Last updated April 8, 2021
Therify is committed to protecting the privacy of our users and will always work diligently to ensure that your personal information is secure. The purpose of this Privacy Policy is to describe how Therify, Inc (“Therify”, “we”, “our” or “us”) collects, uses, and shares your personally identifiable information and the standards and procedures we employ to make sure it is safeguarded when you visit our website at https://therify.co (or such other URLs or web addresses as may be made available by Therify from time to time; the foregoing together as the “Site”) and use the services, features, content or applications we offer (collectively with the Site, the “Services”).Therify, including its employees and affiliates, strictly adhere to this Privacy Policy to ensure the confidentiality of our users and your personal information. As such, it is our policy to comply with all federal and state laws relating to the privacy of personal information applicable to us in the provision of the Services.
What Does This Privacy Policy Cover?
This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services such as when creating your account (your “Account”). “Personal Information” is information that can be used to identify you by itself or when it is combined with other information, such as your first and last name, e-mail address, postal address or payment card information. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access. Personal Information once “de-identified” is not subject to this Privacy Policy and we and our service providers and Agents (as defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.
Personal Information We Collect
Therify collects Personal Information from users of our Services, particularly information we use to match you with a therapist. We collect the following categories of Personal Information:
Account Information. When you create an Account, you provide information that could be Personal Information, such as your name, password and email address. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you consent to allowing others, including us, to identify you. We may use your Account, which may include Personal Information, in a manner consistent with this Privacy Policy including to send you information about our Services. You may unsubscribe from these messages through your Account settings, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.
IP Address Information and Other Information Collected Automatically. We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on). Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them. Email Communications We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.
Information Collected Using Cookies. Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet. Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.
Aggregate Information. We collect statistical information about how users use the Services. Some of this information is derived from Personal Information. However, this statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser.
Information from Other Sources. We may obtain information about you from other sources, including service providers and third party services as well as your employer in connection with setting up your Account and to provide the Services, and combine such information with information we have collected about you. To the extent such third party sourced information, alone or in combination with other information, can be used to identify you personally, we will treat the third party sourced information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.
HIPAA and Protected Health Information
Under the Health Insurance Portability and Accountability Act (“HIPAA”), some health related personal information that we collect as part of providing the Services may be considered “protected health information” or “PHI.” Examples of PHI you may provide include:
1. When you use your Account to engage with medical professionals, Personal Information such as your name, address, and medical history.
2. When you use the Services, health information such as appointment information, claims processing data, and payment information.
HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. We may use or disclose your PHI for treatment, payment, or healthcare operations purposes on behalf of healthcare providers and other purposes permitted or required by law. In this case we enter into agreements with your providers that protect the use and security of your PHI. We may also disclose your PHI to other companies or individuals that need the information to provide services to us. For example, we may provide information to companies that assist us with support services or billing services now or in the future. These other entities, known as “business associates,” are required by HIPAA to also keep the PHI confidential and secure. Additionally, you may be asked by us to e-sign an authorization (the “HIPAA Authorization”). Your decision to e-sign the HIPAA Authorization is entirely voluntary. If you choose to e-sign the HIPAA Authorization, you agree that we may use and disclose your PHI in the same way we use and disclose your Personal Information that is not PHI. To the extent any provision in the HIPAA Authorization is inconsistent with this Privacy Policy, then the provisions in the HIPAA Authorization only controls with respect to your PHI. If you do not e-sign the HIPAA Authorization, then your Personal Information that is not PHI is governed by this Privacy Policy and your Personal Information that is PHI is used and disclosed by us only as permitted in accordance with our agreements with your healthcare provider(s). You may retract your HIPAA Authorization at any time by email to hello@therify.co.
Uses of your Personal Information
Therify uses non-identifying information you provide us to match users with licensed therapists who meet their preferences and needs. For example, when a user tells us they are experiencing issues related to anxiety and depression, we use this information to match them with a therapist who specializes in treating anxiety and depression. We only provide this non-identifying data to therapists after we have removed the user’s email address and any other personally identifying information from it. We may publicly share anonymous, aggregate data from our user base, but only after their data has been combined with other people's data in a way that it no longer personally identifies any particular individual. The anonymous, aggregated data also may be published through various media, but will not include any personal identifying information. In addition to the above we may use information about you, including your Personal Information, for any purposes consistent with our statements under this Privacy Policy or as permitted by applicable law, including to:
• Manage your Account;
• Respond to your comments, questions, and requests, and provide customer service;
• Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
• Prevent and address fraud, breach of policies or terms, and threats or harm;
• Monitor and analyze trends, usage, and activities;Conduct research, including focus groups and surveys;Improve the Services, the Site or other Therify websites, applications, marketing efforts, products and services;
• Send you advertisements and communicate with you regarding our and third party products, services, offers, promotions, rewards and events we think you may be interested in; and
• Fulfill any other purpose disclosed at the time you provide Personal Information.
