VITALITY PRIVACY STATEMENT
Relationships are built on trust. One of the most important elements of trust is respect for an individual's privacy. Vitality values our relationship with you, and we take your personal privacy seriously.
For purposes of this Privacy Statement, "we", "us", "our" and "Vitality" refer to The Vitality Group, Inc. and its parents, affiliates, subsidiaries, employees, directors and agents. "I", "you", "your" and "member" refer to each member of the Manulife Vitality Program. “The Manulife Vitality Program” refers to any products and services related to or connected with Vitality and/or the Manulife Vitality website, including, but not limited to, any products or services associated with the Manulife Vitality Program (including any activities or other incentives offered by or through your insurance policy or other financial products offered by The Manufacturers Life Insurance Company and its, affiliates and subsidiaries ("Manulife")). "Our website" refers to the Manulife Vitality website.
We are committed to ensuring that our members understand our privacy practices. This Privacy Statement will outline, among other things:
- what personal information we may collect,
- how we may use and disclose that personal information,
- who may have access to that personal information, and,
- how we protect the personal information.
Please read the entire Privacy Statement before using our website or the Manulife Vitality Program.
Accountability for our compliance with this Privacy Statement rests with our Privacy Officer. Other individuals within Vitality may be delegated to act on behalf of the Privacy Officer. If you have questions or concerns about this Privacy Statement or our privacy practices, please contact our Privacy Officer using the contact information below.
COMMITMENT TO CONFIDENTIALITY
Confidentiality is a top priority at Vitality. We are committed to maintaining the confidentiality of the information we receive from our members. This Privacy Statement is intended to assure you that Vitality takes appropriate measures designed to ensure that the information you share with Vitality is kept confidential and secure.
COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
Users of our website or the Manulife Vitality program are required to provide certain personal information in order to receive products and services. Please refer to the document entitled "Consent To Collection, Use and Disclosure of Personal Information" on this site, for details on how we will collect, use, store, process, review and disclose personal information.
DATA SECURITY PROCEDURES
We maintain security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information you submit to us. We protect personal information with organizational, physical, mechanical and electronic safeguards appropriate to the sensitivity of the information, including encryption and secure server technology where appropriate.
Information that you share on our website is encrypted (encoded) information is protected using "Secure Socket Layers (SSL)" as it passes between your browser and our website. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet or method of electronic storage is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Only authorized persons are permitted to access your personal information. All authorized persons must abide by relevant security, privacy and confidentiality agreements, and applicable rules and laws. We may also use service providers, including service providers outside Canada, to assist us in administering the Vitality Program. Where personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with our privacy policies and practices.
You are responsible for maintaining the confidentiality of your account password and for any access to or use of our products and services using your password, whether or not authorized by you. Please notify us immediately of any unauthorized use of your password or account or any other breach of security.
Your personal information will be retained only as long as necessary for the fulfillment of the purposes referred in the Consent To Collection, Use and Disclosure of Personal Information, in this Privacy Statement, or as may be required by law, after which time it will be destroyed or de-identified. We may be unable to remove information to the extent that it is permitted or required to be retained by applicable law or document retention and data backup or disaster-recovery policies, or if removal is not practicable due to technological reasons.
You acknowledge that in participating in the Manulife Vitality Program, your information may be gathered and stored in jurisdictions outside of Canada, and may be subject to the laws of the jurisdiction in which your information is held.
For written information on, or specific inquiries about our use of service providers outside Canada, please contact our Privacy Officer using the contact information set out below.
TECHNOLOGY USE ON OUR WEBSITE
Information about you and your use of our website is collected through the use of session cookies. Session cookies are small text files that are stored within your computer. These files are used to facilitate your navigation throughout our website.
Persistent cookies are small computer files that are transferred to your computer's hard drive. These stored files are used in the generation of data that is fed to a contracted third party for website usage analysis. Reports created using this information will provide Vitality with a better understanding of the use of our website. You may choose one of three different levels of data collection associated with the use of the persistent cookie. Transfer to Persistent Cookie Opt-out Options for more information. Information stored within both session and persistent cookies are not tied to your personal information.
