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Privacy policy

The terms of this Privacy Policy were last updated and go into effect as of February 1, 2024.

This Privacy Policy applies only to, and email communications controlled by Via Vita SBC and/or Zoë (the “Sites”). This Privacy Policy describes how Via Vita SBC and/or Zoë and its subsidiaries and affiliated companies (“Via Vita” “Zoë” or collectively, “we”, “us” or “our”) collect, use and disclose personal information of visitors to our Sites, users of our online services and others to whom we expressly provide that this Privacy Policy will apply (collectively, “you” or “your”). It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

This Privacy Policy applies to individuals who visit our Site or interact with us through email. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our Sites in any way, such as browsing or interacting with them, you acknowledge that you have read, understood and agree to be bound by the terms and conditions set forth in this Privacy Policy and the Terms and Conditions of Use. Your acknowledgement includes your consent and agreement to the manner of collection and use of information, including the use of personal information (described below). If you do not agree with this Privacy Policy and the Terms and Conditions of Use, you may not use this Site.


For the purposes of this Privacy Policy, personal information is any information about an identifiable individual.

We collect and maintain different types of personal information that you provide to us on a voluntary basis. This may include:

  • contact and identification information, such as your real name, e-mail address, education level, major or projected major in college, and assessment results;

  • Internet or other electronic network activity information, including, but not limited to, information regarding your interaction the Site;

  • product and service-related information concerning the products and services that we provide to you or programs that we offer;

  • any other information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household; and

  • for parties with whom we do business, credit and financial information such as your payment methods.


If you email us a question or request, we may use your email address to process your request and respond to your question, which may involve collecting any personal information that you choose to provide to us in your email. .
We may also collect market-related information, which may include personal information, concerning, product or service selections, assessment results, market trends and activities impacting our business for the purpose of market analysis, resource planning, and strategic planning.

As a general rule, we collect personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions) or rely on the permission you have given to the third party.

From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.


We collect personal information from you to enable us to manage, maintain, and develop our business and operations, including:


  • to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the programs, products and services that have been requested;

  • to be able to review the products and services that we provide to you so that we may understand your requirements for our programs, products and services and so that we may work to improve our products and services;

  • to protect us against error, breach of contract, negligence, fraud, theft, and illegal activity;

  • to alert you to updated information and other new products and services from us, or third-parties, or to forward promotional materials to you, where you have consented to receive such information;

  • to complete a transaction or service requested by you;

  • to respond to inquiries or requests submitted by you;

  • to ensure the Sites are relevant to your needs;

  • to detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

  • to debug to identify and repair errors that impair existing intended functionality;

  • to undertake internal research for technological development;

  • to help us create and publish content most relevant to you;

  • to enable us to comply with applicable law or regulatory requirements; and

  • any other reasonable purpose to which you consent.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.


Your personal information may be used and disclosed:

  • as permitted or required by applicable law or regulatory requirements;

  • to comply with valid legal processes such as search warrants, subpoenas or court orders;

  • as part of our regular reporting activities;

  • to protect our rights and property;

  • where the personal information is publicly available;

  • during emergency situations or where necessary to protect the safety of a person or group of persons investigate fraud, or respond to a government request; or

  • for any additional purposes for which we have obtained your consent.

We may disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. For example, we may share your personal information from time to time with our third-party information technology and data processing service providers so that we may operate our business.

We do not sell, transfer or disclose your personal information to any third party’s other than for the limited purposes described in this Privacy Policy. We may share aggregated information that does not directly identify you.


When you visit our Site, we may automatically collect website use information, such as information about your operating system, browser type, domain name, Internet Protocol (IP) address, your access times, the website that referred you to us, the web pages you request, and the date and time of those requests. We use this information only to monitor our Site’s performance and improve our Site’s content and structure.

Via Vita SBC and or Zoë and its partners use cookies to analyze trends, administer the Site, and track users’ movements around the Sites. You may be able to control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Sites.

As described in this Privacy Notice, Via Vita SBC and/or Zoë or its partners on our digital propert(ies) may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:


In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple’s IDFA or Android’s GAID), visit the device manufacturer’s current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: (


Our Site may include social media features, such as the Facebook Like button, and Widgets, such as the “Share This” button or interactive mini programs that run on our Site. These features may collect your Internet Protocol address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.


We do not track our web visitors across third party websites to provide targeted advertising and, therefore, our Sites do not respond to Do Not Track (DNT) signals. We do not support Do Not Track browser settings and do not currently participate in any Do Not Track frameworks that would allow any of our Sites to respond to signals or other mechanisms from you regarding the collection of your personal information.


It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified at the relevant time.

If we seek additional information from you beyond the information provided by you, we will seek your consent at the time that we collect any such personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

Unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy. You may change or withdraw your consent to the collection of personal information at any time, subject to legal or contractual restrictions and reasonable notice, by using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to the address set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to, or acquire products or services from, you or your employer.

