Privacy Policy

Effective Date: October 11, 2019

Brightside Health Inc. (“Brightside”) provides a platform for individuals to learn about depression and anxiety, understand treatment options, and connect with a Healthcare Provider for clinical care, if desired. Our Privacy Policy explains our information practices, the kinds of information we collect, how we use and share that information, and your options.

Scope

This Privacy Policy applies to personal information processed by us in our business, including on our website (“Site”) and other online or offline offerings (collectively, the “Services”). Any individually identifiable information that is provided to us for purposes of receiving Clinical Services (also referred to as “Protected Health Information” or “PHI”) is subject to the Brightside Notice of Privacy Practices. The Notice of Privacy Practices describes how Brightside can use and share your PHI and describes your rights with respect to this information. The Notice of Privacy Practices (and not this Privacy Policy) will govern our privacy practices with respect to your PHI.

  1. Personal Information We Collect
    The categories of Personal Information we collect and our privacy practices depend on whether you are a customer, user, or visitor and the requirements of applicable law.

    Information You Provide to Us

    • Account Creation.
      When you create a user account, we collect your name, e-mail and password.
    • Communications with Us.
      We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.
    • Surveys.
      We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.

    Information Automatically Collected or From Others

    • Automatic Data Collection.
      We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
    • Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising.
      We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and Services.

      • Cookies.
        Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
      • Pixel Tags/Web Beacons.
        A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
    • Analytics.
      We may also use Google Analytics and other analytics software to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
    • Information from Other Sources.
      We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
  2. How We Use Your Information

    We use your information for a variety of business purposes, including:

    • Fulfill our contract with you and provide you with our Services,
      such as:

      • Managing your information and accounts;
      • Responding to your questions, comments, and other requests;
      • Providing access to certain areas, functionalities, and features of our Services;
      • Communicating with you about your account, activities on our Services and policy changes;
      • Processing your financial information and other payment methods for products or Services purchased;
      • Processing applications and transactions;
      • Answering your requests for customer or technical support; and
      • Allowing you to register for events.
    • Analyze and improve our Services pursuant to our legitimate interest,
      such as:

      • Measuring interest and engagement in our Services;
      • Conducting research and development;
      • Developing new products and Services;
      • Ensuring internal quality control;
      • Verifying your identity and preventing fraud;
      • Detecting bugs or other software issues;
      • Preventing potentially prohibited or illegal activities;
      • Enforcing our Terms; and
      • To comply with our legal obligations, protect your vital interest, or as may be required for the public good.
    • Provide you additional content and Services,
      such as:

      • Providing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
      • Providing Services to you and our customers;
      • Auditing relating to transactions; and
      • Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
    • De-identified and Aggregated Information Use.
      We may use personal information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create.
    • Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

      • Operationally Necessary.
        This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
      • Performance Related.
        We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
      • Functionality Related.
        We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;
      • Advertising or Targeting Related.
        We may use first party or third party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on third party sites.
    • Notice regarding Third Party Websites and Social Media Platforms

      The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

      Our Services may include publicly accessible blogs, forums, social media pages such as Instagram, and private messaging features. By using such Services, you assume the risk that the personal information provided by you may be viewed and used by Third Parties for any number of purposes.

  3. DISCLOSING YOUR INFORMATION TO THIRD PARTIES

    We may share your personal information with the following categories of third parties:

    • Service Providers.
      We may share any information we receive with service providers. The types of service providers (processors) to whom we entrust personal information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested (e.g. Healthcare Providers); (iii) payment processing (e.g. insurers); (iv) customer service activities; and (v) the provision of the Site and Services.
    • Business Partners.
      We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.ervice Providers.
    • Advertising Partners.
      Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.
    • Disclosures to Protect You, Us, or Others.
      We may access, preserve, and disclose any information we store associated with you to external parties if we or our providers, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
    • Disclosure in the Event of Merger, Sale, or Other Asset Transfers.
      If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
    • International Data Transfers.
      You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
  4. YOUR CHOICES

    • General

      You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non- personal information regarding your activities on our Services and for other legal purposes as described above.
    • Email Communications

      If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

      We process requests to be placed on do-not-contact lists as required by applicable law.
    • Mobile and Other Devices

      If you provided access to your device’s health app (e.g., Apple HealthKit) or other devices such as Apple Watch to collect your fitness activity data, you can withdraw your consent and disable access by changing the app settings on your device. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
    • “Do Not Track”

      Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
    • Cookies and Interest-Based Advertising

      You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at:

      To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

      Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

    • Your Privacy Rights:
      In accordance with applicable law, you may have the right to:

      • request confirmation of whether we are processing your personal information;
      • obtain access to or a copy of your personal information;
      • receive an electronic copy of your personal information or ask us to send that information to another company;
      • restrict our uses of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, depending on applicable law;
      • seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and
      • request erasure of personal information held about you, subject to certain exceptions prescribed by law.

      If you would like to exercise any of these rights, please log into your account or contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

  5. DATA RETENTION

    We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
  6. SECURITY OF YOUR INFORMATION

    We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

    By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
  7. CHILDREN’S INFORMATION

    The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
  8. SUPERVISORY AUTHORITY

    If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
  9. CHANGES TO OUR PRIVACY POLICY

    We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.
  10. CONTACT US

    If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this policy, please contact us at:

    Brightside Health, Inc.

    Privacy and Security Officer – Brad Kittredge

    156 2nd St.

    San Francisco, CA 94105.
741-741

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