Privacy Policy

SECTION 1: Data Collection and Processing

Do we collect, store, or process your data? 

At Embark Therapy, we collect and process data necessary to provide you with high-quality mental health services. The types of data we handle include information required to operate our Platform effectively and ensure you can utilize our services efficiently. While we send out communications to assist in our service provision, such as appointment reminders or therapy materials, we ensure that your consent is respected at every step. We also offer you the choice to opt-out of marketing communications at any time. Moreover, we maintain strict protocols, only sharing data with third parties upon your explicit consent, particularly for purposes aligned with enhancing your therapy experience.

What specific data are we processing, and why do we collect it? 

The data we process varies depending on your interactions with our website, app, or platform. Below are the specific types of data we collect and their respective purposes:

• Visitor Data: When you engage with our website or app, we collect data such as the pages you visit, the features you use, your session duration, any errors encountered, and information regarding your device, browser, and IP address. If consented, we may share non-sensitive data with third parties for improved service delivery.

Purposes:

• Enhancing connection with therapy services.

• Facilitating tools for you and your therapist.

• Improving the quality and personalization of therapy services.

• Legal compliance and safety assurance.

• Onboarding Data: Gathered when you fill out our initial service questionnaire, helping us tailor the therapy experience to your needs.

• Account Data: Includes the account details you set up with us, like your chosen username and demographic information. We don’t collect email addresses to respect your privacy further but may require other forms of contact information, such as a phone number, for essential communication.

• User ID: Every user is assigned a unique ID for platform functionality and personalized service.

• Transaction Data: Details of your transactions with us, including payments and service registrations, are processed for billing and service improvement purposes.

• Member Engagement Data: We monitor your platform interactions, excluding the content of therapy sessions, to enhance service quality and user experience.• Therapy Data: This includes your shared information with your therapist, which is strictly used to facilitate and improve your therapy experience.

Do we process location data? 

We process your IP address for location approximation to customize the platform experience geographically, such as localizing content to your state or country. However, we do not use precise location data (e.g., GPS) unless it is essential for therapy regulation compliance or emergency situations.

For further information on our data retention policies and your rights regarding data erasure, please refer to the later sections of this policy.

Contact for Inquiries: If you have any questions about how we collect and use your data, please contact us at [email protected]

SECTION 2: Data Sharing

What are the purposes for sharing my data? 

At Embark Therapy, your data may be shared only under specific circumstances that are essential to providing you with our specialized therapy services:

1. Compliance with Laws: We may share your data if required by law, such as in response to a subpoena or similar legal process. While we prioritize your confidentiality, certain situations may necessitate the disclosure of your information.

2. Operational Support: A limited number of our employees or associates might access your data to offer essential support services. However, they operate under strict confidentiality agreements.

3. Service Providers: We collaborate with certain service providers who assist us in operating the Platform, enhancing your experience, and ensuring seamless service delivery. This includes:

• Data Hosting and Storage: Utilizing services like cloud hosting for secure data management.

• Technology and Customer Service Providers: Integrating tools to facilitate live sessions, manage queries, and improve service functionality.

• Payment Processing: Engaging with services such as payment gateways for secure transaction handling.

4. Therapist Collaboration: To optimize therapy matching and service delivery, we may share necessary information with our therapists and associated professionals.

5. Non-identifiable Group Data: With your consent, aggregated data that does not identify you personally may be shared with third parties, like employer programs, for statistical or analytical purposes.

6. Business Transitions: In the event of a merger, acquisition, or bankruptcy, your data may be part of the transferred assets.7. Public Information: Any information you make public on the Platform is accessible to others. Be mindful of the personal details you share.

8. Advertising and Analytics: With your explicit consent, we may share certain non-sensitive data for targeted advertising and analytical purposes, aimed at enhancing your experience and our service offerings.

How do we comply with legal requirements? 

Embark Therapy adheres to legal obligations by cooperating with government and law enforcement agencies. However, the decision to release therapy notes or communication rests with your therapist, adhering to strict confidentiality rules and ethical guidelines.

Do we sell your data? 

We do not sell your personal data. California residents should note that “selling” under state law includes exchanges of personal information for value; opting into certain services like targeted advertising might fall under this definition.

