Overview of Our Privacy Practices

VOW Digital Health champions comfort, confidence, and joy around live experiences by COVID-clearing individuals prior to live gatherings such as a work shift or event. Here is a high-level overview of our privacy practices and how we comply with applicable law. We have also provided a more privacy policy below that outlines our specific data collection practices.

  • VOW Digital Health achieves this by asking individuals to provide valid proof of identity (such as a government-issued ID) and comparing the identifying information on an individual’s ID to the individual’s valid health credential, which could include proof of a COVID vaccine or a negative COVID test.
  • The information VOW Digital Health collects as part of this process includes first name, last name, date of birth, cell phone number, email address, and relevant information present on a COVID vaccine and/or negative COVID test.
  • VOW Digital Health does not assert the legitimacy of a person’s government-issued ID or health credentials. Users affirm that their information is real and consent to uploading it to VOW Digital Health for the purposes outlined in the Privacy Policy and Terms and Conditions.
  • VOW Digital Health is not subject to the HIPAA rules and regulations because it does not meet the definition of a “Covered Entity” under the law. VOW Digital Health is also not subject to HIPAA as a Business Associate because VOW does not provide services to HIPAA Covered Entities.
  • VOW Digital Health complies with all applicable data protection laws, including the General Data Protection Regulation and the California Consumer Privacy Act.
  • VOW Digital Health implements reasonable administrative, physical, and technical safeguards to protect any personal information or personal data that it collects.
  • VOW Digital Health does not use any end user data for its own sales or marketing purposes.

This Privacy Policy (“Policy”) describes how VOW by Jennifer Brisman Inc. (“VOW,” “we,” “our,” “us”) collects, uses, and discloses certain information obtained through your use of our website (the “Site”), which is available at https://vowdigitalhealth.com/, and the VOW mobile application (“App”), which is available for download on iOS on the Apple App Store and through Android on the Google Play Store. By visiting our Site or App and/or using the features made available to you on those platforms (collectively, the “Services”), you are agreeing to the terms of this Policy.

Information We Collect and Maintain About You

We collect information from you directly when you provide it to us through the Services. We may also automatically collect certain information about you and your smartphone or other device when you use, access, or interact with our Services.

Personal information provided directly by you

We collect personal information from individuals that utilize our Services to attend events (“Event Attendees”) or their workplaces (“Employees”). If you are an Event Attendee or Employee and you create an account with us, we may collect the following information that you provide to us:

  • Your name;
  • Your contact information (email address and phone number);
  • A copy of your government issued identification card;
  • With your consent, information about your COVID-19 health status (e.g. vaccination status (including the vaccine manufacturer and vaccine dates), your current health symptoms, whether you have ever tested positive for COVID-19, whether someone you have been in close proximity has tested positive for COVID-19 etc.); and
  • With your consent, other health information requested by the Event Organizer or Employer.

If you wish to use the Services for your event or workplace (and are either an “Event Organizer” or an “Employer”), we will collect information to create an account for you. This information could include your name, the name of your organization, and information about the event you wish to host or your workplace (such as its location and expected occupancy). We will also collect contact information that you provide about your Event Attendees or Employees (such as name, email address, or phone number).

You may also use our Site without creating an account or otherwise submitting any personal information. However, if you use certain features on the Site, such as the “Contact Us” feature, you may be required to submit personal information. This information could include your name, contact information, and any other information that you choose to provide.

Text messages

If you are an Event Attendee, Event Organizer, Employee, or Employer, we may send you text messages with your consent. These text messages may relate to your use of the Services (such as a reminder text for you to submit your COVID-19 test results in order to attend your event). Please note that standard messaging and data rates may apply. You may opt out of receiving text messages from us by following the instructions in those messages or by emailing us at privacy@vow.app.

Server logs

Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Services on a particular time and day and collect information such as your device ID.

