Privacy Policy

Your privacy is important to us. This Privacy Policy explains how Virtual Software Inc. (“Virtual Software,” “we,” “us,” or “our”) collects, uses, stores, shares, and protects information when you use our website, mobile application, software, and related services, including the Virtual Software app.

Virtual Software helps users access and display certain healthcare-related information, including information made available through supported health plans, government programs, healthcare providers, APIs, or other authorized third-party sources. Our current purpose is to provide eligible users, including NCDHHS Medicaid members, a way to view healthcare data available to them.

This Privacy Policy applies to information we collect when you use Virtual Software. It does not apply to websites, services, health plans, healthcare providers, government agencies, or third-party applications that we do not own or control.

By using Virtual Software, you agree to this Privacy Policy. If you do not agree, please do not use our Services.

1. Information We Collect

We collect information only when we have a reason to do so, such as providing the Services, verifying your identity, helping you access your data, communicating with you, maintaining security, or improving the Services.

We may collect information from three main sources:

1. information you provide to us;

2. information collected automatically when you use the Services; and

3. information received from third parties with your authorization or as needed to provide the Services.

2. Information You Provide to Us

You may provide information directly to us when you create an account, contact us, request support, complete forms, update your profile, give consent, or otherwise use the Services.

This information may include:

• name;

• email address;

• phone number;

• mailing address;

• date of birth;

• login credentials;

• account preferences;

• communications with us;

• support requests;

• consent records;

• any other information you choose to provide.

If you do not provide information that is necessary to operate the Services, some features may be limited or unavailable.

3. Health Information and Permission to Store Data

Virtual Software may collect, receive, store, display, or process health-related information when you use the Services.

This may include information related to:

• health coverage;

• Medicaid or insurance membership;

• healthcare claims;

• benefits;

• providers;

• visits;

• diagnoses;

• medications;

• procedures;

• lab results;

• care history;

• payment for healthcare;

• other records made available by supported health data sources.

We refer to this information in this Privacy Policy as “Health Information.”

Virtual Software will only store your Health Information when you give us permission to do so or when storage is necessary to provide a feature you request. If you do not give us permission to store Health Information, some features of the Services may be limited or unavailable.

You may revoke permission, request deletion of your data, or delete your account at any time as described in this Privacy Policy.

We use Health Information to provide the Services to you, including displaying your healthcare data in the Virtual Software app. We do not use Health Information to provide medical advice, diagnosis, treatment, insurance advice, benefits decisions, or emergency services.

4. Information We Collect Automatically

When you use our website, app, or Services, we may automatically collect certain technical and usage information, such as:

• IP address;

• device type;

• browser type;

• operating system;

• app version;

• device identifiers;

• access dates and times;

• pages or screens viewed;

• features used;

• crash logs;

• diagnostic information;

• general location inferred from IP address;

• referral information;

• security logs.

We use this information to operate, secure, troubleshoot, analyze, and improve the Services.

5. Cookies and Similar Technologies

Our website or Services may use cookies, pixels, local storage, software development kits, or similar technologies.

These technologies may help us:

• keep you signed in;

• remember preferences;

• understand how users interact with the Services;

• improve performance;

• detect fraud or abuse;

• secure the Services.

You may be able to control cookies through your browser settings. If you disable cookies or similar technologies, some parts of the Services may not work properly.

6. Information From Third Parties

We may receive information about you from third parties when needed to provide the Services or when you authorize a connection.

These third parties may include:

• health plans;

• healthcare providers;

• Medicaid or government program systems;

• health information exchanges;

• API providers;

• identity verification services;

• authentication providers;

• cloud hosting providers;

• analytics or security providers;

• customer support tools;

• other service providers that help us operate Virtual Software.

Third parties may have their own privacy policies, terms, and security practices. We are not responsible for the privacy practices of third parties we do not control.

7. How We Use Information

We may use information we collect to:

• create and maintain your account;

• verify your identity;

• connect you to supported health data sources;

• retrieve, organize, store, and display your Health Information when authorized;

• provide, operate, maintain, and improve the Services;

• respond to your requests and support questions;

• communicate with you about your account or the Services;

• send important notices, including security or policy updates;

• troubleshoot errors and technical issues;

• monitor and improve performance;

• detect, investigate, and prevent fraud, misuse, unauthorized access, security incidents, or illegal activity;

• comply with legal, regulatory, contractual, or compliance obligations;

• enforce our Terms of Service;

• protect the rights, safety, and property of Virtual Software, our users, and others;

• create de-identified or aggregated information that does not reasonably identify you.

We do not use your Health Information to make medical decisions for you.

8. No Sale of Health Information

We do not sell your Health Information.

We do not sell, rent, license, or trade your personal information or Health Information to third parties for their own direct marketing purposes.

If we ever make a material change to how we use or share Health Information, we will update this Privacy Policy and, where required, obtain your consent.

9. Sharing Information

We share information only in limited circumstances.

With your consent or at your direction

We may share information when you authorize us to do so, such as when you connect your account to a health data source, direct us to retrieve your records, or request that we share information with another party.

With service providers

We may share information with companies that help us operate the Services, such as cloud hosting providers, security vendors, analytics providers, customer support tools, identity verification providers, and professional advisors.

These service providers may access information only as needed to perform services for us and are expected to protect the information they process.

With health data sources

When you request that we connect to or retrieve data from a health plan, provider, government program, or other source, we may share information needed to authenticate, authorize, process, or complete that request.