From time to time, we communicate via email or text with users who request information or subscribe to our newsletters of email mailing lists. For example, we may use your email address to confirm a request you have made, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. If you do not wish to receive email communications from us, you may change or withdraw your consent at any time. You also may opt-out of receiving emails by clicking on the “unsubscribe” link within the text of the email. Additionally, for other communications the opt-out choice may be exercised by ticking or un-ticking the appropriate box if such checkbox is available at the points where personally identifiable information is collected or by contacting us. For text messages, should you choose to “unsubscribe” or stop receiving such messages, you can contact us directly at or reply with the message “STOP” to a message after it is received. Further, you hereby confirm consent to receiving a confirmatory message in response to your STOP request. Message and data rates may apply.

We partner with a third party to either display advertising on our Sites or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Site and other sites in order to provide you advertising based upon your browsing activities and interests.


We urge parents to regularly monitor and supervise their children’s on-line activities.


We partner directly with the following third parties to support our products and Sites. Assessment partners include but are not limited to Career Key Discovery®; Gallup CliftonStrengths®, and Acclaro Values Clarifier©. Our Sites offers links to these companies.

Our Sites may offer links to other websites that may be subject to less stringent privacy standards. If you visit one of these linked websites, you are then subject to the privacy policies and other policies of such website and are no longer protected by our policies. We are not responsible for, or able to monitor or control, the policies and practices of other companies, including with respect to their collection, use or disclosure or your personal information. You should review the privacy policies of these websites before providing them with personal information.


No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.

Once we receive your transmission, we make reasonable efforts to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.


In addition, although we obligate third parties who support our Sites and their related offers or other programs to use any personal information only for the purpose of performing their work, we do not control such third parties’ websites or other security measures.

If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.


Upon request Via Vita SBC and or Zoë will provide you with information about whether we hold any of your personal information. If you wish to obtain access to the personal information that we maintain about you, or to correct, amend, update or delete such information, please contact us in writing using the contact information provided below. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavor to respond within an appropriate timeframe and, in any event, within any timeframe required by law. If you require assistance in preparing your request, please contact us using the contact information set out below.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed or erased in accordance with our record retention obligations and practices. In the event, we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.


Under the California Consumer Privacy Act, California residents have the right to:

  • Request that a business delete any personal information about the consumer which the business has collected from the consumer.

  • Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:

    • The categories of personal information that it has collected about that consumer.

    • The categories of sources from which the personal information is collected.

    • The business or commercial purpose for collecting or selling personal information.

    • The categories of third parties with whom the business shares personal information.

    • The specific pieces of personal information it has collected about that consumer.

  • Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:

    • The categories of personal information that the business collected about the consumer.

    • The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal was sold, by category or categories of personal information for each third party to whom the personal information was sold.

    • The categories of personal information that the business disclosed about the consumer for a business purpose.

  • Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.

You may submit a request under the California Consumer Privacy Act through the following methods:

  • By Mail: Via Vita SBC, 600 Hwy 169 South, Suite 500, Minneapolis, MN 55426 ATTN: Compliance Officer

  • By E-Mail:

To submit a request, we are required to verify your identity. Please be prepared to provide us with your address, phone number, and email address and employee ID. We will match the personal information that you provide to us with personal information that we already maintain about you in order to verify your identity. We may also need to contact you to confirm your request.


You may also designate an authorized agent to make a right to know or deletion request on your behalf. To use an authorized agent, you as the California resident must provide the agent with written authorization, including the verification information above. In addition, the agent will be required to verify their own identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by the you to act on your behalf.

We may not be able to honor each request that we receive, but if we are unable to do so, we will respond to let you know our reasons. We will not discriminate against you if you choose to exercise any of your rights as described in this section.


From time to time, we may revise this Privacy Policy as well as the Terms and Conditions of Use. Any revisions made will be posted within the Privacy Policy or Terms and Conditions of Use, as applicable, on the Sites and will take effect immediately as indicated by the ‘last updated’ date, unless otherwise noted. Collection and use of information from that point forward will be subject to the revised terms. If you do not agree with any revision to this Privacy Policy or Terms and Conditions of Use, you must stop using and accessing the Sites. Your continued access or use of the Sites after any such revisions are posted will constitute your acceptance of these changes. You should review the Privacy Policy and Terms and Conditions of Use from time to time for any changes. This Privacy Policy was last updated on February 1, 2024.


It is at the mutual agreement of both you and Via Vita SBC with regard to the Agreement that the relationship between the parties shall be governed by the laws of the state of Minnesota without regard to its conflict of law provisions and that any and all claims, causes of action and/or disputes, arising out of or relating to the Agreement, or the relationship between you and Via Vita SBC, shall be filed within the courts having jurisdiction within the County of Hennepin, Minnesota or the U.S. District Court located in said state. You and Via Vita SBC agree to submit to the jurisdiction of the courts as previously mentioned and agree to waive any and all objections to the exercise of jurisdiction over the parties by such courts and to venue in such courts.

If you believe that we are not processing your personal data within the scope of our Privacy Policy, you may direct any inquiries or complaints, to our Compliance Officer at or by writing to the following mailing address:

Compliance Officer

Via Vita SBC
600 Hwy 169 South, Suite 500

Minneapolis, MN 55426

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