Cookies

We also use cookies on the Services. Cookies are small files that are stored on your mobile device through the Services. A cookie allows the Services to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Services during your current session and over time (including the pages you view and the files you download), your device’s operating system, your device ID, and your general geographic location.

Pixel tags

A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement, or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email.

Third-party plugins

Our Services may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.

Third-party online tracking

We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set pixels and cookies through the Services. This information may be used for a variety of purposes, including analytics, as discussed below (see the section entitled “How we share your information”).

Aggregated, anonymized, or deidentified information

We may also share aggregated, anonymized, or deidentified information about users of the Services, such as by providing Event Organizers or Employers with the number of individuals in a particular situation whose test results have indicated that they may be positive for COVID-19. Such aggregated, anonymized, or deidentified information will not identify you personally.

How We Use and Process Your Information

We use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.

The purposes for which we collect your personal information include to:

  • Offer you our Services;
  • Respond to your questions or requests concerning the Services;
  • Fulfill the terms of any agreement you have with us;
  • Fulfill your requests for our Services or otherwise complete a transaction that you initiate;
  • Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails;
  • Improve our artificial intelligence and machine learning;
  • Deliver confirmations, account information, notifications, and similar operational communications;
  • Improve your user experience and the quality of our products and Services;
  • Comply with legal and/or regulatory requirements;
  • Aggregate and deidentify information;
  • Count and recognize visitors to the Services;
  • Analyze how visitors use the Services and its various features;
  • Improve the Services and enhance users’ experiences with the Services;
  • Create new products and services or improving our existing Services;
  • Enable additional analytics and research concerning the Services; and
  • Manage our business.

We may link information gathered through the Services with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.

With Whom and Why We Share Your Information

We share your information with third parties for a variety of purposes, as described below.

To offer you our Services

If you are an Event Attendee or Employee, we will share information about your COVID-19 status (such as the status or results of a COVID-19 test you have taken) or other health information (such as your temperature) with your Event Organizers or Employers. In addition to this Policy, any information that Event Organizers or Employers receive about Event Attendees or Employees is also governed by the Event Organizers’ or Employers’ privacy policies.

Third-party service providers

VOW uses third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.

We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Analytics

We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and access cookies and device IDs from your browser or device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.

Legal purposes

We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

  • To comply with applicable law or a court order, subpoena, or other legal process;
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • To establish, protect, or exercise our legal rights or defend against legal claims; or
  • To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Your Choices

You may opt out of receiving marketing emails or text messages from us by following the instructions in those messages or by emailing us at privacy@vow.app.

If you want to learn more about the personal information that we have about you, or you would like to update, change, or delete that information, please contact us by email at privacy@vow.app.

California Residents

If you are a resident of the state of California, please review our California Privacy Addendum for additional rights that may be applicable for you.

EU Residents

If you are an EU resident and we process your information as a controller under the General Data Protection Regulation (“GDPR”), you may have the following rights available to you with regards to our collection and use of your personal information. These rights may include:

  • The right to be informed about our data collection practices;
  • The right to access and rectify your data;
  • The right to erase or delete your data;
  • The right to data portability;
  • The right to restrict and object to the processing of your data (including for direct marketing purposes);
  • The right to opt-out of marketing emails and text messages;
  • The right to limit our use of any automated decision-making processes;
  • The right to lodge a complaint to your local data protection authority; and
  • The right to withdraw consent (to the extent applicable).

To exercise any of the rights listed above, please contact us via email at privacy@vow.app. We will respond to your request as soon as reasonably possible but no longer than 30 days.

External Links

This Services may contain links to third-party websites or services. If you use these links, you will leave the Services. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.

Data Security

We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no mobile Services is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.

Data Retention

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

International Users

The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any information to us, you expressly consent to such transfer and processing.

Children

Content on this Services is directed at individuals over the age of 21 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.

Changes to this Policy

We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Services, so you should review this page periodically.

How to Contact Us

Should you have any questions or concerns about this Policy, you can contact us at by email at privacy@vow.app.