Effective Date: May 14, 2025
Last Updated: May 14, 2025
IMPORTANT NOTICE: This Privacy Policy applies to Vaulted Vitality, a division of Etsell Health Services LLC (“Company,” “we,” “us,” or “our”). We are committed to protecting your privacy and safeguarding your health information in compliance with the Health Insurance Portability and Accountability Act (HIPAA), the Telephone Consumer Protection Act (TCPA), applicable state SMS privacy laws, and all other relevant federal and state regulations. Please read this policy carefully.
1. Scope and Applicability
This Privacy Policy applies to all personal information and protected health information (PHI) collected through:
The Vaulted Vitality website and any associated web portals or mobile applications
Phone, SMS/text messaging, email, and in-person interactions
Online intake forms, scheduling systems, and health questionnaires
Any other services provided by Vaulted Vitality or Etsell Health Services LLC
2. Information We Collect
2.1 Personal Information
We may collect the following categories of personal information:
Name, date of birth, gender, and contact details (address, phone number, email)
Account credentials and login information
Payment and billing information
IP address, browser type, device identifiers, and website usage data
Communications you send us, including messages and support requests
2.2 Protected Health Information (PHI)
As a HIPAA-covered entity operating within Etsell Health Services LLC, we collect and process Protected Health Information (PHI), which may include:
Medical history, diagnoses, conditions, and treatment records
Prescription and medication information
Lab results, vitals, and clinical notes
Health insurance information and member/subscriber IDs
Information you provide in health intake forms or questionnaires
Any other information that identifies you and relates to your past, present, or future health
2.3 SMS and Communications Data
When you opt in to receive text messages from us, we collect your mobile phone number, message content, opt-in/opt-out status, and message delivery records.
3. How We Use Your Information
3.1 Treatment, Payment, and Healthcare Operations (HIPAA)
Under HIPAA, we may use and disclose your PHI without separate authorization for the following purposes:
Treatment: To provide, coordinate, and manage your healthcare and related services
Payment: To bill and collect payment for services rendered, including insurance claims
Healthcare Operations: For quality improvement, staff training, audits, and business operations
3.2 General Business Purposes
We use your personal information to:
Respond to your inquiries and provide customer support
Process appointments, registrations, and service requests
Send appointment reminders, health updates, and administrative communications
Improve our website, services, and user experience
Comply with legal obligations and enforce our terms
3.3 SMS and Text Messaging
With your express written consent, we use your phone number to:
Send transactional messages: appointment reminders, confirmations, billing notices, and care instructions
Send marketing messages: promotions, wellness tips, new service announcements, and special offers
4. SMS / Text Message Communications — Your Rights & Disclosures
■ Message and data rates may apply. Message frequency may vary.
4.1 Opt-In
You may opt in to receive SMS messages from Vaulted Vitality by:
Checking an opt-in box on our website or intake forms
Texting a designated keyword to our short code or long code number
Providing verbal or written consent during an appointment or intake call
By opting in, you expressly consent to receive both transactional and (if separately selected) marketing text messages from Vaulted Vitality / Etsell Health Services LLC at the phone number you provide, using automated or manually dialed technology.
4.2 Opt-Out
You may opt out of SMS communications at any time by:
Replying STOP to any text message you receive from us
Contacting us at the email or phone number listed in Section 10
Submitting a written opt-out request through our website
After opting out, you will receive one final confirmation message. You will not receive further marketing or transactional SMS messages unless you opt back in. Note: opting out of marketing texts does not opt you out of legally required or HIPAA-permitted treatment-related communications where no alternative method is specified.
4.3 Help
At any time, you may reply HELP to any SMS message to receive assistance and our contact information.
4.4 No PHI via SMS
We do not transmit Protected Health Information (PHI) via standard SMS/text message. Appointment reminders and health-related transactional messages will reference scheduling or administrative details only and will not include clinical diagnoses, treatment details, or other sensitive PHI unless delivered through a HIPAA-compliant encrypted messaging channel with your explicit consent.
4.5 Third-Party Carriers
Mobile carriers are not liable for delayed or undelivered messages. Message frequency depends on your interaction with our services and your selected preferences.