For legal and safety reasons

We may disclose information if we believe disclosure is reasonably necessary to:

• comply with law, regulation, subpoena, court order, legal process, or government request;

• protect against fraud, abuse, security threats, or illegal activity;

• protect the rights, property, or safety of Virtual Software, users, or others;

• enforce our agreements;

• investigate potential violations.

Business transfers

If Virtual Software Inc. is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, information may be transferred as part of that transaction. We will make reasonable efforts to ensure that your information remains protected consistent with this Privacy Policy.

De-identified or aggregated information

We may use or share information that has been de-identified or aggregated so that it does not reasonably identify you. For example, we may use aggregated statistics to understand app performance, improve features, or evaluate usage trends.

10. Your Choices and Rights

You control important choices regarding your information.

Depending on where you live and how you use the Services, you may have the right to:

• access information we maintain about you;

• request a copy of your information;

• correct inaccurate information;

• delete certain information;

• withdraw consent where processing is based on consent;

• close your account;

• opt out of certain communications;

• restrict or object to certain processing;

• request information in a portable format.

You may delete your account from inside the Virtual Software app. You may also ask us to delete your data at any time by contacting us at [Insert privacy email].

We may need to verify your identity before responding to your request. Some information may be exempt from deletion if we need to retain it for legal, security, fraud prevention, audit, regulatory, backup, or compliance purposes.

11. Account Deletion and Data Retention

You may delete your account from inside the Virtual Software app. You may also request deletion of your account or data by contacting us at [Insert privacy email].

When you delete your account or request deletion of your data, we will delete or de-identify personal information and Health Information associated with your account, unless we need to retain certain information for legitimate business, legal, security, audit, regulatory, backup, or compliance purposes.

We may retain certain limited records, such as access logs, consent records, disclosure logs, security logs, deletion records, or transaction records, where necessary to comply with law, resolve disputes, enforce agreements, investigate abuse, maintain security, or demonstrate compliance.

Deletion requests apply going forward and may not remove information that has already been lawfully disclosed to third parties at your direction or information retained in legally required records.

We keep information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

12. Security

We use reasonable administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, disclosure, alteration, or destruction.

These safeguards may include encryption, access controls, monitoring, authentication, logging, security reviews, and vendor management.

However, no method of transmission or storage is completely secure. We cannot guarantee absolute security of information transmitted to or stored by the Services.

You are responsible for protecting your account credentials and for using secure devices and networks when accessing Virtual Software.

13. Security Incidents

If we determine that your information has been involved in a security incident requiring notice under applicable law, we will notify you and any required regulators or other parties as required by law.

Because health apps may be subject to federal or state breach notification requirements, we will evaluate incidents based on the type of information involved, our legal role, and applicable laws.

14. HIPAA and Health Privacy Laws

Virtual Software may handle health-related information. Depending on how the Services are used, some information may be subject to HIPAA or other federal or state health privacy laws.

Virtual Software is not automatically a HIPAA covered entity simply because it displays health information. In some situations, we may act as a business associate or service provider to a covered entity, health plan, provider, government program, or other organization. In other situations, we may provide Services directly to you at your request.

Where HIPAA applies to our Services, we will comply with applicable HIPAA Privacy, Security, and Breach Notification Rule requirements, including any required business associate agreements, safeguards, use and disclosure limits, and breach notification obligations.

Where HIPAA does not apply, we will still protect your Health Information according to this Privacy Policy and applicable laws.

This Privacy Policy does not replace any Notice of Privacy Practices provided by your health plan, healthcare provider, government program, or other covered entity.

15. No Medical Advice

Virtual Software does not provide medical advice, diagnosis, treatment, insurance advice, benefits decisions, or emergency services.

Any Health Information displayed through the Services is provided for informational and access purposes only. You should contact a qualified healthcare provider, health plan, government program, or other appropriate source for questions about your health, treatment, coverage, benefits, or records.

If you believe you are experiencing a medical emergency, call 911 or seek immediate medical attention.

16. Third-Party Links and Services

The Services may contain links to third-party websites, services, or resources. This Privacy Policy does not apply to third-party websites or services.

If you use a third-party service, your information may be collected, used, or shared according to that third party’s privacy policy and terms. We encourage you to review those policies before using third-party services.

17. Children’s Privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13.

If we learn that we have collected personal information from a child under 13 without appropriate consent, we will take reasonable steps to delete it.

If you believe a child has provided information to us, contact us at [Insert privacy email].

18. Communications

We may send you service-related communications, such as account notices, security alerts, verification messages, policy updates, and support responses. These communications are necessary for the Services and you may not be able to opt out of them while maintaining an account.

We may also send optional marketing or informational communications. You may opt out of marketing emails by following the unsubscribe instructions or contacting us.

19. International Users

Virtual Software is operated from the United States. If you access the Services from outside the United States, your information may be transferred to, stored in, or processed in the United States or other countries where our service providers operate.

Data protection laws in those countries may differ from the laws where you live.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make changes, we will update the “Last Updated” date above. If changes are material, we may provide additional notice, such as through the app, website, email, or another reasonable method.

Your continued use of the Services after an updated Privacy Policy becomes effective means you accept the updated Policy.

21. Contact Us

If you have questions about this Privacy Policy or want to exercise your privacy rights, contact us at:

Virtual Software Inc.

Email: info@myvirtualsoftware.com