Thrive360 Digital Platform Privacy Policy

Virtual Therapy, LLC d/b/a Thrive360 ("Thrive360") provides a wellness and healthy lifestyle content library that allows websites, apps and other internet-connected properties to provide wellness content to individuals who may be interested in such products or services. This policy explains how we collect, use, and disclose information through our online digital platform (the "Platform").

Our goal is to be transparent about our business by describing our technology and services in simple terms so that you can understand our practices. We know this is complicated, so if you have any questions about this information, please contact us at info@thrive360.com.

Overview

Below we provide an overview of our practices and where you can find more information.

Detailed Information

Information We Collect

When you visit our Platform or use technology that integrates with our Platform, we collect certain information about your visit. This policy refers to this information as "Platform Data", and includes the following:

• Information about your browser including: the type of browser you use, browser language, browser settings, and cookie information.
• Information about your device including device operating system version, connection type, device make, device model, device identifiers such as your IDFA or AAID, and the IP address from which the device accesses the Platform.
• Information about your activity on the Platform including web pages or apps visited or used and the time those web pages or apps were visited or used.

How We Use Your Information

We use the data we collect to maintain and enhance our services including through the use of information for machine learning, optimization and statistical analysis. The information we collect may be used for the following purposes:

• Compiling statistics about the transactions occurring through our Platform and conducting research and development for our own internal business purposes, such as analyzing forecasts and conducting machine learning to help our Platform users.
• Analyzing and reporting on segment use, such as reporting to our content providers about when and how you have been exposed to segments maintained in our content library.
• Investigating, protecting against and deterring malicious activity, fake traffic or fraudulent, unauthorized or illegal activity on the Platform and on the internet.

Information Sharing

We do not sell your data or provide it to other parties, except as follows: we may provide Platform Data to partners and service providers for the purpose of operating, managing, maintaining, or enhancing our services, including for the safety and security of the Platform and the online industry, or as required by law.

Data Storage and Retention

Platform Data is stored using generally accepted security standards. It is usually aggregated or deleted within 60 days but may be retained for a longer period of time for purposes of contacting you and optimizing the delivery of content provided through our Platform.

Your Rights and Choices

If you are a resident of certain jurisdictions, you may have certain rights and protections under a particular jurisdiction's law regarding the collection, processing, and use of information about you. This policy describes the rights that may be available to you, and how you can implement them.

California Privacy Rights

If you are a California consumer as defined by the CCPA, you may have the right to: (i) request access to your personal information and request additional details about our information practices, (ii) request deletion of your personal information, (iii) opt out of the "sale" of your personal information (as that term is defined by the CCPA), and (iv) to not be discriminated against for exercising any of your rights under the CCPA.

European Data Protection Rights

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your "personal data" as defined under applicable law. Some of the Platform Data that Thrive360 maintains in its Platform may constitute "personal data" under these laws.

International Data Transfers

Thrive360 is a company headquartered in the United States with data centers located in the United States. When we transfer your personal data to third-party service providers outside of the European Economic Area, we ensure that appropriate protections are in place under European data protection legislation.

Changes to This Policy

We may change this privacy policy at any time. If we make changes that, in our sole discretion, are material, those changes will not be applied to information collected prior to the date the changes went into effect.

Contact Us

If you have questions about privacy on the Thrive360 Platform, you can send us a message to info@thrive360.com.

You can also contact us by post using the details below: