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Privacy Policy

Welcome to Varry Info

Welcome to the Varry Info website, and online services("Varry Info Site," the "Site," or "Sites"), an onlinee-commerce, information, and communications service providedby Varry Info and all affiliates ("Varry Info" or "We"or "Us"). We take your privacy seriously, and we want you toknow how we collect, use, share, and protect yourinformation. In addition to this privacy policy ("PrivacyPolicy"), users of the Varry Info Site should consult theVarry Info Site Terms of Use as well as anyproduct-specific terms and conditions that apply. You mayreview policies specifically related to patient information(protected health information or PHI) submitted throughVarry Info's Patient Online Services. This Privacy Policyapplies to all Sites where it is posted. Other Varry Infoonline properties may have their own privacy policies thatapply to those sites. You should review those privacypolicies in connection with your use of those sites.

What information we collect

Information you give us: We respect the right to privacy ofall visitors to the Varry Info Sites. We receive and storesome information that you enter on our Sites or that youprovide to us through the Sites in any other way. Theinformation we collect or that you provide on or through ourSites or by using our services includes: Data that maypersonally identify you, including your name, postaladdress, billing address, shipping address, e-mail address,home, work and mobile telephone numbers, age, date of birth,physical characteristics that may personally identify you,sexual orientation, IP address, national origin, medicalconditions, citizenship, information about any physical ormental disabilities you may have, information related toyour religious or philosophical beliefs, political opinions,information regarding your gender at birth and how youcurrently express your gender identity, information relatedto your sex life, such as pregnancy, child birth and relatedmedical conditions, any history of criminal convictions,biometric information (such as fingerprints, exercise data,psychological characteristics, face prints, gait patterns,genetics, behavioral characteristics, voice, sleep data, andiris/retina scans), and genetic information (includingfamilial genetic information) (collectively, "PersonalData"); Information that you provide by filling in forms onour Sites, such as appointment request forms or productordering forms. It also includes information you providewhen you register to use our Sites, purchase products, oruse services available through the Sites or facilities. Wemay also ask you for information when you report a problemwith our Sites. Some forms collect sensitive information,such as health information, necessary for us to provide ourservices to you; Records and copies of your correspondence(including email addresses), if you contact us; Yourresponses to surveys that we might ask you to complete forresearch, development, and marketing purposes; and Detailsof transactions you carry out through our Sites and of thefulfillment of your orders. You may be required to providefinancial information before placing an order through ourSites. You also may provide information to be published ordisplayed (hereinafter, "Posted") on public areas of theSites or transmitted to other users of the Sites or thirdparties (collectively, "User Contributions"). Your UserContributions are Posted on and transmitted to others atyour own risk. Although we limit access to certain pages,please be aware that no security measures are perfect orimpenetrable. Additionally, we cannot control the actions ofother users of the Sites with whom you may choose to shareyour User Contributions. Therefore, we cannot and do notguarantee that your User Contributions will not be viewed byunauthorized persons. Information we collect automatically:We collect information about you automatically as younavigate through or use our Sites. Information collectedautomatically may include usage details, IP addresses,session replay and recording technology (recording yourmovements, clicks, etc. on our Sites), and informationcollected through cookies, web beacons, pixels tags, andother tracking technologies. As you navigate through andinteract with our Sites, we may use automatic datacollection technologies (such as session replay and trackingtechnologies referred to above) to collect certaininformation about your equipment, browsing actions, andpatterns, specifically: Usage Details. Details of yourvisits to our Sites, such as traffic data, location, logs,referring/exit pages, date and time of your visit to or useof our Sites, error information, clickstream data, and othercommunication data and the resources that you access and useon or in the Sites. Device Information. Information aboutyour computer, mobile device, and Internet connection,specifically your IP address, operating system, browsertype, and App version information. Location Data.Information about your location collected throughGeolocation technology. Varry Info applications andservices that run on mobile devices do not generally usegeolocation. However, the Varry Info app can collect anduse geolocation information only for the limited purpose offacilitating check-in to your scheduled appointment uponarrival. You may disable this functionality on your mobiledevice by removing permission for the Varry Info app touse location services at any time. The information wecollect automatically may include Personal Data or we maymaintain or associate information we collect with PersonalData we collect in other ways or receive from third parties.It helps us to improve our Sites and to deliver a better andmore personalized service by enabling us to: estimate ouraudience size and usage patterns; improve our product andservices offering; store information about your preferences,allowing us to customize our Sites according to yourindividual interests; and recognize and/or authenticate youwhen you return to our Sites. The technologies we use forthis automatic data collection may include: Cookies (orbrowser cookies). We and our service providers may usecookies, web beacons, and other technologies to receive andstore certain types of information whenever you interactwith our Sites through your computer or mobile device. Acookie is a small file or piece of data sent from a websiteand stored on the hard drive of your computer or mobiledevice. On your computer, you may refuse to accept browsercookies by activating the appropriate setting on yourbrowser, and you may have similar capabilities on yourmobile device in the preferences for your operating systemor browser. However, if you select this setting you may beunable to access or use certain parts of our Sites. Unlessyou have adjusted your browser or operating system settingso that it will refuse cookies, our system will issuecookies when you direct your browser to our Website or useour App. Pixels and Web Beacons. Pages on our Sites, or oure-mails, may contain small electronic files known as webbeacons (also referred to as clear gifs, pixel tags, andsingle-pixel gifs) that permit us, for example, to countusers who have visited those pages or opened an e-mail andfor other related Sites statistics (for example, recordingthe popularity of certain Sites content and verifying systemand server integrity). For example, we use Tealium, Inc.