My Hungry Head

Effective date: March 1, 2024

limitations. Please note that, if you disable or remove cookies on
your device, some parts of our Site or other aspects of our
Services may not function properly.
Embedded Scripts. An embedded script is programming code
designed to collect information about your interactions with the
Site, the Apps, and other aspects of our Services, such as a link
that you may click on. Embedded scripts are temporarily
downloaded onto your device. Embedded scripts remain active
only while you are connected to the Services and are then
deactivated or deleted.
Web Beacons. The Services may also include small graphic
images or other web programming code called “web beacons”
(also known as “1×1 GIFs” or “clear GIFs”). Any electronic
image or other web programming code inserted into a page or
email can act as a web beacon, and web beacons may be
invisible to you. Web beacons and similar technologies may be
used for a number of purposes, including to count visitors to the
Services, to count how many sent emails were opened, to count
how many articles or links were viewed, or to monitor how users
navigate the Services.

WHO OWNS THE PERSONAL INFORMATION YOU
DISCLOSE TO COMPANY?
You retain all ownership or license rights that you possess in
your User Submissions (including any Personal Information and
PHI), provided that when you use the Services or otherwise
disclose or authorize others to disclose any User Submissions to
us, you grant us a license to those User Submissions as
described in our Terms of Use and this Privacy Policy.

WHAT PERSONAL INFORMATION DO WE SHARE?
The following sections describe certain circumstances when we
may share your Personal Information:

Communications in Response to User Submissions:
As part of the Services, you will receive from us email or text
messages and other communications relating to your User
Submissions. By posting User Submissions, you acknowledge
and agree that we may send you email and other
communications that we determine in our sole discretion relate
to your User Submissions.

Reporting to Sponsors and Third-Party Administrators:
We may, in our sole discretion, share, transfer, or otherwise
disclose certain of your Protected Health Information to entities
that are authorized to receive that information for legally
permitted purposes under HIPAA, which may include the
companies paying for your participation in an My Santa Via
Program. This type of sharing is described in more detail in our
BAA agreements with other covered entities. We only share
your Protected Health Information in accordance with HIPAA
and other applicable legal requirements.

Information Available to App Providers:
By downloading any of the Apps from an App Provider, such as
the Apple App Store or Google Play, please note that the App
Provider and its agents may be able to identify you as a user of
our Services.
Our Business Transfers
We reserve the right to disclose and transfer all Personal
Information to an operator of the Site or of any of the Apps or
applicable databases, provided that the operator agrees to be
bound by the applicable terms and conditions of this Privacy
Policy. We also reserve the right to disclose and transfer all
Personal Information to a successor in interest of My Santa Via
in connection with a merger, consolidation, restructuring, or
change of control, the sale of substantially all of our interests
and/or assets, or another organizational change (including during
the course of any due diligence process), provided that the
successor entity agrees to be bound by the terms and conditions
of this Privacy Policy.

Protection of My Santa Via and Others:
We may release your Personal Information when we believe in
good faith that releasing that information is necessary to comply
with applicable law, to enforce our conditions of use and other
agreements, or to protect the rights, property, or safety of My
Santa Via, our employees, our users, or others. We may
exchange information with other companies and organizations to
detect, suppress, or protect against fraud and for credit risk
reduction. If necessary and required by law, we will disclose any
breach of the security, confidentiality, or integrity of your
Personal Information, including, without limitation, breaches of
your unencrypted, electronically stored “personal information”
or “medical information” (as defined by applicable laws). To the
extent permitted by applicable laws, we may make these
disclosures to you via email or a conspicuous posting on your
private profile in the Services in the most expedient time
possible and without unreasonable delay, so long as this is
consistent with the legitimate needs of law enforcement and any
other measures necessary to determine the scope of the breach
and restore the reasonable integrity of the data system.

De-identified Data:
As described in our Terms of Use, we may de-identify the User
Submissions that you share with us, including any Personal
Information, or otherwise process them so that they are no
longer attributable to you without additional information (“De-
identified Data”). We may use that De-identified Data without
restriction in any way allowed by law. For example, we might
use De-identified Data to understand, evaluate, or modify the
Services, to generate statistical information about the Services
that we share with our customers and other third parties who are
evaluating, analyzing, accrediting, or researching My Santa
Via's programs, or for our other business purposes. When an
applicable law requires that we use a particular method of de-
identifying data or rendering it no longer attributable to you, we
will comply with that law. Otherwise, we may use a method that
is appropriate under the circumstances and would not reasonably
identify you.

