Last Updated: September 1st 2023
When information identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you, we refer to it as “Personal Information.”
There are several ways we may obtain Personal Information about you, including through (A) information you provide to us; (B) information we automatically collect; (C) information we receive from third parties; and (D) combining information from different sources. This includes data that identifies you personally whether directly or indirectly.
We collect Personal Information from a variety of sources as described below.
Personal Information You Provide When You Interact with Us. When you use the Services, we will ask you to provide certain Personal Information to obtain the Services, and to customize the Services for you. For example, we ask for Personal Information when you register to create an account, update your Personal Information, to sign up for a membership or subscription, use certain features, access, upload or download content, purchase products or services, enter into any of our promotions, fill out a survey, request customer support, or otherwise communicate with us. We also may collect Personal Information from you to match you with the right therapist through an in-take questionnaire, which may include questions such as your name, reasons for therapy, email address, mental health status, geographic location and age.
Personal Information You Provide When You Interact with Our Therapists. We collect communications and related information that, as a user of the Services, you share with your therapist to facilitate the therapy. This includes messages with therapists, charting notes, attendance, clinical surveys and notes.
Personal Information You Provide When You Make a Purchase. If you make a purchase from us and become a subscription member, you will be required to provide a credit/debit card number and related financial information (such as CVV, expiration date, and billing address).
Personal Information You Provide about a Third Party. We collect Personal Information about a third party if you provide us with another person’s information (such as name, email, address, or phone number). For example, this may be the case if you are paying the cost of another person to receive the Services.
When you visit and interact with the Services, and with your consent where applicable, we or our third-party advertising and analytics partners and service providers may use a variety of technologies, such as cookies, tags, and scripts, to collect certain information regarding your browser and device as well as information about how you interact with the Services. Collection of this information helps us to understand you better and, in some cases, provides us direction on what products may be of most interest to you. It also helps us analyze the performance of the Services to make improvements, serve targeted advertising, and collect limited demographic information for marketing/advertising purposes. The cookies and other similar technologies deployed on the Services do not collect directly-identifiable information (e.g., your name) or Sensitive Personal Information.
We (or our third-party vendors) may use tools and software to monitor and record information (including screenshots and videos) about your interactions with the Services, including keystrokes, mouse movements, form field entries, and overall engagement with the Services. We may collect and use this information for compliance verification purposes.
The specific types of information that we and our partners and service providers may automatically collect when you visit and interact with the Services include:
When you access the Services, information about your device and browser may be collected automatically, including your device’s Internet Protocol (“IP”) address and/or other unique identifiers, browser type, device type, internet service provider, and operating system. When you access the Services from a mobile device, your device’s approximate location (derived from your device’s IP address or other signals) may also be collected.
When you interact with the Services, certain information may be collected, including the date and time of your visit, the pages you view immediately before and after you access the Services, the areas or pages of the Services that you visit, the amount of time you spend viewing or using the Services, and other site usage information.
We collect information about the location of your device when you access or use the Services. In addition, if you choose to turn on your Bluetooth, Wi-Fi or other geolocation functionality when you use our mobile applications, we may collect and use your geolocation information.
Additionally, if you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through to the Services).
“Cookies” are text files that are placed on your browser by the websites that you visit. Cookies are used for various purposes, including to distinguish you from other users, make your site navigation more efficient, help remember your preferences, enhance your browsing experience, and improve the use and functionality of the Services and related content. They can also enable the delivery of relevant and personalized advertisements to you across the Internet.
Please note that cookies (and other similar technologies) provided by third parties may be placed on your browser and the providers of these technologies may combine information collected from your interaction(s) with the Services with information they collect from other sources and use the combined information for analytics and/or advertising purposes. You may adjust your device or Internet browser settings to limit certain tracking or to decline cookies. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete cookies and/or disable your device or browser from receiving cookies or controlling your tracking preferences. You can also visit and update your privacy preferences at any time by visiting the Your Privacy Choices link on the website.
We may receive Personal Information from other sources, such as:
We may use Personal Information that we collect from and about you for the following business purposes:
We may disclose your Personal Information for legitimate business purposes to the following categories of third parties:
We disclose Personal Information where appropriate to third parties that provide services to us or to whom we outsource certain services, such as website/system/data hosting, management, and support and data analysis services. All such parties are subject to binding contractual obligations and restrictions on the use of the information for any purpose other than carrying out the services that they are performing for us.
Clinical documentation captured by your therapist during your interactions are only shared with government, regulatory, and public authorities in certain events. For example, a court may subpoena information from us where we would be required to share information specified in the subpoena. We defer to your therapist to choose whether to produce (or not produce) the records created during interactions with you. We encourage you to discuss with your therapist any questions or concerns you may have regarding their disclosure obligations.
Please be aware that therapists may be obliged to disclose Personal Information to authorities to meet their professional, legal, and ethical responsibilities. Some state laws require therapists to disclose information and/or take action for: (a) reported or suspected abuse; (b) serious suicidal potential; (c) threatened harm; and (d) court-ordered treatment. We recommend that you speak with your therapist if you have questions or concerns about this.
Our Analytics and Marketing Partners. With your consent, we may disclose limited types of Personal Information, such as your IP address and online identifiers, to our partners that assist us in providing you with relevant advertising, to analytics and to help us measure the effectiveness of the Website’s content and our marketing and advertising efforts.
Relevant Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.
Other Third Parties. We will disclose your Personal Information to other third parties only with your consent. Additionally, we will disclose your Personal Information as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.
We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information, and with your consent.
We provide you with the ability to make certain choices about how we use your Personal Information. Additional details are below.
If you opt in and accept online tracking technologies, including cookies, on our Website, we may use third-party services to help us track, segment, and analyze usage of our Website, and to help us or those third parties service more targeted advertising to you on the Services and across the Internet. These third parties may use technologies such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to track online activity. They may also combine information they collect from your interaction with our Website with information that these third parties collect using cookies or other tracking technologies.
You must be opted in through our Website in order to be tracked for analytics and/or advertising purposes through the Your Privacy Choices link on the website. If you choose not to opt in, we may not be able to remember your preferences or deliver relevant advertising to you.
Please note that we do not disclose therapy data with third parties through these cookies and similar technology.
From time to time, we may send you marketing and promotional communications and materials, including special offers from us. If you no longer wish to receive promotional and marketing emails from us, you may opt out of such communications at any time by following the opt-out instructions included in any promotional or marketing email you receive from us. Even if you opt out of receiving promotional and marketing emails from us, we may still send you administrative and transactional emails from which you cannot opt out.
We reserve the right to deny information requests that are unduly burdensome as permitted by law. We may also ask you or your authorized agent, as described below, to reasonably verify your identity or status as an authorized agent.
Please note that once you have started subscribing to the Services, we may retain some of your Personal Information for an extended period based on applicable data retention laws.
Only you or your authorized agent may make a request to access Personal Information on your behalf. Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf or must demonstrate that they have the power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using your Personal Information, or any information collected from or about you, for any purpose other than to fulfill your request, for verification, or for fraud prevention.
If you are interested in exercising one or more of the rights outlined above, or if you have questions about your rights, please contact us by calling 1-800-976-2920 or emailing us at email@example.com.
We will not discriminate against you for exercising any of your privacy rights. We will not deny you the Services, charge you different prices or rates, impose penalties, or provide a different quality of service.
The Services may have links to third-party services, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.
The Services are not designed for or intentionally targeted at children under the age of 18, and we do not knowingly collect Personal Information from anyone under 18 years of age.
We take your privacy and protecting your data very seriously. We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and users of the Services. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.