("Tealium"), to understand how users interact with ourSites. We use this information to assist us in improving ouruser experience. Google Analytics. We use Google Analytics,a web analytics service provided by Google, Inc. ("Google")to collect certain information relating to your use of ourSites. Google Analytics uses cookies, which are text filesplaced on your computer, to help our Sites analyze how usersuse the Sites. You can find out more about how Google usesdata when you visit our Sites by visiting "How Google usesinformation from sites or apps that use our services"(located athttps://policies.google.com/technologies/partner-sites). Wemay also use Google Analytics Advertising Features or otheradvertising networks to provide you with interest-basedadvertising based on your online activity. For moreinformation regarding Google Analytics please visit Google'swebsite, and pages that describe Google Analytics, such ashttps://marketingplatform.google.com/about/. Facebook Pixel.We use Facebook Pixel, a web analytics and advertisingservice provided by Facebook Inc. ("Facebook") on ourPlatform. With its help, we and our customers can keep trackof what users do after they see or click on a Facebookadvertisement, keep track of users who access our Platformor advertisements from different devices, and better provideadvertisements to our target audiences. The data fromFacebook Pixel is also saved and processed by Facebook.Facebook can connect this data with your Facebook orInstagram account and use it for its own and othersadvertising purposes, in accordance with Facebook's DataPolicy which can be found athttps://www.facebook.com/about/privacy/. Please click hereif you would like to withdraw your consent for use of yourdata with Facebook Pixelhttps://www.facebook.com/settings/?tab=ads#_=_. Do Not TrackSignals. Some web browsers permit you to broadcast a signalto websites and online services indicating a preference thatthey "do not track" your online activities. At this time, wedo not honor such signals; although, we currently do not useautomated data collection technologies to collectinformation about your online activities over time andacross third party websites or other online services for anypurpose, including advertising. Email communications,newsletter, and related services Our Sites provide you withthe opportunity to receive communications from us or thirdparties. For example, you can sign up for a free Varryhealth email newsletter. You can unsubscribe from thisnewsletter at any time. You may use the unsubscribemechanism or link in our marketing emails if you wish tostop receiving marketing emails from us. Emailcommunications that you send to us via the email links onour Site may be shared with a customer servicerepresentative, employee, medical expert, or agent that ismost able to address your inquiry. We make every effort torespond in a timely fashion once communications arereceived. Once we have responded to your communication, itis discarded or archived, depending on the nature of theinquiry. Note, that email communications that you send usvia the email links on our Site are not automaticallyencrypted, and it is possible that unencrypted emailcommunications with us may be accessed or viewed by anotherinternet user while in transit to us. Surveys Weoccasionally survey visitors to our site. The informationfrom these surveys is used in aggregated, de-identified formto help us understand the needs of our visitors so that wecan improve our site. The information may be shared withthird parties with whom we have a business relationship. Wegenerally do not ask for information in surveys that wouldpersonally identify you; if we do request contactinformation for follow-up, you may decline to provide it. Ifsurvey respondents provide personal information (such as anemail address) in a survey, it is shared only with thosepeople who need to see it to respond to the question orrequest, or with third parties who perform data managementservices for our site. Those third parties have agreed tokeep all data from surveys confidential. How we use theinformation we collect In addition to the uses describedabove, we use the information we collect for things like:Optimizing the performance and user experience of our sites;Operating, evaluating, and improving our business; Providinghealthcare services; Fulfilling purchases, orders, andrequests for products, services, or information on oure-commerce sites, including the Varry Info Store and Varryhealth Marketplace; Processing returns and exchanges fromour e-commerce sites, including the Varry Info Store andVarry Info Marketplace; Tracking and confirming onlineorders from our e-commerce sites, including the Varry InfoStore and Varry Info Marketplace; Delivering or installingproducts; Marketing and advertising products and services,including by inferring your interests from your interactionswith our websites and newsletters and tailoringadvertisements, newsletters, and offers to you (both on ourwebsites and on other websites) based on your interactionswith us in our stores and online interests; Sending youemail newsletters; Conducting research and analysis;Communicating with you about your account, special events,and surveys; and Establishing and managing your accountswith us. We may combine this information with any otherinformation we have about you, including, if you are a Varryhealth patient, any PHI we have about you. If we combinethis information with your PHI, we will treat all of thatinformation as PHI and will only use or disclose thatinformation as set forth in our Notice of Privacy Practices.