Are we using your data for advertising? 

We engage in minimal advertising to reach individuals seeking mental health support. Should you opt into advertising services, specific anonymized data might be utilized to tailor advertisements to your interests without compromising the privacy of your therapeutic communications.

SECTION 3: Data Retention, Erasure, and Exporting

How long do we retain your data and how can you request data erasure?

Embark Therapy is dedicated to retaining your data only as long as necessary to provide you with quality mental health services and in line with relevant legal standards.

• Data Retention: We retain different categories of your data for varying durations, depending on whether you have initiated therapy and other specific factors related to your engagement with our services. Generally, if you have not initiated therapy, your data is kept for three years after your last interaction with us, then securely erased. If you have engaged in therapy, we retain your data for ten years following your last session to comply with healthcare guidelines and legal requirements.

• Erasure Requests: Should you decide to request the deletion of your data, you can contact us directly at [email protected]. We will guide you through the process for requesting data erasure and ensure your data is handled respectfully and in accordance with your wishes.

Exercising Your Data Protection Rights: You have the right to access, correct, or delete the personal data we hold about you under various data protection laws.

• Requesting Data Erasure: If you wish to erase your personal data from our records, please contact us at [email protected] for direct support. We will provide you with the necessary guidance to ensure your data is removed in compliance with legal and ethical standards.

• Requesting Data Access: If you seek access to your personal data, contact us at the provided phone number. We are committed to providing transparency and access to your data upon request.

Legal and Regulatory Limits to Data Erasure: While we aim to accommodate your data erasure requests, there are circumstances under which we cannot fully comply due to legal, ethical, or regulatory requirements. These exceptions include:

• Legal Holds: If your data is subject to a legal hold or court order, we may be required to retain it beyond your request for erasure.

• Regulatory Compliance: Certain information may need to be retained to comply with professional and legal standards, especially concerning medical records and therapy documentation.

Requesting a Copy of Your Data: If you wish to receive a copy of the personal information we hold about you, please contact us at [email protected]. We will assist you in accessing your data and provide you with the information necessary to understand the data we’ve collected about you.

Contact Information for Data Requests: For all data-related requests, including erasure and access: Embark Therapy, 2001 Barrington Avenue, Los Angeles, California 90025, United States

Please remember, your privacy and the security of your data are of utmost importance to us at Embark Therapy. We are here to address any concerns or questions you may have regarding your personal information and our privacy practices.

SECTION 4: Security and Anonymity

How do we keep your data secure? 

At Embark Therapy, we prioritize your security and privacy by employing industry-standard best practices and robust security measures. While we recognize that no internet-based service is entirely risk-free, we strive to protect your data against unauthorized access and disclosure. Our commitment to your safety is reflected in the following practices:

• Data Encryption: All communications between clients and therapists are protected with strong encryption protocols.

• Secure Infrastructure: Our servers and data storage solutions are designed for optimal security, ensuring your personal and therapy data remain confidential and intact.

• Modern Security Practices: We follow contemporary best practices for web browsing encryption (SSL) and database management to safeguard your information.• Active Monitoring: Our security team actively monitors and evaluates our systems to prevent and address potential threats. We maintain a vigilant posture with 24/7 security operations.

Staying Safe Online: To ensure your safety, please be cautious of phishing attempts and unsolicited requests for your personal information. Embark Therapy will never ask for sensitive details in an insecure manner. Additionally, be aware of external links and their associated privacy practices, as they may differ from ours.

Anonymity in Therapy: While complete anonymity online is challenging, Embark Therapy respects your desire for privacy. When signing up, you are not required to use your real name, allowing a level of anonymity. We only request essential contact information necessary for the effective delivery of our services and in case of emergency situations. Your interactions with your therapist, including messages and therapy content, remain confidential between you and your therapist.

Data from Children: Embark Therapy does not knowingly collect personal information from children under the age of thirteen. If such information is inadvertently gathered, it will be deleted promptly upon discovery.

Visibility of Your Therapy Interactions: Your therapy interactions, such as messages, worksheets, and journal entries, are visible only to you and your assigned therapist. If consented, certain interactions may be reviewed for quality assurance by a licensed therapist within our team but are never shared externally.

