Introduction
HolaVida Health, Inc. and its subsidiaries ("HolaVida Health," "we," or "us") own and operate various digital platforms, including websites and mobile applications (collectively referred to as the "Platform"). These platforms may include, but are not limited to, the websites and apps associated with our services. By accessing, using, or interacting with any part of the Platform, including its content ("Content") and the products or services available through it (collectively referred to as the "Service"), you agree to comply with the terms of this Privacy Policy. Capitalized terms not explicitly defined in this Privacy Policy hold the same meaning as outlined in our Terms and Conditions ("Terms").
We respect the privacy of all users interacting with the Service. This Privacy Policy explains how HolaVida Health collects, uses, and shares information to provide and improve the Service.
By creating, registering, or logging into an account through the Service, or otherwise accessing or using the Service, you acknowledge and accept the latest version of this Privacy Policy. We may update this Privacy Policy to reflect significant changes in our Service or in our practices regarding the handling of personal data, as required by applicable laws. Any revisions to this Privacy Policy will be posted with an updated “Last Updated” date at the top. If material changes are made, we will notify you as necessary to ensure your consent in accordance with legal requirements.
If you are using the Service on behalf of someone other than yourself, you confirm that you have been authorized by that individual to act on their behalf and that they are aware of the practices outlined in this Privacy Policy.
Restrictions on Use by Minors
The Service is primarily intended for individuals aged eighteen (18) years or older, or the minimum age required by applicable law in the jurisdiction where the Service is accessed. Users between the ages of thirteen (13) and eighteen (18) (or the higher age of majority in their jurisdiction) may use the Service solely for the purpose of obtaining medical consultations, such as for the treatment of acne, if a parent or legal guardian consents to such use, in accordance with our Terms and Conditions.
Our Service is not intended for children under the age of thirteen (13). If we learn that we have inadvertently collected personal information from someone under the age of thirteen (13), we will take reasonable steps to delete that data from our systems.
Additionally, if you are under sixteen (16) years old, or a minor in your jurisdiction, you (or your parent or guardian, if under thirteen) may request the removal of any content or information you have posted on the Platform. To make such a request, please contact us using the following:
By Mail: HolaVida Health, Inc.,
Attn: Privacy Officer,
1100 S Miami Ave, Apt. 2801, Miami, FL 33130
Subject: "Request for Removal of Minor Information"
By Email: privacy@holavida.com
Subject: "Request for Removal of Minor Information"
Please include the following in your request:
A description of the content or information to be removed
The specific location of the content on the Platform (e.g., the URL)
Your contact information (name, address, email)
Your preferred method of response (mail or email)
We will not process requests made by telephone or facsimile. In some cases, we may be unable to fulfill a removal request due to legal or other obligations.
Please be aware that we are not obligated to delete, remove, or otherwise make inaccessible certain content or information under specific circumstances. These circumstances include, but are not limited to: instances where we are required to retain the content or data under applicable international, federal, state, or local laws, regulations, or legal obligations; where the content or information forms part of your electronic health record and is maintained on behalf of your healthcare providers (as defined in our Terms and Conditions); where the content or information was submitted or republished by someone other than you, including third-party reposts of your original content; where the information has been de-identified or anonymized such that it no longer directly identifies you; where the removal request was not submitted in accordance with the procedures outlined in this Privacy Policy; or where you have received any form of payment or benefit in exchange for the submission of the content or information.
The above statement outlines HolaVida Health’s discretionary approach to collecting personal information from certain minors via our Services. It is not intended to serve as an acknowledgment that HolaVida Health is governed by the Children’s Online Privacy Protection Act (COPPA), the corresponding rules set forth by the Federal Trade Commission, or any comparable laws, regulations, or rules at the international, federal, state, or local level.
Protected Health Information (PHI) and HIPAA Compliance
At HolaVida Health, we are committed to maintaining the privacy and security of your Protected Health Information (PHI) in compliance with the Health Insurance Portability and Accountability Act (HIPAA). PHI refers to any health information that can be used to identify an individual and that is related to their physical or mental health, healthcare services received, or payment for healthcare services.
