Privacy

DETAILS OF OUR POLICY

Thrive360 Digital Platform Privacy Policy

January 28, 2021

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.

DETAILS

What information do we collect and use?

The Platform is designed to collect and use only Platform Data (as defined below) as described in this document.

How do we collect information?

The Platform uses cookies, beacons, pixels, tags, mobile SDKs, and other non-cookie technologies to collect and store Platform Data about web browsers and devices across web sites and apps and over time.

For what purposes do we use the collected information?

Thrive360 uses the information collected on the Platform to provide, operate, manage, maintain, and enhance the Platform and allow our clients to use our Platform. This means we collect information concerning the device you are using to optimize the Platform’s user experience. We also collect data on the sessions users view from the content library in order to determine content adoption and suitability. In order to contact you and determine eligibility for access privileges to the Platform, we collect your name, email address and, if you choose to provide such information, the name of your workplace and the industry in which you work. We also maintain information acknowledging your opportunity to review the terms of our User Agreement and this Privacy Policy. 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 also 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

When you (an internet user) visit our Platform or uses 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.

What information do we share with third parties?

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. Thrive360 does not share the information collected on the Platform with other third parties, unless legally required.

As set forth above, we provide information to our service providers (including data centers, hosting providers, anti-fraud, technology and security providers). We share with our service providers (or enable their collection of) Platform Data so that they can perform functions and provide services to us including for purposes of protecting the safety and security of the online ecosystem, including to detect and prevent malicious activity or fake traffic. Our service providers are subject to obligations consistent with this Privacy Policy and appropriate confidentiality and security measures.

We may also disclose Platform Data when we reasonably believe it is required by law, subpoena or other legal process, including to meet national security or law enforcement requirements.

We may transfer Platform Data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

We may also share aggregated data derived from the Platform, including, for example, statistics about Platform activity with our content and service providers.

How is the information stored and how long is it kept?

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.

What are your choices and rights?

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.

Details

Regardless of where you live, Thrive360 provides several options for you to choose how you want to interact with the Platform and respects user choices provided by device-system software. While we don’t collect data regarding your online behavior beyond what is disclosed in this Privacy Policy, you may be able to: (i) opt out of having the Platform used to select ads for your browser based on your online web browsing behavior, (ii) opt out of the use of information about your usage of mobile apps for targeted advertising purposes, based on choices made available to you by those apps and your mobile device, and (iii) opt out of the collection of certain forms of location information, based on preferences available to you on your mobile device.

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

What are your California Privacy Rights?

If you are a California consumer as defined by the CCPA (as defined below), 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. Your options regarding the personal information we collect or receive about you are described in “Your Choices and Rights” below. You may also call us at (512) 348-7813.

What are your rights and protections in European Countries?

If you are located in the European Economic Area, the United Kingdom, or Switzerland (the “European Countries”), 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.

Where do we operate?

Thrive360 is a company headquartered in the United States with data centers located in the United States.

What happens if this privacy policy is changed?

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.

Questions?

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

Your Choices and Rights

If you reside or are located in certain jurisdictions, you may have rights and protections regarding the collection, processing, sharing, and use of your data under a particular jurisdiction’s law. This may mean that you may have the right to:

Request access and obtain a copy of your data;
To request rectification of your data;
In certain circumstances, and subject to some specific legal reasons where we may need to retain data, to request that your data be deleted or erased;
To opt out of the sale of your data to third parties;
If applicable, to enforce your right to data portability;
To object to the processing of your data in certain circumstances;
Not be discriminated against for exercising your rights with respect to yourdata.

Targeted Ads

While we do not directly participate in digital environments that drive targeted ads, certain online browsers and other search functions available to online users permit the collection and aggregation of data for use in delivering targeted ads. Mobile device system software such as Apple iOS or Google Play Services provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device or otherwise. For more information, or to opt out using these mechanisms, consult your device settings (“Opt out of Personalized Ads” on Android devices and “Limit Ad Tracking” on iOS devices).

Location Data

While we do not directly participate in digital environments that collect location data, certain online browsers and other search functions available to online users permit the collection and aggregation of location data. Most mobile devices offer you the ability to stop the collection of location information at any time by changing the preferences on your device. You may also be able to stop the collection of location information by particular apps by adjusting the settings for individual apps or following the standard uninstall process to remove specific mobile apps from your device. Note when location services have not been enabled in any of your apps, we will still infer data about your location based on your IP address.