Data retention

We will retain your information for as long as your accountis active or as needed to provide you services, comply withour legal obligations, resolve disputes, and enforce ouragreements. You may request that we delete your data bycontacting us as provided below. However, we may not be ableto honor that request in all instances given the laws andregulations that apply to us. For example, under state andfederal law, we may be required to maintain some data thatis specific to you and that may identify you, such as yourmedical records or other information. We may also have alegal basis or obligation to maintain medical and otherinformation about you to provide care and treatment or tocomply with our professional, legal, and other obligations.

Disclosure of your information

We may share the information we collect about you with thirdparties who we have engaged to help us provide the Site, aswell as the products and services available through ourSite. In this regard, we may disclose your Personal Data toaffiliates, contractors, service providers, and other thirdparties we use to support our business. The servicesprovided by these organizations include providing IT andinfrastructure support services, advertising, marketing, andpayment processing services. Advertising and marketingpartners such as Facebook, Instagram, Google, and otheradvertising networks may receive and use your Personal Datato assist us with our advertising and marketing efforts. Ineach case, we will ensure that these third parties haveagreed to safeguard your data. Our partner, Everyday Health,may use a third-party ad network provider, such asCollective Media, to help present advertisements on thiswebsite. We may provide third parties with aggregatestatistics about our visitors, traffic patterns, and relatedsite information. These data reflect site-usage patternsgathered during visits to our website each month, but theydo not contain information that personally identifies youunless you have given us permission to share thatinformation. We may also disclose your Personal Data: to abuyer or other successor in the event of a merger,divestiture, restructuring, reorganization, dissolution, orother sale or transfer of some or all of our assets, whetheras a going concern or as part of bankruptcy, liquidation, orsimilar proceeding, in which Personal Data held by Varryhealth about our Sites users are among the assetstransferred; to fulfill the purpose for which you provideit; for any other purpose disclosed by us when you providethe information; with your consent; to comply with any courtorder, law, or legal process, including to respond to anygovernment or regulatory request; to affiliates to markettheir products or services to you if you have purchased oneof our products and if you have not opted out of thesedisclosures. For more information, see Choices About How WeUse and Disclose Your Information; to enforce or apply ourTerms of Use and other agreements, including for billing andcollection purposes; and if we believe disclosure isnecessary or appropriate to protect the rights, property, orsafety of Varry Info, our customers, or others. Thisincludes exchanging information with other companies andorganizations for the purposes of fraud protection andcredit risk reduction. Choices about how we use and discloseyour information We do not control third parties' use ofcookies or how they manage the information collected throughthe use of cookies. However, our sponsors and advertisershave agreed that they will not collect any personallyidentifiable information from our Site visitors while usingour Sites. These third parties may aggregate the informationthey collect with information from their other customers fortheir own purposes. In addition, we strive to provide youwith choices regarding the Personal Data you provide to us.We have created or you have available mechanisms to provideyou with control over your Personal Data: Cookie Settingsand Advertising. You can set your browser or operatingsystem to refuse all or some cookies or to alert you whencookies are being sent. If you disable or refuse cookies,please note that some parts of our Sites may then beinaccessible or not function properly. Promotional Offersfrom Varry Info. If you do not wish to have your emailaddress used by us to promote our own products and services,you can opt-out at any time by clicking the unsubscribe linkat the bottom of any email or other marketing communicationsyou receive from us or submitting a request to ourPreference Center. This opt-out does not apply toinformation provided to Varry Info as a result of aproduct purchase or your use of our services. If you wish toopt-out of such sharing, please email us atcustomerservice@mayopublications.com. Disclosure of YourInformation to Affiliates. By purchasing our products, youconsent to our sharing of your Personal Data with ouraffiliates for their promotional purposes. If you wish tounsubscribe from such affiliate promotions, you can do so byclicking the unsubscribe link at the bottom of any email orother marketing communications you receive from them. If youwish to opt-out of such sharing, please email us atcustomerservice@mayopublications.com. Targeted Advertising.To learn more about interest-based advertisements and youropt-out rights and options, visit the Digital AdvertisingAlliance and the Network Advertising Initiative (NAI)websites (www.aboutads.info and www.networkadvertising.org).Please note that if you choose to opt out, you will continueto see ads, but they will not be based on your onlineactivity. We do not control third parties' collection or useof your information to serve interest-based advertising.However, these third parties may provide you with ways tochoose not to have your information collected or used inthis way. You can also opt out of receiving targeted adsfrom members of the NAI on its website. Your rightsregarding your information and accessing and correcting yourinformation For non-patient information, you can Contact Usthrough the Contact Information below to access and/or findout what information we have about you and to correct thatinformation. You can also review and change your PersonalData by logging into our site and visiting either theSettings or Account Preferences sections. You may alsonotify us through the Contact Information below of anychanges or errors in any Personal Data we have about you toensure that it is complete, accurate, and as current aspossible or to delete your account. We cannot completelydelete your personal information except by also deletingyour account with us. We may not be able to accommodate yourrequest if we believe it would violate any law or legalrequirement or if we have a legal basis or obligation tomaintain it, or if it would cause the information to beincorrect. If you are a patient of Varry Info, you canaccess the patient-related information that we maintainabout you through Patient Online Services or through ourhealth information management department. For moreinformation about requesting your medical records, ask us orgo online to the Patient and Visitor Guide for the locationwhere you receive your care, then explore the release ofinformation options:http://www.mayoclinic.org/patient-visitor-guide. You alsocan request a correction to your patient information throughour Patient Online Services or health information managementdepartment. In our mobile app, you can request to deactivateyour account; however, we are still required maintain yourpatient-related information under the Health InsurancePortability and Accountability Act (HIPAA) and other federaland state law.