How We Treat Protected Health Information (PHI)
We collect and process PHI through the services we provide, which may include details such as your name, address, contact information, medical history, symptoms, and other health-related data that you share with us. This information is collected when you interact with our website, fill out forms, or engage in healthcare services with our medical providers. We only collect the minimum necessary PHI to provide the services you request.
Patient Rights Regarding PHI
As a patient, you have the following rights regarding your PHI:
Right to Access: You have the right to request a copy of the PHI we have about you.
Right to Correct: If you believe any of your PHI is incorrect or incomplete, you have the right to request corrections.
Right to Request Restrictions: You may request restrictions on how we use or disclose your PHI. We will consider your request but are not required to agree to all restrictions.
Right to Confidential Communications: You have the right to request that we communicate with you in a certain way or at a certain location to maintain privacy.
Right to Privacy: You have the right to request that we send your PHI to a different address or email.
Our Legal Duties Regarding PHI
As a business associate under HIPAA, HolaVida Health is required by law to:
Maintain the privacy of your PHI: We will not disclose your PHI without your explicit consent, except as necessary to provide healthcare services or as required by law.
Notify You of Privacy Practices: We will provide you with a Notice of Privacy Practices explaining how we collect, use, and protect your PHI.
Implement Security Measures: We implement physical, technical, and administrative safeguards to protect your PHI from unauthorized access, use, or disclosure.
Comply with HIPAA: We are committed to complying with all HIPAA regulations, including maintaining the confidentiality of your PHI and ensuring that our partners and service providers follow HIPAA requirements as well.
If you have any questions or concerns about your rights regarding your PHI or would like to exercise any of the rights outlined above, please contact us at privacy@holavida.com.
Protected Information
When you create an account with HolaVida Health, you enter into a relationship with us that allows you to use the various features of the Platform. As part of this, you may provide personal details such as your name, email address, shipping address, phone number, and transactional information. These details are not considered "protected health information" or "medical information."
When using certain features of our Services, you may choose to provide health-related or medical information that may be protected under applicable laws. HolaVida Health is not classified as a “covered entity” under the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”), and its implementing regulations. Certain affiliated entities, such as laboratories, pharmacies, or medical groups (as defined in our Terms and Conditions), may qualify as “covered entities” or “business associates” under HIPAA, and HolaVida Health may, in some instances, act as a “business associate” to those organizations.
It is important to understand that the mere involvement of health-related information does not automatically trigger HIPAA obligations. Accordingly, HIPAA may not govern your communications or interactions with HolaVida Health, the medical groups, healthcare providers, pharmacies, or laboratories associated with the Services. However, to the extent that HolaVida Health is determined to be acting in the capacity of a “business associate,” we may be subject to certain HIPAA requirements, but only with respect to “protected health information” (“PHI”) as defined by HIPAA, and only in connection with services provided on behalf of a covered entity.
Additionally, any health or medical data you provide that is specifically protected under state privacy laws (together with PHI, referred to herein as “Protected Information”) will be handled in compliance with those applicable legal requirements. Any information not categorized as Protected Information under federal or state law may be used or disclosed as described in this Privacy Policy. Protected Information does not include data that has been properly de-identified in accordance with legal standards.
Medical groups and providers engaged through our Services maintain their own Notices of Privacy Practices, which outline how they manage and disclose Protected Information. By accessing or using our Services, you acknowledge and accept receipt of such notices from your healthcare provider(s) and medical group.
Finally, please be aware that any information you share with HolaVida Health that is not submitted for the specific purpose of receiving clinical care, laboratory testing, or prescription services is not considered Protected Information and will instead be subject to our general Privacy Policy and any applicable state laws. For example, information you provide when creating an account—such as your name, birthdate, email address, shipping information, and phone number—is not classified as Protected Information under HIPAA.
Collection of Personal Information
The types of personal information we collect vary based on your interactions with us, the services you choose to use, and the decisions you make.
We gather personal information from multiple sources and in various ways when you engage with our services, including data you provide directly, automatically collected data, third-party information, and insights we generate based on other data we collect.
We collect the personal details you provide to us, such as:
- Personal and Contact Information: Name, email address, phone number, billing information, and physical addresses.