IS MY PERSONAL INFORMATION SECURE?
We employ industry-standard administrative, physical, and
technical measures designed to safeguard and protect
information under our control from unauthorized access, use,
and disclosure. In addition, when we collect, maintain, use,
disclose, and process your Personal Information, we will do so
using systems and processes consistent with the information
privacy and security requirements of applicable federal and state
laws, including HIPAA.
Your individual user account is also protected by a password for
your privacy and security. To help avoid unauthorized access to
your account and Personal Information, we suggest that you
safeguard your password appropriately, limit access to your
devices and browsers, and sign off after you have finished
accessing your account.
In addition, to the extent that you use one of the Apps and your
device permits that App to send you push notifications, we may
send you push notifications that include Personal Information
and, in limited instances, PHI that is not encrypted. Depending
on your device settings, push notifications may be visible to
other people who encounter your device. In most cases, you can
opt out of receiving push notifications by adjusting the settings
on your device. To the extent that you do not opt of receiving
push notifications, you agree to receive push notifications and to
be responsible for the security and confidentiality of any
information displayed in push notifications on your devices.
We exercise great care to protect your Personal Information.
However, we cannot ensure the security or confidentiality of any
Systems or Connections that you use to transmit information to
us. For example, we cannot ensure that your email or your
mobile phone or any other personal device is secure. In addition,
communication lines used to transmit emails and text messages
do not have the same security features that are built into our
Services. For more information on your Systems and
Connections, please review the Terms of Use.
Although we take great care to protect your Personal
Information, we cannot guarantee that criminals or others acting
unlawfully will not succeed in efforts to undermine our security
measures. Unauthorized entry to, access to, or use of our
systems or locations, hardware or software failure, loss, and
other factors may compromise the security of your information
at any time.
If you have reason to believe that your data or your interactions
with us are no longer secure or if you have questions related to
privacy or data security, you may contact us in any of the
manners described at the end of this Privacy Policy.

WHAT PERSONAL INFORMATION CAN I ACCESS
AND CORRECT?
If you have an account with us to receive one of the My Santa
Via services, you can access certain information about you
described below through the App or otherwise through the My
Santa Via service in order to view, and in certain situations,
update that information. This list may change as the Services
change.
• User email address
• Password
• Communication preferences (e.g., email and push
notifications)
• Tracking data on weight, body composition, diet,
medications, symptoms, exercise, sleep, mood, and other.
In order to help us maintain your information and ensure that it
is accurate and up to date, please update your information if it
changes or inform us promptly in any of the manners described
at the end of this Privacy Policy so that we can make the
appropriate changes. When you update information, we often
maintain a copy of the unrevised information in our records.

WHAT RIGHTS AND CHOICES DO I HAVE
REGARDING MY PERSONAL INFORMATION?
Choosing Not to Disclose
You may choose not to disclose information to us, even though
that information may be required to take advantage of certain
features of the Services.
Requesting Information
You also have the right to request certain information from us,
specifically:
• a copy of the Personal Information that we collect from
you,
• a description of the specific pieces of Personal Information
that we collect from you,
• a description of the categories of Personal Information that
we collect from you (which you can find in this Privacy
Policy),
• a description of the sources of Personal Information that we
collect from you (which you can find in this Privacy
Policy), and
• a description of the purposes for which we gather Personal
Information from you (which you can find in this Privacy
Policy and in our Notice of HIPAA Privacy Practices).
You also have rights concerning our access to and use of your
Protected Health Information.
For your convenience and to avoid any need to request this
information from us, we have confirmed in this Privacy Policy
that we will not rent or sell your Personal Information.
To request information from us or to obtain additional
information and instructions for exercising your rights to obtain
information, please contact us in any of the manners described at
the end of this Privacy Policy.
Unsubscribing from Communications
You may unsubscribe from communications from us, but please
keep in mind that, by opting out of further communications after
you enroll in a My Santa Via service, you may limit program
reminders and other valuable program content and components.
In addition, even if you do not want to receive legal notices from
us, such as this Privacy Policy, those legal notices will still
govern your use of the Services, and you are responsible for
reviewing legal notices for changes. When you receive an email
from us, you can opt out of receiving further emails by
following the included instructions to unsubscribe. If you would
like assistance in unsubscribing from email communications you
may indicate this preference by contacting us in any of the
manners described at the end of this Privacy Policy. We will
process your request within a reasonable time, but please note
that you may receive additional emails as we process your
request.
Deleting Your Personal Information
You have the right to request deletion or restriction of your
personal data processed by us. Even if you stop using our
Services for any reason, we will protect your User Submissions
and other Personal Information in accordance with our Terms of
Use and this Privacy Policy as if you were still using the
Services.

HOW CAN WE CHANGE THIS PRIVACY POLICY?
We may prospectively change or replace any terms of this
Privacy Policy at any time and for any reason at our discretion.
We will post the most recent version of this Privacy Policy on
our Sites and in the Apps, and any changes to this Privacy
Policy will become effective when posted. Use and disclosure of
information that we collect is subject to the Privacy Policy in
effect at the time the information is disclosed to us. You are
responsible for checking this Privacy Policy periodically for
changes. If we change or replace any terms of this Privacy
Policy in a manner that meaningfully reduces your rights, we
will notify you and designate a reasonable time period before the
new terms will take effect. By continuing to use or access the
Services after any changes come into effect, you agree to be
bound by the updated Privacy Policy. If you disagree with any
changes, you must stop using the Services.

HOW CAN YOU CONTACT US WITH QUESTIONS OR
CONCERNS?
If you have any questions or concerns regarding this Privacy
Policy or My Santa Via's privacy practices or if you would like
to request to access or correct your Personal Information, please
contact by email at [email protected].
We will make every effort to respond to your questions,
concerns, and requests within a reasonable time.

Effective Date: 3/1/24