Effective November 17, 2016
At Vision Group Holdings, our Company, its affiliates and subsidiaries, and its affiliated medical practices (“collectively referred to as “Company,” “our” or “we”) value your privacy and the trust placed in us by our patients, customers and business partners to appropriately use and protect information shared with us. We are the leading provider of vision services and treatment (“Services”) in the United States. We pride ourselves on offering our patients the most advanced, leading edge healthcare technology in vision treatment and services. We are pleased to provide you with information on our privacy practices used in the marketing and advertising of our Company’s Services.
TABLE OF CONTENTS
Personally Identifiable Information You Provide: We collect information that you voluntarily provide when you use the Services, such as when you register for our Services, participate in a survey, provide a testimonial, participate in an interactive feature or forum (such as chat features), participate in a contest, or contact us with a question, comment, or request. This personally identifiable information that you provide might include, for instance, your name, address, age, birth date, gender, email address, phone number, photo, social media account ID, zip code, education, professional experience, demographic information, information about your health and/or medical conditions, product and Services usage and preferences.
Non-Personally Identifiable Information We May Collect: Non-Personally Identifiable Information refers to information that does not by itself identify a specific individual. We gather certain information about you based upon the portion(s) of the websites that you visit. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the website’s Uniform Resource Locator (“URL”) that you just came from, which URL you go to next, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web (“Web”). Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.
Information We Receive from Third Parties: We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information, joint marketing partners, social media platforms, people with whom you are connected on social media platforms, and other third parties.
We, our service providers and business partners may collect information automatically from your device in a variety of ways including:
Through your browser or device: Certain information is collected by most browsers or may be automatically collected through your device with the use of a tracking code and other technology, to collect information such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this to collect information on your activities on our websites or applications.
Through your use of a mobile or desktop application: When you download and use a mobile or desktop application of one of our business partners/service providers, they and we may track and collect application usage data, such as the date and time the application on your device accesses our servers and what information and files have been downloaded to the application.
Using pixel tags and other similar technologies: We may use pixel tags (also known as web beacons and clear GIFs) to, among other things, track the actions of users of our websites and our email recipients, measure the success of our marketing campaigns and compile statistics about usage and response rates.
Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of our websites. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs, how to prevent Flash LSOs from being placed on your computer without your consent, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses our applications or websites, along with the time of the visit and the page(s) visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels, helping diagnose server problems, and administering the websites. We may also derive your approximate location from your IP Address.
Precise Real-Time Location Information: We may collect precise, real-time information about the location of your mobile device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s location to provide you with personalized location-based services and content, including marketing communications. You may be permitted to allow or deny the use of your device’s location by managing your location services preferences through your device settings.
Interest-Based Advertising: We may use third-party advertising companies to serve advertisements to you when you access our websites, applications or online services, based on information relating to your access to and use of other websites, applications or online services on any of your devices. To do so, these companies may use various technologies, including the placement or recognition of a unique cookie on your browser (including through use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. These companies use the information they collect, as well as information received from third parties, to serve ads for us and others about goods and services that may be of interest to you when you are on our websites or on third-party properties.
Online Behavioral Advertising: Online Behavioral Advertising (“OBA”) is the practice of collecting information from web browsers so it can be used to present online advertisements that are more relevant to the user of a particular computer. We believe OBA offers consumers a much better experience of online advertising. When a consumer visits our website, the pages they visit, the amount of time they view each page, the links they click on, the searches they make and the things that they interact with, allow us to collect that data so that we can create a “profile” that links to that visitor’s web browser. We use this information to personalize your experience, enhance security, facilitate navigation, display material more efficiently and recognize the device that you are using. We may disclose OBA information to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
Behavioral Targeting/Re-Targeting: We partner with third parties to display advertising on our websites and manage our advertising on other sites. Our third party business partners may use technologies such as cookies to gather information about your activities on our websites and other sites in order to provide you advertising about us based upon your browsing activities and interests. If you access our websites on your mobile device, you may not be able to control tracking technologies through the settings. You may also be redirected from the landing page of one website to another website, owned or controlled by us, through these technologies.
Please see Section 6 on Choices As To Your Privacy to obtain information on opting-out of OBA.
If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to disable cookies. On your mobile device, go to Settings, then Safari, and then to the Cookies section. For other browsers, check with your provider to find out how to disable cookies. Also see Section 6, Choices As To Your Privacy.
As is true of online companies, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyze trends, to administer the website, to learn about user behavior on the website, to improve our product and services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services as well.
