This Privacy Policy is prepared by Therawin Family Therapy Corporation., a California professional corporation (“Company” or “we” or “us” or “our”). The Privacy Policy described the manner in which we may utilize and/or disclose personal information of its user (“user” or “you”) of our website located at www. [website url].com, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should review any changes since the last time you used the Website.
The Website is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use.
From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users anonymously and in the aggregate, such as by publishing a report on trends in the usage of the Website.
A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used. COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES.
We may use third-party advertising companies to serve ads when you visit the Website. These companies may use information about your visits to the Website and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third-party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the instructions and links here: http://www.networkadvertising.org/choices/ and http://preferences-mgr.truste.com, or http://www.aboutads.info/choices. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.
We may allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the Non-Personally Identifying Information we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads help (https://support.google.com/ad/answer/262922?hl=en).
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Website and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
In addition, Company may make use of de-identified information in accordance with applicable privacy law.
We may provide you the option to connect your account on the Website to your account on some social networking sites for the purpose of logging in, uploading information or enabling certain features on the Website. When logging in using your social network credentials, we may collect the Personally-Identifying Information you have made publicly available on the social networking site, such as your name, profile picture, cover photo, username, gender, friends network, age range, locale, friend list and any other information you have made public. Once connected, other users may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By connecting your account on the Website to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the connected social networking site without first disclosing that to you. Each social network may further allow you to set privacy controls around your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore the available features and shared information are subject to change without notice to you.
We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when (1) registering for our service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) creating a public profile or (6) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic or relevant information as determined by Company from time to time. Users of the Website are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
Certain Personally-Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the Website. We may provide areas on the Website where you can post reviews and other information relating to your activities on the Website. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.
We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings.
Company may disclose Personally-Identifying Information under the following circumstances:
You may at any time review or change your Personally-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and in accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally-Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.
Company uses the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website (1) to deliver the products and services that you have requested; (2) to manage your account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties; (4) to resolve disputes and troubleshoot problems; (5) to inform you of updates; (6) to customize your experience; (7) to detect and protect us against error, fraud and other criminal activity; (8) to enforce our Terms of Use; and (9) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed to manage our business.
The features, programs, promotions and other aspects of our service requiring the submission of personally identifiable information are not intended for anyone under 13 years of age. We do not knowingly collect personally identifiable information from children under the age of 13 other than minor children receiving the service through registration by their parent or legal guardian. If you are under 13 then you may not use or access our website or services at any time or in any manner. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us please contact us at xxxx@xxxxx.com. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof.
Company uses its best efforts to contractually prohibit its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from Company, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally-Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets and a variety of other third-party applications accessible through the Website. Company neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.
We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
Despite our efforts to protect your Personally Identifiable Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted. Therefore, we make no representations or warranties regarding the sufficiency of the above security measures. No data transmission over the Internet or through mobile devices can be guaranteed to be 100% secure. While we strive to protect your personal information from unauthorized access, use or disclosure, we cannot ensure or warrant the security of any information you transmit to us on the Website. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information.
Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, at least once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. The Website does currently respond to DNT browser signals or mechanisms.
We take the privacy of your mobile contact information very seriously. We will never share, trade, or sell your personal information such as phone numbers and SMS opt-in consent to any third parties or affiliates under any circumstances. Mobile opt-in data (your phone number and your consent to receive text messages) is collected solely for the purpose of communicating with you as you have permitted, and it remains confidential. Even when we utilize authorized service providers to help deliver our text messages, those providers are not permitted to share or use your information for any other purpose. In short, your mobile opt-in details will be used only by Therawin (and its contracted messaging platform) to serve you, and will never be disclosed or sold to outside marketers, partners, or other third parties.
We only send SMS text messages to individuals who have explicitly opted in to receive them. Consent to receive SMS is optional and not a condition of receiving services. When you provide your phone number through our website or other sign-up forms, you will be presented with a clear option (such as a checkbox or similar mechanism) to consent to receiving text communications from TheraWin. We obtain your SMS consent during signup by requiring you to actively agree indicating that you want to receive text messages. This consent process makes it clear what you are signing up for, and unless you affirmatively opt in, you will not receive SMS messages from us. We will never send you marketing or health-related text messages without your permission, and we maintain a record of your consent for verification and compliance purposes. Standard message/data rates from your mobile carrier may apply, but no charges are imposed by us.
