Legal Notices

This Privacy Policy applies to Vynca (“we,” “us,” or “our”), which operates this website and related applications (“Services”) and describes how we collect, use, and disclose personal information. It is prepared in accordance with multiple legislations, including Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”) and the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (together, “CCPA/CPRA”).

By using the Services, you agree to the practices described herein.

HIPAA Notice

In addition to this Privacy Policy, Vynca maintains a separate Notice of Privacy Practices that describes how we use and disclose protected health information (PHI) in accordance with the Health Insurance Portability and Accountability Act (HIPAA). 

Types of Data Collected

Among the types of Personal Data that the Services collects, by itself or through third parties, are: cookies; usage data; email address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using the Services.

Unless specified otherwise, all Data requested by the Services is mandatory and failure to provide this Data may make it impossible for the Services to provide its services. In cases where the Services specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact Vynca.

Any use of Cookies or other tracking tools by the Services, or by Vynca’s authorized third-party providers, is for the purpose of delivering the requested service to the User and for the additional purposes described in this Privacy Policy. You can manage your cookie preferences at any time by selecting the “Cookie Settings” link on our website, which allows you to adjust or withdraw consent to non-essential cookies.

Users are responsible for any third-party Personal Data obtained, published or shared through the Services and confirm that they have the third party’s consent to provide the Data to Vynca.

Categories of Personal Data (CCPA/CPRA Disclosure)

In the past 12 months, the following categories of Personal Data (as defined by the CCPA/CPRA) may have been collected:

• Identifiers: name, email address, IP address, cookies, unique identifiers.
• Customer Records: account information, billing/contact data.
• Internet or Network Activity: browsing history, interactions with the Services, Usage Data collected by Google Analytics.
• Geolocation Data: approximate location from device/IP, if enabled.
• Commercial Information: records of services purchased or used.
• Inferences: drawn from other Personal Data to create a profile reflecting preferences or interests.

We collect “sensitive personal information,” such as health-related data, only when necessary to provide our services. We do not use sensitive personal information for marketing or advertising purposes.

Mode and Place of Processing the Data

Methods of Processing
Vynca takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of the Data. Processing is carried out using computers and IT-enabled tools, following organizational procedures strictly related to the purposes indicated.

Authorized Personnel and Service Providers
In addition to Vynca, Data may be accessible to persons involved with the operation of the Services (administration, sales, marketing, legal, system administration) or external parties (e.g., hosting providers, analytics providers, communications agencies) appointed as Data Processors. An updated list of these parties may be requested from Vynca at any time.

Legal Basis of Processing

Vynca may process Personal Data relating to Users if one of the following applies:

• Users have given consent for one or more specific purposes.
• Provision of Data is necessary for the performance of an agreement with the User.
• Processing is necessary for compliance with a legal obligation.
• Processing is necessary for purposes of legitimate interests pursued by Vynca or by a third party.

(For California users, processing of Personal Data is aligned with the “business purposes” and “commercial purposes” defined in the CCPA/CPRA.)

Purposes of Processing

Data concerning the User is collected to allow Vynca to provide its Services, as well as for the following purposes:

• Analytics and service optimization.
• Managing contacts and sending messages.
• Advertising, remarketing, and behavioral targeting.
• Security, fraud prevention, and compliance with law.

Disclosure of Personal Data

Personal Data may be disclosed to service providers, contractors, or business partners solely for the purposes described in this Privacy Policy.

We do not sell Personal Data in exchange for money. However, the use of analytics, cookies, and remarketing services may constitute “sharing” of Personal Data for cross-context behavioral advertising under the CCPA/CPRA. Users in California have the right to opt out of such sharing.

Retention Time

Personal Data shall be processed and stored for as long as required by the purposes collected. Once the retention period expires, Personal Data will be deleted.

Detailed Information on the Processing of Personal Data

Analytics (Google Analytics)

We use Google Analytics, a web analytics service provided by Google LLC. Google Analytics collects information such as your IP address, device identifiers, browser type, interactions with our site, and usage patterns. This information is used to understand how visitors use our website, improve performance, and support outreach.

We have configured Google Analytics to limit data sharing and retention, and we do not use it in any way that would allow the collection of protected health information (PHI). Google may process the collected data in the United States or other locations.

Under the CCPA/CPRA, information collected by Google Analytics may constitute “personal information” and, when linked with advertising services, may be considered “sharing” for cross-context behavioral advertising. You may opt out of analytics tracking by adjusting your cookie preferences or enabling a Global Privacy Control (GPC) signal.

For more information, please see the Google Privacy Policy and Google’s explanation of how it uses information from sites and apps.

Managing Contacts and Communications (HubSpot)

We use HubSpot, Inc. to manage email communications, customer relationship management, and certain website interactions (such as contact forms or newsletter sign-ups). HubSpot may collect information such as your email address, contact details, and usage data (e.g., when you open or click on emails).

This information is used solely to communicate with you, manage subscriptions, and improve our outreach. HubSpot processes this data as our service provider and is contractually prohibited from using your personal information for any purpose other than providing services to us.

For details on HubSpot’s practices, see the HubSpot Privacy Policy.

Rights of Users

GDPR Rights (for EU/EEA users)

Users in the EU/EEA may exercise the following rights: access, rectification, erasure, restriction, data portability, objection, and withdrawal of consent.

CCPA/CPRA Rights (for California residents)

California residents have the following rights:

• Right to Know/Access: Request disclosure of the categories and specific pieces of Personal Data collected, used, disclosed, or shared.
• Right to Delete: Request deletion of Personal Data, subject to exceptions.
• Right to Correct: Request correction of inaccurate Personal Data.
• Right to Opt-Out of Sale/Sharing: Direct us not to “sell” or “share” Personal Data for cross-context behavioral advertising.
• Right to Limit Sensitive Personal Information: If applicable.
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights.

How to Exercise Rights

Users may exercise their rights by contacting Vynca via:

• Email: privacy@vyncacare.com
• Toll-Free Telephone:1-888-227-8884

We will verify your identity before fulfilling requests. Authorized agents may also act on behalf of consumers with proper authorization.

How Opt-Out and “Do Not Track” Requests Are Handled

The Services does not respond to “Do Not Track” (DNT) signals, which are not standardized.
However, in accordance with the CCPA/CPRA, the Services does recognize and honor Global Privacy Control (GPC) signals as valid opt-out requests to stop the “sale” or “sharing” of Personal Data.

Users may also exercise their opt-out rights through the “Do Not Sell or Share My Personal Information” link on our website or by contacting us using the methods described above.

Changes to this Privacy Policy

Vynca reserves the right to make changes to this Privacy Policy at any time. Users will be notified of changes by updating the “effective date” below.

Version: 2.0 Effective Date: September 18, 2025