We will not use information we have collected from you for purposes that are materially different, unrelated or incompatible with this Privacy Policy without providing you with prior notice. At any time, users may request access to a description of the data we collect and maintain about them by emailing us at hello@therify.co.
Disclosure of Personal Information
We do not share Personal Information of our users with anyone, except if required by law, or as follows:
• To any person to whom you have provided consent;
• To government or regulatory agencies if we are ordered to comply with a court order, subpoena, or similar legal process or investigation;
• To individuals or entities we employ and contract with that perform certain tasks or services on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.To our other third party services providers such as those who may provide cloud hosting or payment processing functions and are subject to agreements that protect the confidentiality of your Personal Information.Information disclosed pursuant to business transfers. From time to time, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, sell all or substantially all of our assets, are acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred to or acquired by a third party. You acknowledge that such transfers may occur, that we may transfer for your Personal Information in accordance with this policy and applicable law, and agree that any acquirer of us or any of our assets may continue to use your Personal Information as set forth in this policy.
• Information disclosed for our protection and the protection of others as permitted by law.
We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof or thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
How We Protect Personal Information
We are committed to protecting the Personal Information of our Users. To this end, we have implemented strict protections to comply with applicable laws and regulations and ensure the protection of PI and PHI belonging to our users, including:
• Maintaining physical and electronic safeguards that comply with relevant privacy laws
• Entering into agreements with third-party providers that require them to safeguard your Personal Information and to use it only for the purposes of fulfilling our specific business need
• Restricting access to user information solely to our Agents and third party service who have a legitimate business need to access such information
California Consumer Privacy Act (CCPA)
This Section of our Privacy Policy applies solely to visitors and users who reside in the State of California. The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes those CCPA rights and explains how to exercise those rights. The categories of information, including Personal Information, which we collect from you can be found in the “Personal Information We Collect” section above. As stated above we will never sell your Personal Information.
The business or commercial purposes for which we use the categories of information, including Personal Information, which we collect from us can be found in the “How We May Use Your Information” section above.
Your Rights Under the CCPA:
Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (“Right to Know”). You have the Right to Know (i) the categories of Personal Information we collected about you; (ii) the categories of sources for the Personal Information we collected about you; (iii) our business or commercial purpose for collecting that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; and (v) the specific pieces of personal information we collected about you.
Right to Delete: You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable request, we will delete your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us to: (i) complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another party to exercise their free speech rights, or exercise another right provided for by law; (v) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (vi) comply with a legal obligation; or (vii) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights under the CCPA:
To exercise your Right to Know or Right to Delete, please submit a verifiable request to us by sending an email to hello@therify.co.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information. The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may need to contact you to request additional information in order to verify you are the person about whom we collected Personal Information or that you are an authorized representative. We will not use any information provided as part of a request, including any contact information you provide or that we request in order to respond to or verify a request, for any purpose other than to respond to or verify your request.We will make an effort to respond to your verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing either by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period before our receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights by (i) denying you goods or services; (ii) charging you a different price or rates for goods or services; or (iii) providing you a different level of quality of goods or service. For additional information regarding your rights under the CCPA, or how to exercise them, you may contact us at hello@therify.co.
Closing Thoughts
We’d like to remind all Therify users that while you are using our services at your own risk, we will always work tirelessly to ensure the safety and protection of our users and their personal information. The safety and security of your information is our top priority, however we cannot guarantee its protection. Therify is not responsible for the actions, content, information, or data of third parties, and you release us, our directors, officers, and employees from any claims and damages, known or unknown, arising out of or in any way connected with any claim you have against such third parties. Note that Therify is a U.S. company. Regardless of the country in which you live, you authorize us to access, transfer, store, and use your Personal Information in the United States and in accordance with this Privacy Policy. U.S. privacy and data protection laws and rules may vary from those in the country where you live.We reserve the right to amend this Privacy Policy at any time without notice, and only the current Privacy Policy may be deemed effective. If we make changes to this Privacy Policy we will revise the Last Updated date set forth above.