SECTION 5: Cookies and Web Beacons

What is a cookie or web beacon?

In the digital world, “cookies” and “web beacons” are tools used to enhance and personalize your online experience. A cookie is a small data file stored on your device to help websites remember your preferences and activities. Embark Therapy utilizes cookies to improve the performance and functionality of our platform and to streamline your interactions with our services.

A web beacon, also known as a pixel, is a tiny, often invisible, graphic image placed on a website or in an email. It is used to monitor user behavior and site traffic, providing insights that help us improve our services.

What are we using cookies and web beacons for? 

At Embark Thearpy, cookies and web beacons serve several functions:

• Performance Enhancement: They allow you to log into our platform seamlessly and remember your preferences.

• Usage Monitoring: We analyze how you interact with our platform to improve our services and offer a more personalized experience.

• Legal Compliance: Ensuring we adhere to the relevant laws and regulations.

• Advertising: If you consent, we may use cookies for targeted advertising to provide you with more relevant information.How can you opt out of cookies, web beacons, and other tracking technologies? If you prefer not to use cookies or web beacons, you have the option to opt out. While we do not directly collect email addresses, and therefore do not send direct marketing emails, you can manage your preferences directly through the settings in your web browser. You can delete existing cookies, disable future cookies, and opt out of web beacons. For detailed instructions on how to adjust your cookie settings, please refer to your browser’s help documentation.

Contact Information for Privacy Inquiries: If you have any questions about our use of cookies and web beacons, or how to opt out, please feel free to contact us at: Embark Therapy, 2001 Barrington Avenue, Los Angeles, California 90025, United States

Your privacy and the integrity of your online experience are of utmost importance to us at Embark Therapy. We are committed to providing clear, transparent information about our use of cookies and other tracking technologies.

Additional Privacy Notice for California Residents

This Privacy Notice for California Residents complements the Embark Therapy Privacy Policy to adhere to the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”) of 2020.

The CCPA and CPRA grant California residents certain rights concerning their personal information, including the right to be informed about what kinds of personal information we have collected over the past twelve months and the reasons for its use or disclosure, as well as the right to request corrections to their personal information.

Data Processed by Embark Therapy: The categories of personal information we have collected, along with the purposes for collecting such data, align with the sections outlined in this privacy policy:

• Identifiers: This includes information such as your name (or pseudonym used for therapy sessions), IP address, and other similar identifiers.

• Personal Information: As defined in the California Customer Records statute, this could include your contact details used for therapy sessions.

• Protected Classifications: Any demographic information provided for counseling suitability and compliance.

• Commercial Information: Details related to the services purchased or considered, as applicable.

• Internet Activity: Your interaction with our service platform.

• Geolocation Data: General location data derived from your IP address.• Professional or Employment-Related Information: Particularly relevant if services are provided through employer programs.

• Sensory Data: Audio and visual information during therapy sessions, if applicable.

Your Rights Under CCPA and CPRA: As a California resident, you have the right to request information about our collection, use, and disclosure of your personal information over the past twelve months, and to request the deletion of your personal information. You are also entitled to opt out of the sale of your personal information, if applicable.

Exercising Your Privacy Rights: To exercise the rights described above, please contact us directly at [email protected]. Upon receiving a request, we will verify your identity before disclosing the requested information or deleting your information.

Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. This means that we will not deny you services, charge you different prices, or provide a different level or quality of services just because you have exercised your rights.

Data Deletion and Correction Requests: You can request the deletion of your personal information from our records or ask for corrections to your personal information by contacting us at the phone number provided. Your information will be processed in accordance with our retention policy and legal obligations.

Do Not Sell My Personal Information: Embark Therapy does not sell personal information in the traditional sense. However, under CCPA, certain sharing activities such as targeted advertising might be considered a sale. California residents can opt out of these activities by contacting us at [email protected].

Other California Privacy Rights: Under California’s “Shine the Light” law, California residents may request and obtain from us once a year, free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes.

Contact Information: For further information or to exercise your rights, please contact: Embark Therapy, 2001 Barrington Avenue, Los Angeles, California 90025, United States

Your privacy is critically important to us, and we are committed to complying with all applicable laws and regulations to protect it.

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