VITAL Hub Health Start2 Partnership Privacy Policy
Last updated: January 6, 2026

This Privacy Policy describes the personal information that Start2 Group, Inc. (“Start2,” “we” or “us”) collects when you visit the websites we host on behalf of our government partners (collectively, the “Services”). This Privacy Policy also describes how we use and share that information, the choices you have, and how you can contact us if you have questions or concerns.

This Privacy Policy does not apply to information we collect independently through the Start2 Group website, https://www.start2.group/privacy-policy. Such information is governed by our Start2 Group Privacy Policy.

Personal Information We Collect

Information you provide to us may include:

• Contact details, such as your company’s name, your first and last name, email address, state, and phone number, if you choose to provide this information.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
• Marketing information, such as your preferences for receiving communications about our services, and details about how you engage with our communications.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, such as:

• Device data, such as your computer’s or mobile device’s operating system, manufacturer and model, browser type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state or geographic area; and
• Usage data, such as  pages or screens you viewed, how long you spent on a page, browsing history, and access times.

We may collect this information using cookies and other similar technologies. Cookies, which are text files that websites store on a visitor‘s device or in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.

How We Use Personal Information

We use your personal information for the following purposes:

To provide and improve the Services and respond to your inquiries. This includes:

• Administering, hosting, and operating the Services;
• Communicating with you and responding to any inquiries you may have;
• Analyzing your use of the Services to allow us to evaluate and improve the Services and its features; and
• Creating aggregated, de-identified or anonymous statistics, which we may use for lawful business purposes, including for Services analytics and strategic planning.

Business promotion. We may use personal information to promote our business, including by sending information that may be relevant to you by email, mail, telephone and other means. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our services.

For compliance and protection, including to enforce any applicable terms and conditions, comply with legal obligations, defend against legal claims or disputes, protect the security and integrity of the Services, and identify and investigate fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Personal Information

We may share your personal information with:

Affiliates. We may share personal information with our commonly-branded and commonly-owned affiliates for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, support, email delivery, and website analytics services).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Advertising partners. We may share personal information with third-party advertising companies for the business promotion purposes described above.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, us or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your Choices

Unsubscribe from marketing communications. You may opt out of our marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you. We may continue to send you administrative communications that are necessary for our relationship with you, such as relevant updates to our policies.

Privacy Act information. In some instances, we may maintain personal information on behalf of government agencies protected by the Privacy Act. To learn more about what is covered under the Privacy Act, or to make a request under the Privacy Act, please contact us as provided in the “How to Contact Us” section below. Also see the Privacy Act of 1974 (US Department of Justice).

Privacy choices. Depending where you reside, you may have the following rights under applicable laws:

• Information. You may have the right to obtain information about how we collect, use, and share your personal information. We provide this information within this Privacy Policy.

• Access, correction and deletion. You may also have the right to request access to your personal information, to correct personal information that is out of date or inaccurate, or to delete personal information that is no longer needed for a permitted purpose. If you have questions about how we handle your personal information or if you believe your information is inaccurate or has been collected in error, please contact us as provided in the ‘How to Contact Us’ section below and we will endeavor to resolve your questions or concerns.

• Targeted advertising. We share information with advertising networks and analytics partners to support our interest-based advertising. To understand your choices for managing cookies and targeted advertising, please see the “Online Tracking Opt Out” section below.

To make a request, please email us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. In some instances, your choices may be limited, such as where fulfilling your request is not supported by applicable laws or would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

Online tracking opt-out. There are a number of ways to limit online tracking, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout. 

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Data Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

The Services are not intended for use by children. If we learn that we have collected personal information through our Services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services.

How to Contact Us

You can reach us by email at info@start2.group for any questions regarding our Privacy Policy.