If you are concerned about the storage and use of cookies, you may be able to direct your Internet browser to notify you and seek approval whenever a cookie is being sent to your hard drive. You may also delete a cookie manually from your hard drive through your Internet browser or other programs. You can also set your browser to refuse all cookies. Please note, however, that some parts of our website may not function properly or be available to you if you refuse to accept a cookie or choose to disable the acceptance of cookies.
To gauge the effectiveness of our website, we may collect non-personal information about our website users. This information may include, among other things, your: browser type, Internet service provider (ISP), domain names, referring/exit pages, operating system, date/time stamp, clickstream data and page views. We use this information, which does not identify individual users, to analyze trends, to administer the website, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically collected data to personal information.
LINKS
Links to other websites may be included on our website to provide you with additional useful information and services. Links that take you off our website are clearly labeled. Vitality is not responsible for the privacy policies or actions of those who control other websites. We encourage you to look for and review the privacy policies of any website you visit.
Vitality may also partner with third parties and provide links to their websites to offer you additional information and services. You may see both the Vitality logo and the third party's logo on these third-party websites. Users of these websites should be aware of who is collecting personal information and whose Privacy Statement applies before they provide personal information. Vitality may not have control over third-party partners' use of your information.
WITHDRAWAL OF CONSENT
Your consent may be expressed in writing, verbally or it may be given electronically. In certain circumstances, your consent may also be implied or inferred from certain actions.
You can withdraw your consent at any time to collection, use or disclosure of your personal information, subject to legal or contractual restrictions and reasonable notice. You may do so by using the contact information provided at the end of this Privacy Statement. Such withdrawal may make it impossible for us to continue providing some or all products and services to you, including participation in the Manulife Vitality Program. We will inform you of any implications of such withdrawal. We may be unable to remove information to the extent that it is permitted or required to be retained by applicable law or document retention and data backup or disaster-recovery policies, or if removal is not practicable due to technological reasons.
EMAIL
If you send questions or comments to a Vitality email address or via a contact form located within our website, we will share your correspondence with a Vitality associate most capable of addressing your questions and concerns. We will retain your communications until we have done our very best to provide you with a complete and satisfactory response. Ultimately, we will either discard your communication or, in some cases, subject to the terms and conditions of the Consent To Collection, Use and Disclosure of Personal Information Privacy Statement or as required by law, we may retain it on file for a period of at least one (1) year. We will not keep your email address for secondary purposes. All information and correspondence you share with us will be handled in the strictest confidence.
Although email has become a standard communication tool used by many different parties, standard Internet email is unfortunately not secure. For that reason, please do not use unsecured email to communicate information to us that you may consider to be confidential or sensitive.
CHILDREN'S PRIVACY
Our website is not intended for use by individuals under the age of 18.
PRIVACY STATEMENT CHANGES
This Privacy Statement is effective as of June 1, 2016 and was last updated in June, 2016.
If we decide to change our privacy policies, we will post those changes to this Privacy Statement, the home page of our website and other places that we deem appropriate, and will indicate when the change will become effective. Vitality reserves the right to modify this Privacy Statement at any time, so please review it frequently.
CORRECTING INFORMATION
We will establish a file from which your information will be used to administer your membership in the Manulife Vitality program. Your file is secured in the United States.
We will make all reasonable efforts to ensure that any personal information we collect and keep is as accurate, complete and as up to date as required for the identified purposes. To do so, we will rely to a large extent on you to provide us with accurate information and to inform us of changes, such as changes in your contact information. You have the right to access and verify your personal information maintained in our files, and to request that any factually inaccurate personal information be corrected, if appropriate.
CONTACT US
You may submit a request to access or update your personal information, or if you have questions or concerns about the collection, use, disclosure, amendment, deletion or location of your personal information using the contact information below:
Privacy Officer
Email: RMrizek@thevitalitygroup.com
telephone: 312-224-7399
or write to: 200 W. Monroe St, Suite 1900, Chicago, IL 60606