In some of our email messages, we use a “click-through URL” linked to content on our website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
We do not respond to web browser Do Not Track Signals. If you would like to learn how to set your browser so that third parties do not track you, see Section 6 on Choices As To Your Privacy.
We may use the information provided by you for any legally permissible purpose. We require your opt-in consent for the sharing of any Personally Identifiable Information with third parties. We will not sell, distribute or lease your Personally Identifiable Information or use your personal information to send you promotional information about third parties, unless you have given us your opt-in consent to do so. We may, without your consent, sell or transfer Personally Identifiable Information to third parties in connection with any merger, acquisition, reorganization, change in capital structure, or sale of all or substantially all of our assets or the websites we own.
Through contractual arrangements with affiliates, service providers, partners and other third parties, we and our service partners use your Personally Identifiable Information to operate the websites and to deliver their services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on the websites; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us provide customer service. We will encourage our service partners and marketing partners to adopt and post privacy policies. However, the use of your Personally Identifiable Information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control. Occasionally we may be required by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful. We may also provide Non-Personally Identifiable Information about our customers’ sales, traffic patterns, and related information to third party advertisers, but these statistics do not include any Personally Identifiable Information.
Opting Out of Online Behavioral Advertising (“OBA”) and Enabling Do Not Track: You may opt out of OBA and enable Do Not Track by doing the following:
If you delete your consumer opt-out cookies, subsequently change your settings, use a different computer or change browsers you will need to opt-out again. OBA opt-outs work only on the web browser you’re using when you opt-out. You will need to repeat the opt-out for each computer and each web browser you use (e.g. Safari, Chrome, Firefox, Internet Explorer).
If your browser has cookies disabled, you do not need to opt-out, as relationship based or online behavioral advertising technology does not work when cookies are disabled. Please check your browser’s security settings to validate whether cookies are active or disabled.
Please note that even if you opt-out, you may still receive online advertising from us. Opting-out from a specific advertising provider means only that the ads you do receive will not be based on OBA.
Opting Out of Receipt of Postal, Email or Telephone Marketing and Promotional Communications: If you elected to receive marketing and/or advertising materials from us via the postal service, email, or telephone and no longer wish to do so, you may opt out of receiving those communications by:
Postal Communications: If you do not wish to receive postal communications from us, please send us a letter with your name, address and email address to Compliance Officer, 1555 Palm Beach Lakes Blvd., Suite 200, West Palm Beach, FL 33401 or email us at: advertising(at)vgroupholdings(dot)com;
Phone Communications: If you do not wish to receive telephone communications from us, please send us a letter with your name, address, email address, and phone number to Compliance Officer, 1555 Palm Beach Lakes Blvd., Suite 200, West Palm Beach, FL 33401 or email us at: advertising(at)vgroupholdings(dot)com;
Email Communications: If you do not wish to receive promotional emails from us, please let us know by using the opt-out response that can be found at the bottom of every email we deliver or by emailing us at: advertising(at)vgroupholdings(dot)com.
Under California Civil Code Section 1798.83, California residents who have an established business relationship with a company may choose to opt out of that company sharing their personally identifiable information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your personally identifiable information to third parties for direct marketing purposes, please send an e-mail to: advertising(at)vgroupholdings(dot)com with “California Third Party Disclosure” in the subject line.
Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit personal information from anyone under the age of 18. If we learn that we have collected the personal information of a child under 18, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
We contract with advertising companies to advertise our products and Services on websites not affiliated with us (“Third Party Websites”). We may provide OBA information provided by you to these Third Party Websites to assist in the selection of which of our advertisements or offers may appeal to you, display them to you and monitor your responses. Third Party Websites are not subject to our Privacy Policies. Please visit those individual websites for additional information on their data and privacy practices and opt-out policies.
Occasionally, you may encounter banner advertisements for us on third-party websites. We use third-party advertising service providers to distribute our advertisements on websites where we have paid to advertise. These advertisements may use tracking technologies to capture information such as IP address, browser type and usage information in order to track the effectiveness of our advertising efforts. In addition, we use advertising service providers such as Google and The Trade Desk to place advertisements for our accounts and services on websites not affiliated with us, and to help us determine which of our advertisements are most likely to be of interest to you using non-personal behavioral information. Advertisements placed by these service providers may use tracking technologies that allow monitoring of your responsiveness to such advertisements. We restrict access and collection of information by advertising service providers for purposes other than assisting us with our advertising efforts.
You can review, correct, update or delete inaccuracies to the information about you that we keep by contacting us directly at advertising(at)vgroupholdings(dot)com. Please include your name, address and email address when you contact us. We will respond to your request within 30 days.
We will retain your information for as long as your account is active or as needed to provide you Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.