Security

Whether you are visiting the Varry Info Site or one of ourclinic locations, we use reasonable security measures toprotect the confidentiality of personal information underour control, and we appropriately limit access to it. We usea variety of information security measures to protect youronline transactions with us. The Varry Info Site usesencryption technology, such as Secure Sockets Layer (SSL),to protect your personal information during data transport.SSL protects information you submit via our website, such asordering information including your name, address, andcredit card number. That being said, Varry Info cannotensure or warrant the security of any information youtransmit to us, and you do so at your own risk. We havetaken reasonable steps to ensure the integrity andconfidentiality of personally identifiable information thatyou may provide. You should understand, however, thatelectronic transmissions via the internet are notnecessarily secure from interception, and so we cannotabsolutely guarantee the security or confidentiality of suchtransmissions. Users in the European Economic Area (EEA),the United Kingdom, and Switzerland If you are a resident ofthe EEA, the United Kingdom, or Switzerland, the followinginformation applies with respect to personal data collectedthrough your use of our Site. Purposes of processing andlegal basis for processing: As explained above, we processpersonal data in various ways depending upon your use of theservices. We process personal data on the following legalbases: (1) with your consent; (2) as necessary to providethe services; (3) to comply with our legal obligations; and(4) as necessary for our legitimate interests in providingthe services where those interests do not override yourfundamental rights and freedoms related to data privacy.Transfers: Personal data we collect may be transferred to,and stored and processed in, the United States or any othercountry in which we or our affiliates or processors maintainfacilities. We will ensure that transfers of personal datato a country or an international organization outside theEEA, the United Kingdom, or Switzerland are subject toappropriate safeguards. Your rights: You are entitled to therights under Chapter III of the EU General Data ProtectionRegulation, the United Kingdom General Data ProtectionRegulations and Data Protection Act 2018, or Section 2 ofthe Swiss Federal Act on Data Protection with respect to theprocessing of your personal data, which include the right toaccess and rectify and to request erasure of personal data.In order to verify your identity, we may require you toprovide us with personal information prior to accessing anyrecords containing information about you. To exercise theserights, please contact Mayo's Data Protection Officer atINTLcompliance@mayo.edu. Complaints or concerns: You arewelcome to raise any complaints or concerns to Varry Infoby contacting Mayo's Data Protection Officer atINTLcompliance@mayo.edu. You also have the right to lodge acomplaint with a supervisory authority. Protectingchildren's privacy Other than our Patient Online Services,our Sites are not intended for users under 18 years of age.No one under age 18 may provide any information to orthrough the Sites. We do not knowingly collect Personal Datafrom users under 18. If you are under 18, do not use orprovide any information on or in our Sites or on or throughany of their features, including your name, address,telephone number, email address, or any screen name orusername you may use. If we learn we have collected orreceived Personal Data from a user under 18 withoutverification of parental consent, we will delete thatinformation. If you believe we might have any informationfrom a user under 18, please contact us at the contactinformation below. Our Patient Online Services is availableto patients 18 years of age and older. It is also availableto patients who are between the ages of 13 years old and 17years old with the permission of their parents or legalguardians.

Links to other websitess

Our Sites link to other websites, many of which have theirown privacy policies. Be sure to review the privacy policyon the site you're visiting.

Privacy policy updates

We may need to update our Privacy Policy as technologychanges and Varry Info evolves. If we make significantchanges to this Privacy Policy, we'll post a prominentmessage on our websites.