Confidential Health Information
As individual practitioners and collectively as a clinic, we are bound by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to protect the privacy of your personal information.
Your personal information is accessible only by duly authorized members of our practice; and also with business associates, but only as much as is needed to process your insurance claims.
We take steps to prevent unauthorized access of physical and electronic records. All employees and care providers receive training on confidentiality procedures and are subject to professional censure and/or discipline for any violation of our written privacy policies.
This Privacy Notice for California Residents supplements and is expressly made part of the information contained in the theraBridge Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice.
Through your use of our website, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The description of the information that we collect is provided above, in the section titled “Categories of Information Collected.” In particular, our websites have collected the following categories of personal information from consumers within the last twelve (12) months. Additionally, we have disclosed the following categories of information for a business purpose in the past twelve (12) months:
Category: | Collected | Disclosed for a business purpose |
---|---|---|
Identifiers | Yes | Yes |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Yes | Yes |
Protected classification characteristics under California or federal law. | Yes | Yes |
Commercial information. | Yes | Yes |
Biometric information. | No | No |
Internet or other similar network activity. | Yes | Yes |
Geolocation data. | Yes | Yes |
Sensory data. | No | No |
Professional or employment-related information. | Yes | Yes |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | No | No |
Inferences drawn from other personal information | No | No |
The information that we share with third parties is described in greater detail above in the section titled “Purposes for Which Information is Disclosed to Third Parties.”
theraBridge obtains the categories of personal information listed above from the following categories of sources:
We may use the personal information we collect for one or more of the following business or marketing purposes:
Category of Personal Information | Purpose of Use |
---|---|
Identifiers | We may use Identifiers (provided account name, email address, theraBridge online identifier, and IP address) to communicate with you, deliver our services to you, facilitate the Counselor Services, customize and market the services (attribution and optimization), conduct research and development and other activities to improve our service, understand how you interact with our services, and comply with the law. |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | We use your name (if you provide it to us) and the payment details you provide to us to communicate with you, deliver services to you, and facilitate the Counselor Services. |
Protected classification characteristics under California or federal law. | We may use your age, religion, sex, orientation and medical condition to customize and deliver the services to you. If you are a veteran or have military status, we may use this information to offer you a discount for our services.
We may also use this information to conduct research and development and other activities to improve our service, show and optimize advertising, and understand how you interact with our services. |
Commercial information. | We use information regarding your purchase of our services to customize and market services, conduct research and development and other activities to improve our services, show and optimize advertising, and understand how you interact with our services. |
Internet or other similar network activity. | We use information regarding your activity on our websites to deliver our services to you, customize and market services (attribution and optimization), conduct research and development and other activities to improve our service, and understand how you interact with our services. |
Geolocation data. | We use your geolocation information to personalize the services to you and for analytics. |
Inferences drawn from other personal information. | We use information regarding your actions on our websites and the information you provide to deliver our services to you, customize and market the services, conduct research and development and other activities to improve our service, and understand how you interact with our services. |
In the 12 months preceding the date of this Privacy Policy, theraBridge has shared personal information with the following categories of third parties:
Category of Personal Information | Purpose of Use |
---|---|
Identifiers | We may disclose your IP address, advertising ID, or sequentially generated user ID unique identifier to our analytics vendors for analytics and to ad network partners for advertising optimization and attribution.
We may disclose your contact information to webinar providers and to customer support to provide services for the Platform. We may disclose contact information between users and Counselors to provide the Counselor Services. We may disclose your credit card information to payment processing vendors for payment processing. If you are a user that uses theraBridge as the result of a business arrangement theraBridge has with an organization you are affiliated with or with your employer, we may disclose, with your authorization, identifiers to those entities in order to deliver the services to you. |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | We may disclose your contact information to webinar providers and to customer support and payment processing vendors to provide services for the Platform and to ad network partners for advertising optimization and attribution.
We may disclose personal information between users and Counselors as necessary to provide the Counselor Services. We may disclose your credit card information to payment processing vendors for payment processing. |
Protected classification characteristics under California or federal law. | We may disclose information regarding your age, sex, race, gender, sexual orientation, medical conditions, and disabilities to our Counselors as necessary to provide the Counselor Services. Due to the use of cookies and web beacons, information regarding your activity on our websites, excluding activity when you are logged in and have started counseling, may be disclosed to our advertising partners to optimize marketing. |
Commercial information. | We may disclose information regarding your purchase of our services to our advertising partners to optimize marketing.
We may disclose your credit card information to payment processing vendors for payment processing. |
Internet or other similar network activity. | Due to the use of cookies and web beacons, information regarding your activity on our websites, excluding activity when you are logged in and have started counseling, may be disclosed to our advertising partners to optimize marketing. |
Geolocation data. | We may disclose geolocation data to our advertising partners to optimize marketing. |
Inferences drawn from other personal information. | Due to the use of cookies and web beacons, information regarding your activity on our websites, excluding activity when you are logged in and have started counseling, may be disclosed to our advertising partners to optimize marketing. |
All data categories | We may disclose all necessary information about you to comply with legal requirements that apply to us.
We may disclose information about you at your direction or request. We may disclose information about you to vendors and other contractors and advisors that provide services to us, including data hosting and storage providers, analytics providers, engineering vendors, data security vendors, marketing services processors, lawyers, advisors, auditors, accountants, and others. |
The CCPA defines “sale” broadly. It includes the sharing of personal information in exchange for anything of value. According to this broad definition, in the 12 months before this section was last updated, our use of analytics and targeting cookies and web beacons to deliver advertising tailored to individual interests may have been considered a “sale” of personal information.
Before April 2021, we may have used hashed contact details, which can be categorized as identifiers or personal information categories listed in the California Customer Records statute, to optimize our marketing to prospective users and Counselors.
Prior to April 2021, advertising network partners may have received your hashed contact details for advertising optimization and attribution. Additionally, protected classifications, as described above, may have been shared with advertising partners to optimize marketing.
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that theraBridge disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:
You have the right to request that theraBridge delete any of your personal information that we collected about you and retained, subject to certain exceptions. Once we receive your request and verify who you are, we will delete (and direct our service providers to 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 or our service provider(s) to:
We may also deny your request if the information in question is not subject to the CCPA. Examples of such information include de-identified information, information covered by the Health Insurance Portability and Accountability Act, and information covered by the California Confidentiality of Medical Information Act.
You have the option to opt out of the use or disclosure of your information that is considered a “sale” under the CCPA. If you would like to opt out of the use and disclosure of your information, follow this link to manage your preferences.
To exercise the rights listed above, please submit a request in writing to theraBridge using this form via the submission methods listed below. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.
You may only make a request for access twice within a 12-month period. Your request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify your identity or authority to make the request.
You may submit requests using the following methods:
By completing this form in writing and sending it to:
theraBridge
Data Protection Office
31 W 10th St
New York, NY 1001, USA
By calling our
(212) 673-0446
We endeavor to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days from the day of receipt), we will inform you of the reason and extension period in writing.
For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your 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.
We will not discriminate against you for exercising any of your CCPA rights. We will not:
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hey@therabride.com.
theraBridge reserves the right to amend this Privacy Notice at our discretion and at any time. When we make any changes to this Privacy Notice, we will post the updated Privacy Notice on our websites and update the Privacy Notice’s effective date. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform. Your continued use of our websites and services following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Privacy Notice, the ways in which theraBridge collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
theraBridge
Data Protection Officer
303 Fifth Avenue, New York, NY 10016, USA