Televisions

Your internet connected device (e.g. a smart TV or a set-top box) may give you the ability to opt-out of the use of information for advertising purposes. To determine if your Internet connected device has these options, please visit your device’s settings menu.

Access Rights

If you reside in certain jurisdictions, you may have the right to access the data we hold about your devices.

Deletion Rights

If you reside in certain jurisdictions, you may have the right to delete the data we hold about your devices. Note that you can delete your cookies at any time by using your browser settings. You can also reset the advertising identifier in your mobile device at any time by using the settings referenced in your devices’ user manual.

The United States, where we operate, may not provide an adequate level of data protection for your information (as determined by the European Commission for personal data in its jurisdiction) or have data protection or other laws as comprehensive as those in your country. Please see “Information for Residents of European Countries” below for information on how we protect information that is transferred out of the European Economic Area, United Kingdom, and Switzerland.

Information for California Consumers: Your California Privacy Rights

The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.) applies to the collection, use, and disclosure of “personal information” collected from California “consumers” (as those terms are defined by the CCPA). Some of the Platform Data that Thrive360 maintains may constitute “personal information” under the CCPA. Consequently, the CCPA requires us to disclose to California consumers the categories of personal information (as defined in the CCPA) we collect, our business and commercial purposes for collecting, using, or selling such personal information, the categories of sources from which we collect personal information, the categories of personal information we have disclosed or sold for a business or commercial purpose in the preceding 12 months, and the categories third parties with whom we share personal information. We have provided these disclosures in the “Information Thrive360 Collects,” “How We Use the Information We Collect,” and “How and Why We Share the Information We Collect” sections above.

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. Your options regarding the personal information we collect or receive about you are described in the Your Choices and Rights section above. You may also call us at (512)348-7813.

Information for Residents of European Countries

Role of Thrive360 as a Controller or Processor

If you are located in one of the European Countries, Thrive360 may act a “controller” as defined under applicable law when processing your personal data. Thrive360 may also act as a “processor” as defined under applicable law to the extent that it processes your personal data on behalf of and at the instruction of another party, for example our service providers.

Legal Basis for Processing

Thrive360’s legal basis for processing your personal data depends upon the specific context in which we collect or use it. We normally rely on our legitimate interests to collect and use personal data, except where our interests are overridden by your data-protection interests or your fundamental rights and freedoms. Our legitimate interests are described in greater detail in the “How We Use the Information We Collect” section of this policy. These legitimate interests include the operation of our Platform and business and the provision of our online technology services to our users as required by our User Agreement and this Privacy Policy. In some cases, we may rely on your consent which is obtained through the User Agreement permitting use of our technology and our Platform. If we rely on consent to process your data, we will obtain such consent in compliance with applicable laws. Additionally, we may have a legal obligation to process personal data.

Your Rights

If you are located in one of the European Countries, you may be entitled to exercise certain data-subject rights available under applicable laws. These rights may include the right to request access to personal data we hold about you. You may also have the right to object to, or request that we restrict, processing of your personal data. You may also have the right to ask that your personal data be corrected, erased, or transferred to another party. If you would like to exercise any of these rights, you may do so as explained in the Your Choices and Rights section above.

Data Transfers and Privacy Shield

When Thrive360 transfers your personal data to third-party service providers outside of the European Countries, we ensure that appropriate protections are in place under European data protection legislation (which includes either Model Clauses or Privacy Shield compliance). For example, in order to ensure that your personal data is adequately protected when transferred outside of the European Countries, Thrive360 has entered into agreements and other adequacy arrangements with other various entities located outside the European Countries with whom we share your information.

Additionally, if we transfer personal data from the European Union to the United States or Switzerland to the United States, we comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States, respectively.

Questions or Complaints

If you are in one of the European Countries and have a question or concern about how we process personal data you can contact our Data Protection Officer at info@thrive360.com. If we are not able to resolve your issue, you have the right to lodge a complaint with the data privacy authority where you reside.

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 provided below:

Thrive360
P.O. Box 26602
Austin, TX 78755
USA