing enforcement agencies.
We may also disclose your personal information to third parties, if necessary, to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.
Lastly, we may transfer personal information to a third party as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.
We may disclose non-personally identifiable visitor information to other parties for marketing, advertising, or other uses.
Of the categories of PI noted above, during the past 12 months, we disclosed the following:
| Categories of Personal Information Disclosed
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Categories of Third Parties to Whom Disclosed
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- Identifiers
- Other elements
- Characteristics of protected classifications under California or federal law
- Commercial information
- Education information
- Internet or other electronic network activity
- Biometric information
- Geolocation data
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional or employment-related information
- Consumer profile
- Sensitive personal information
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- Third parties as directed by you. We will disclose your PI with those third parties to whom you direct.
- Our business partners. For example, we might disclose your PI with one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose PI. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
- Third parties who perform services on our behalf. For example, we disclose information with certain service providers, including marketing companies, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to disclose PI on our behalf for these purposes.
- Governmental entities, legal service providers. We may disclose your PI to comply with the law and while providing our products and services and other business activities of the Company. We may also disclose information if a government agency or investigatory body submits a request.
- Successors to all or portions of our business. If all or part of our business is sold, we may disclose PI in preparation for or as part of that transaction.
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6. Cookies, Tracking, and Certain Communications
Cookies. The Site uses cookies and similar web technologies. Some of our digital services, including the Value Care website, use Google Analytics Advertising Features and its associated tracking technologies to help display Value Care ads you see on other sites, and to help us manage and optimize our digital advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page. Website users can also access the Google Analytics Opt Out Browser Add-on.
Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. Value Care leverages its third-party digital services to process the signals. If a user enables “Do Not Track” signals to communicate their privacy preference, then the users’ browser will send the “Do Not Track” signal to Value Care’s 3rd party vendors and the websites they visit to respect their privacy rights accordingly. We track visitors over time and across third parties’ websites.
7. Third Party Website Links
Some portions of our Site may contain links to other websites on the Internet that are neither under our control nor maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that we are providing these links to you only as a convenience, and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites
8. Email and SMS Communications
We may collect your email address via cookies and pixels on the Site through the use of trusted third-party partners. These partners may combine your email information with other information they have access to such as mailing address so that we may send relevant marketing offers to you via direct mail.
You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more. These messages may use information automatically collected based on your actions while on our Sites and may prompt messaging such as cart abandon messages. To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages.
9. Our Sites and Children
We do not knowingly collect or solicit PI from children under 13 years of age. We are concerned about the safety of children when they use the Internet and will never knowingly request PI from anyone under the age of 13. If the parent or guardian of a child under 13 believes that the child has provided us with any PI, the parent or guardian of that child should contact us and ask to have this PI deleted from our files. If we otherwise obtain knowledge that we have PI about a child under 13 in our files, we will delete that information from our existing files so that it is not in retrievable form.
10. Security
We employ reasonable and appropriate administrative, physical and technical measures designed to safeguard the personal information we collect from you. However, no system for safeguarding personal or other information is 100% secure and we cannot fully eliminate security risks associated with personal information. In addition, although we use reasonable measures to protect our Site and your information, the Internet is not 100% secure and we encourage you to use caution when using the Internet.
11. Applicable law
This Policy is governed by the laws of the State of Florida without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within Florida. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
12. Notice to Site Users Located Outside the U.S.
The Company operates in accordance with the laws of the U.S. When you access our Site from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
13. Contact Us
If you have additional questions, you may call us at (888) 601-8638 or reach us by email at HCAprivacy@thekey.com.
14. Changes to this Policy
Effective Date: June 22, 2023
From time to time, we may change our privacy policies. We will notify you of any material changes to our Policy by posting an updated copy on our website. Please check our Site periodically for updates.