Types of Messages You May Receive: If you opt in to our SMS program, you may receive various types of text messages related to our services, including:
We will always strive to keep our SMS communications relevant and respectful of your time. You will not receive unsolicited texting spam—only purposeful messages in the categories described above, and only if you have given consent. Message frequency may vary, but generally you will receive texts only when necessary for the service (for instance, an appointment reminder when you have an upcoming appointment, or a promotional message only occasionally). We do not use automated autodialed blasts for telemarketing; all our messages are tailored to the consent you have provided.
Your participation in our SMS texting program is completely voluntary, and you have the right to stop receiving messages at any time. If you decide that you no longer want to get texts from us, you can opt out at any time by texting “STOP” in reply to any of our SMS messages. After we receive a “STOP” opt-out request, we will send a final confirmation message to let you know that you have been unsubscribed, and then you will not receive any further texts. You may also opt out by contacting us directly (by phone or email) and requesting to be removed from SMS notifications. We make the opt-out process as simple and accessible as possible — there are no penalties or questions asked if you choose to unsubscribe.
If you ever want to re-subscribe after opting out, you may need to provide a new opt-in consent. For help or more information about our SMS program, you can reply “HELP” to any Therawin text, which will trigger an informative message on how to manage your preferences, or you can contact our support team at any time. We are committed to honoring your preferences: whether you choose to receive our texts or not, it will not affect the core services we provide to you. Your decision to opt in or out of SMS messaging is entirely up to you, and we will respect it.
Therawin Family Therapy Corporation is fully committed to compliance with the Health Insurance Portability and Accountability Act (HIPAA) and its regulations regarding the privacy and security of your health information. Any Protected Health Information (PHI) you share with us is handled in accordance with HIPAA’s requirements. In the context of SMS communications, we follow industry best practices and HIPAA guidelines to protect your privacy: if we ever send you information that might be considered PHI via text message, we apply the “minimum necessary” rule. This means we limit the content of such messages to the least amount of information needed for the purpose of the text. For example, an appointment reminder will typically include the time and date of your session and the therapist’s name, but it will not delve into detailed medical information. We avoid including highly sensitive details in any text message. Additionally, any third-party service provider we use to send SMS (such as our telecommunication platform) is required to sign a Business Associate Agreement and implement security measures to safeguard PHI, as mandated by HIPAA. We regularly review our SMS procedures to ensure they meet HIPAA standards for privacy and security.
It is important for you to understand that SMS is not a fully secure or encrypted communication channel. Standard text messages (SMS) are transmitted over cellular networks without encryption, which means there is a risk that messages could be seen or intercepted by unauthorized individuals. Examples of such risks include someone viewing messages on your phone if it’s accessible to others, messages being stored on your wireless carrier’s systems, or in rare cases, interception during transmission. By opting in to receive text messages from us, you acknowledge and accept these inherent risks associated with SMS communication. We will assume that you understand this trade-off and still consent to receive texts containing appointment information or other communications from us. If at any time you have concerns about the sensitivity of information being sent via text, you have the option to discontinue SMS messages (as described in the opt-out section above) and request that we communicate with you through other channels (such as phone calls through our office line, secure email, or a patient portal, if available).
Despite the limitations of SMS, please know that we treat all your personal information with the highest degree of confidentiality and care. We have internal policies and training in place to ensure that our staff only use and disclose your health information in compliance with HIPAA. We will never include information like diagnoses, detailed therapy notes, or other extensive health records in a text message. Our SMS communications are intended to be brief and discreet. In the event that any text message does inadvertently contain PHI, we will handle that information with the same level of protection as we do for all other health records, and we will take appropriate measures to secure it.
HIPAA Notice: This SMS portion of our privacy policy is meant to supplement our standard Notice of Privacy Practices under HIPAA, not replace it. For more information on how we protect your health information generally, please refer to our full HIPAA Privacy Notice or contact our Privacy Officer. By consenting to SMS communication, you are acknowledging that you have been informed of the privacy considerations and still authorize Therawin to send you communications via text. We are dedicated to maintaining your trust, and will continue to monitor and improve our practices to ensure your personal and health information remains secure and private.
If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:
Therawin Family Therapy Corporation
Attn: Privacy Officer
212-214 Homer Ave, Palo Alto, CA 94301
Email: admin@therawin.health
Phone: +1 (650) 656-6838
Last updated on 7/30/2024