- Demographic Information: Gender, date of birth, and zip code.
- Social Media Interactions: Data from third-party social media sites, networks, and platforms (e.g., Facebook, Twitter, Instagram).
- Payment Information: Credit card numbers, bank account details, and other payment methods.
- Content and Files: Photos, videos, documents, and other files you upload through the Service, including emails or any other forms of communication you send us.
Sensitive Personal Information
We may collect sensitive data, including:
- Government Identification: Driver’s license, passport number, social security number, or similar government-issued identifiers.
- Account Credentials: Information like usernames or account numbers along with passwords or other access credentials required to access your account.
- Sensitive Demographic Data: Information regarding your racial or ethnic background.
- Communication Contents: The contents of messages and communications sent through the Service.
- Biometric Data: Biometric data used for identity verification, either by us or our service providers.
- Health Data: Information regarding your health, which may include browsing history, app usage, interactions with the Service, and inferred data based on your activity.
- Sexuality: We may collect or analyze data related to your sexual orientation or sexual life.
Information We Collect Automatically
When you use our services, we automatically collect certain data, such as:
- Identifiers and Device Information: We log your Internet Protocol (IP) address, device type, and related software (e.g., operating system, browser type and version, settings).
- Geolocation Data: If enabled, we collect location information from your device while using our services.
- Usage Data: We track your activity on our websites and apps, such as pages you view, time spent on pages, entry/exit points, and interaction details. This can include sensitive data, such as visits to health-related pages on the Service.
Data We Create or Generate
We may derive new insights from the data we collect, such as inferring your likely preferences or demographic characteristics based on your interactions with us.
For instance, we may determine your general location (city, state, or country) based on your IP address.
Information from Third-Party Sources
We may also gather personal information from third parties, such as:
- Third-Party Partners: Information from external services or applications you interact with through our platform (e.g., social media sites).
- Co-Branding and Marketing Partners: Information from partners we collaborate with for joint marketing or co-branded services.
- Service Providers: Third-party companies that assist in data collection on our behalf, such as those determining your device’s location from its IP address.
- Publicly Available Sources: Information from open public sources, like government databases.
You may choose not to provide certain personal information, and you can use your browser’s settings to block automatic data collection. However, if you choose to withhold necessary information or restrict certain data collection, some features of the Service may be unavailable or not function properly.
HolaVida Health works with medical providers and pharmacies through the Service, which may require storing additional health-related information on their behalf, such as your medical records, prescriptions, and communications with healthcare providers.
Cookies, Mobile IDs, and Similar Technologies
We use technologies such as cookies, web beacons, mobile analytics, and advertising identifiers to enhance the functionality of our websites and services and to gather data including usage statistics, device identifiers, and other information.
What Are Cookies and Similar Technologies?
Cookies are small text files placed by a website and stored on your device. When you revisit the site, the cookies allow the website to recognize your browser and store information about your preferences.
Web beacons (also known as tracking pixels) are tiny graphics embedded in web pages or emails that help track your interactions with our content and measure the effectiveness of communications.
Mobile analytics and advertising identifiers are unique identifiers generated by mobile operating systems (like iOS and Android) and accessed by apps in a manner similar to how cookies are used on websites. These identifiers help us and our third-party partners analyze your app usage and engagement.
How We and Our Partners Use Cookies and Similar Technologies
We, along with our analytics and advertising partners, use cookies and similar technologies across our websites, mobile applications, and online services to collect personal data (such as your browsing history, click behavior, and other usage data, along with identifiers and device information) when you interact with our services. This includes tracking your activities over time and across various websites or services. The collected information helps us to personalize your experience, remember your preferences, enable sign-ins, analyze performance, assess user engagement, create profiles, display interest-based advertisements, combat fraud, and pursue other legitimate interests. We may share this data with third parties for these purposes. For more information on the third-party analytics and advertising partners, please refer to the "Disclosure of Personal Information" section of this Privacy Policy.
What Controls Are Available to You?
Various tools are available through browsers, mobile systems, and other platforms to manage cookies and similar technologies. Detailed information can be found in the "Choice and Control of Personal Information" section below.