5. HIPAA — Protected Health Information
5.1 Your HIPAA Rights
As a patient or member, you have the following rights regarding your PHI under HIPAA:
Right to Access: Request copies of your health records in a designated format
Right to Amend: Request corrections to inaccurate or incomplete PHI
Right to an Accounting of Disclosures: Receive a list of certain disclosures of your PHI
Right to Request Restrictions: Ask us to limit how we use or disclose your PHI
Right to Confidential Communications: Request we contact you in a specific way (e.g., call only your cell)
Right to a Notice of Privacy Practices: Receive this policy or our full HIPAA Notice of Privacy Practices
Right to File a Complaint: File a complaint with us or with the U.S. Department of Health and Human Services (HHS) if you believe your rights have been violated — we will not retaliate
5.2 Permitted Disclosures of PHI
We may disclose your PHI without your authorization only as permitted by HIPAA, including:
To treating providers and care coordination partners
To your health insurer or payer for billing and payment purposes
As required by law (e.g., public health reporting, court orders, law enforcement)
To Business Associates who provide services on our behalf under a signed Business Associate Agreement (BAA)
In response to a serious threat to health or safety
5.3 Authorizations
All other uses and disclosures of your PHI not described above require your written authorization. You may revoke such authorization at any time in writing, and we will cease using your PHI for that purpose, except to the extent we have already acted in reliance on it.
5.4 Data Security
We implement administrative, physical, and technical safeguards required by HIPAA’s Security Rule to protect your electronic PHI (ePHI), including:
Encrypted data storage and transmission (TLS/SSL)
Access controls and user authentication protocols
Regular security risk assessments and workforce training
Audit controls and activity logging
Business Associate Agreements with all applicable third-party vendors
6. How We Share Your Information
We do not sell your personal information or PHI. We may share your information with:
Business Associates: Vendors and service providers (billing, IT, analytics) operating under HIPAA-compliant BAAs
Healthcare Providers: Other treating clinicians involved in your care
Insurance Companies and Payers: For claims processing and payment
Legal Authorities: When required by law, subpoena, or to protect rights and safety
SMS Platform Providers: To transmit text messages on our behalf (no PHI transmitted)
Marketing Platforms: For non-PHI marketing communications, only with your consent
We require all third parties to maintain appropriate confidentiality and security protections for any data they handle on our behalf.
7. Cookies and Online Tracking
Our website may use cookies, pixels, and similar tracking technologies to improve functionality and analyze usage. These technologies collect non-PHI data such as browser type, pages visited, and session duration.
You may manage cookie preferences through your browser settings. Disabling cookies may limit certain website functionality. We do not use tracking technologies that capture PHI on our website.
8. Data Retention
We retain PHI and medical records in accordance with applicable state law and HIPAA requirements — typically a minimum of six (6) years from the date of creation or last effective date. Non-PHI personal information is retained only as long as necessary for the purposes described in this policy or as required by law. Upon expiration of the applicable retention period, data is securely destroyed or de-identified.
9. Children’s Privacy
Our services may be provided to minors with the consent of a parent or legal guardian. PHI for minors is handled in accordance with HIPAA and applicable state minor consent laws. We do not knowingly collect personal information from children under 13 for marketing purposes without verifiable parental consent, consistent with COPPA requirements.
10. Contact Us & Submitting Requests
To exercise any of your rights, submit a request, or ask questions about this Privacy Policy, contact our Privacy Officer:
Company: Vaulted Vitality — A Division of Etsell Health Services LLC
Mailing Address: [Insert Address]
Phone: [Insert Phone Number]
Email: [Insert Privacy/Compliance Email]
Website: [Insert Website URL]
To file a HIPAA complaint with the federal government:
U.S. Department of Health and Human Services, Office for Civil Rights: https://www.hhs.gov/ocr/privacy/hipaa/complaints
11. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy at any time. Material changes will be communicated via notice on our website and, where required by HIPAA, a revised Notice of Privacy Practices will be made available. The effective date at the top of this document reflects the most recent revision. Your continued use of our services after changes are posted constitutes acceptance of the revised policy.
12. Governing Law
This Privacy Policy is governed by the laws of the State of [Insert State] and applicable federal law, including HIPAA (45 C.F.R. Parts 160 and 164), the TCPA (47 U.S.C. § 227), the CAN-SPAM Act, and all applicable FCC and FTC regulations. Where state law affords greater privacy protections than federal law, state law shall control.
Your Agreement to This Policy
By accessing or using the Vaulted Vitality website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this policy, please do not use our website or services.
For SMS communications, your consent is collected separately at the point of opt-in (such as a checkbox on a web or intake form) and is not implied merely by visiting this page.