Use of Personal Information
The personal data we collect is used as outlined in this Privacy Policy, or as otherwise disclosed to you, with due regard for the "Protected Information" section. Below are examples of how we use personal information:
Purpose
Types of Personal Information
Service Delivery
Contact details, demographic info, payment info, content, biometric data, device identifiers, geolocation, usage data, inferences. Sensitive info: government ID, health data, communications content
Business Operations
Contact details, payment info, content, biometric data, device identifiers, geolocation, usage data, inferences. Sensitive info: government ID, account access details, health data.
Product and Service Development
Contact details, demographic info, payment info, content, biometric data, device identifiers, usage data, inferences. Sensitive info: government ID, health data, communications content.
Personalization
Contact details, demographic info, payment info, content, biometric data, device identifiers, geolocation, usage data, inferences. Sensitive info: health data, government ID, communications content.
Customer Support
Contact details, demographic info, payment info, content, biometric data, device identifiers, usage data, inferences. Sensitive info: health data, government ID, communications content.
Communications
Contact details, demographic info, content, payment info, device identifiers, geolocation, usage data, inferences. Sensitive info: communications content, health data.
Marketing
Contact details, demographic info, content, payment info, device identifiers, geolocation, usage data, inferences. Sensitive info: health data.
Advertising
Contact details, demographic info, device identifiers, usage data, inferences. Sensitive info: health data.
We may also combine the data collected from various sources to provide a consistent, personalized experience.
Additionally, we may use data about your browsing activity to market and promote our services, products, and related offerings. In some cases, this could involve collecting information from pages related to health services, but we do not use Protected Information for advertising.
We may also anonymize or de-identify your data for use in research, analytics, or marketing, and such de-identified data may be sold or shared in accordance with applicable laws
Disclosure of Personal Information
We may disclose personal data with your consent or as necessary to complete transactions or deliver services you've requested. As described in the "Protected Health Information" section, we may share the categories of personal data listed below with third parties for service provision or legal purposes:
- Service Providers: We may share your information with third-party service providers working on our behalf to perform various functions, such as customer support, fraud protection, and system security.
- Marketing and Advertising Partners: We may disclose personal information to help deliver personalized advertisements across the web and other platforms.
- Payment Processing Services: When processing payments, your data will be shared with financial institutions and payment vendors to complete the transaction and reduce risks.
- Affiliates: Your data may be shared with our subsidiaries or affiliated entities to help manage and operate our business.
- Medical Providers: We facilitate data sharing with healthcare providers or medical groups involved in your treatment to ensure continuity of care and payment collection.
- Corporate Transactions: If we undergo a corporate event (e.g., merger, sale, or acquisition), we may disclose personal data as part of that process.
- Legal Compliance and Safety: We may disclose data to comply with legal requirements or respond to law enforcement authorities.
In addition, third-party analytics and advertising companies may collect personal data from you via cookies and similar technologies, and may use it for cross-site analytics or marketing purposes.
Choice and Control of Personal Information
You have various options for managing your personal data, including opting out of targeted advertising, accessing, correcting, or deleting your data, and exercising rights where applicable. For further details, visit the "Choice and Control of Personal Information" section below.
Data Retention
We retain personal data for as long as necessary to provide services, fulfill transactions, comply with legal obligations, and for legitimate business purposes. Retention periods may vary based on factors such as user consent, the sensitivity of the data, and legal obligations.
Jurisdiction
This Privacy Policy and our data practices are governed by the laws of the United States, and the services may only be used in certain jurisdictions as specified in our Terms and Conditions.
California Privacy Rights
If you are a resident of California and your personal data is subject to the California Consumer Privacy Act (CCPA), you have specific rights regarding your personal information.
- Notice at Collection: At or before the time we collect personal information, you have the right to be informed about our data practices. This includes the types of personal data and sensitive personal data we collect, the purposes for which we collect and use that information, whether we sell or share such data, and the retention periods for the data. You can review this information in detail within our Privacy Policy, linked above.
- Right to Know: You have the right to request details about the personal data we have collected about you. Additionally, you can request more information about how we collect, use, disclose, or sell your personal information. Much of this information is provided in this Privacy Policy. To make a "request to know," please visit privacy.holavida.com or email us at privacy@holavida.com
- Right to Request Correction or Deletion: You may request that we correct any inaccurate personal information or delete personal data under certain conditions, subject to a range of exceptions. To submit a request for correction or deletion, please visit privacy.holavida.com or email us at privacy@holavida.com.
- Right to Opt-Out / “Do Not Sell or Share My Personal Information”: You have the right to opt-out of the sale or sharing of your personal data as defined by the CCPA.
Please note that the CCPA defines “sale,” “sharing,” and “personal information” broadly, and some of our data-sharing practices outlined in this Privacy Policy may be considered a “sale” or “sharing” under these definitions. Specifically, we allow third-party advertising and analytics providers to collect identifiers (such as IP addresses, cookie IDs, and mobile IDs), activity data (e.g., browsing, clicks, app usage, non-product identifying transaction data), device data, and geolocation data through our sites and applications when you interact with our online services. However, we do not sell or share other types of personal data. If you do not wish for us or our partners to sell or share data related to your visits for advertising purposes, you may submit your request via our Privacy Center or use a Global Privacy Control. By doing so, we will not share or make this data available for purposes defined as "sales" or "sharing" under the CCPA. Nevertheless, we may still share personal information with our service providers to help perform advertising-related tasks. Please note that opting out will not stop the use of previously shared or sold information or eliminate interest-based ads.
We do not knowingly sell or share the personal information of minors under the age of 16. - Right to Limit Use and Disclosure of Sensitive Personal Information: You can limit how we use sensitive personal information for any purposes other than providing the requested goods or services or as otherwise permitted by law.
To opt-out from such uses, please visit the “Your Privacy Choices” section at the bottom of our website or use the Global Privacy Control as outlined in the “Choice and Control” section of this Privacy Policy.
You may appoint an authorized agent through written consent or a power of attorney to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require proof of authorization from you and may need you to verify your identity directly with us.
When requesting the provision, correction, or deletion of specific pieces of personal information, we will need to verify your identity as required by law. Verification may involve submitting your request from the email address associated with your account or providing other information to verify your identity.
You also have the right not to be discriminated against for exercising any of your CCPA rights. - Shine the Light Law (California Civil Code Section 1798.83): California residents who have provided personal information to a business with which they have a relationship for personal, family, or household purposes may request information regarding whether the business has disclosed personal information to third parties for their direct marketing purposes.
Please be informed that we do not disclose personal data to third parties for direct marketing as defined by this law. California residents may inquire further about our compliance with this law by emailing privacy@holavida.com. Note that businesses are only required to respond to one request per California resident each year
Miscellaneous
We employ reasonable physical, technical, and administrative measures to safeguard your information from unauthorized access, use, disclosure, alteration, and destruction. However, you are responsible for securing your account password and maintaining its confidentiality. We advise you to use strong passwords and refrain from sharing them or reusing them on different sites. If you believe your account security has been compromised, please notify us promptly according to the "Contacting Us" section below.
While using our services, you may choose not to provide certain information, but this could limit your ability to access some features or prevent use of the service entirely. You may also opt-out of receiving specific communications (e.g., newsletters, promotions) by emailing your preferences to us. Even if you opt-out, we may still send you communications related to the service. We do not currently respond to "Do Not Track" signals in web browsers or other mechanisms that attempt to block the collection of information across websites. If we do so in the future, we will update this Privacy Policy accordingly.
We may update or modify this Privacy Policy at any time. Any changes will be posted on this page, and the updated policy will be effective as of the date indicated. If the changes are substantial, we may notify you via email or request your acceptance of the new policy. It is your responsibility to review this Privacy Policy regularly.
Contacting Us:
If you have any questions or concerns regarding this Privacy Policy, please reach out to us via email at privacy@holavida.com or by mail at:
HolaVida Health, Inc.
1100 S Miami Ave, Apt. 2801, Miami, FL 33130
Attn: Privacy Officer
By Email:
privacy@holavida.com
Conclusion
This privacy policy reflects the commitment of HolaVida Health to protecting your personal information. Any personal data we collect, use, or share will be handled in compliance with applicable privacy laws and regulations.
Last Updated: April 21, 2025
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