Therapy Partner Privacy Policy

Last Modified: August 17, 2018

This Privacy Policy discloses the privacy practices for www.therapypartner.com and www.therapyclient.com (including all sub-domains, the "Sites"), which are owned and operated by TPC Acquisition, LLC dba Therapy Partner ("Therapy Partner," "our," "we" or "us"). Therapy Partner provides practice management software to behavioral health practices and practitioners as well as a Client Portal for use by a practitioner’s patients (collectively our “Services”).

This Privacy Policy applies to our collection and use of information from all users of our Services including, without limitation, visitors accessing the Sites or using only free services offered on the Sites, and is incorporated into our Terms of Service and Client Terms. Please note that this Privacy Policy does not address the privacy practices of third parties, including those with whom we may share information as set forth below. Please review the privacy policies of any third parties before you disclose information to them. Through your use of any of our Services you consent to the practices described in this Privacy Policy.

Collection and Use of Personal Information

We collect information, including personal information from you when you set up a paid account, a registered free account, or a free demo account with Therapy Partner, or when you provide your information to us directly through a Client Portal. For purposes of this policy, “personal information” refers to any information about an identified or identifiable individual, including financial account information and Protected Health Information (PHI/ePHI). “Practitioners” refers to the registered Users of the Therapy Partner Services on whose behalf Therapy Partner collects certain consumer and patient information.

We collect personal information from and about Practitioners through our Services, and we collect personal information from and about consumers and other individuals (“Clients”) who utilize the services of these Practitioners.

Personal Information about Clients may be provided to us by Practitioners or authorized Users of a Practitioner’s account, or directly by the Clients themselves. By providing information to us through a Client Portal that is part of a Practitioner’s instance of our Services, Clients consent to our collection of such information and our sharing of that information with the Practitioner as set forth in this policy. In cases where authorized Practitioners Users enter a Client’s Personal Information into our systems, they certify that they have received any required authorization to do so from the Client, and that the disclosure does not violate the PCI DSS, HIPAA, or any other law or regulation.

We generally collect and use information as follows:

From Practitioners with a Free Account or Trial Account

The Sites may require you to give us contact information (name, business name, phone number, e-mail address, etc.) in order to obtain a registered free account or a free trial account. We use this information, and any personal information for your own customers (Clients) that you enter into our Service, to configure your account for sending messages to your Clients, booking appointments, and other uses and activities relating to our provision of the Services. We may also use this information to communicate with you about your free account usage, to provide account-specific technical support, and to provide information to you about additional Therapy Partner products and services that we believe may be of interest to you.

We may also use your personal information to send you promotional products and information about Therapy Partner, the Sites, and/or on behalf of trusted third-parties, subsidiaries and affiliates. Additionally, we may create anonymous records from personal information by excluding information (such as your name) that makes the information personally identifiable to you or one of your Clients. We may use this anonymous information for certain business purposes of Therapy Partner or its subsidiaries or affiliates, including but not limited to, directing future development efforts, analyzing usage patterns so that we may enhance our services, and providing reports based on anonymous non-personal information.

From Practitioners with a Therapy Partner Paid Account

To obtain a Therapy Partner Paid User Account, you must provide contact information (name, address, phone number, and e-mail address) in addition to other personal information and information about your practice, and payment information to authorize automatic recurring billing for your subscription fees. You may also enter personal information for your own Clients as part of using the Therapy Partner service. You represent and warrant that you have the right to provide Therapy Partner with any information, content, data, or materials provided by you, and that the disclosure does not violate the PCI DSS, HIPAA, or any other law or regulation.

We use your personal information to administer your account, to send you messages related to your usage of the Services, and to send you information about our company and your account.

We use billing and financial information (bank account numbers/credit card numbers) to process recurring subscription fees and other fees as applicable, via third-party payment processors. Therapy Partner does not store any bank account or credit card information in its own systems. All payment card data and bank account data is stored by our third party vendors who are contractually required to maintain compliance with the PCI DSS and to adhere to all NACHA rules for ACH payment processing.

We may use your personal information to send you promotional products and information about Therapy Partner, the Sites, and/or on behalf of our parent company, partner companies, subsidiaries and affiliates. We may also create anonymous records from personal information by excluding information (such as your name) that makes the information personally identifiable to you. We may use this anonymous information to direct future development, including but not limited to analyzing usage patterns so that we may enhance our services, and providing reports based on anonymous non-personal information.

From Clients Using a Client Portal

Any Personal Information we collect about a Client (consumer or other individual), whether entered directly into our systems by the Client via a Client Portal operated on behalf of a Practitioner, or entered by an authorized Practitioner User, is used solely for the purpose of providing our Services or as otherwise set forth herein.

As part of utilizing a Client Portal, you may book appointments with Practitioners, send and receive free-form messages to/from Practitioners, make payments to or activate payment plans with Practitioners, and receive, review, complete and upload forms supplied by the Practitioner. In all of those cases, the information collected may be classified as Protected Health Information (PHI/ePHI) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Health Information Technology for Economic and Clinical Health Act (“HITECH”) and their implementing regulations set forth at 45 C.F.R. Parts 160 and Part 164 (the “HIPAA Rules”).

Therapy Partner, via integration with third parties, processes payments for and collects information from Clients via the Client Portal, in cases where the Practitioner has contracted with a third party for payment processing. When you submit a payment or payment account information from a Client Portal, we may collect information necessary to process that transaction, including your name, address, zip/postal code, credit card or financial account number, IP address, and any other information necessary to process or authenticate the transaction. Furthermore, we may collect information about you and your purchase, as well as any personal information or demographic data that you provide at the time of purchase, including (without limitation) your email address, contact information, and other information related to the products/services purchased. This information is shared with third party processors solely for the purpose of processing the transaction, and the third party’s use of the information is governed by the contractual agreements between the Practitioner and the third party.

We may store indefinitely, on behalf of the Practitioner, any Protected Health Information (PHI/ePHI), personal, payment, and other information collected as part of a Client Portal transaction. The Practitioner may have access to that personal information, including your credit card number and Protected Health Information, as part of our Services. The Practitioner may also use the information you provided us for marketing and other similar purposes, and may combine that information with other information the Practitioner holds about you as set forth in the Practitioner’s privacy policy or other terms and conditions between you and the Practitioner. By providing information, including PHI/ePHI to us through the Client Portal you expressly consent to our collection of such information and our sharing of that information with the Practitioner as set forth in this policy.

Additionally, to make our Sites more useful to you, and to adhere to the PCI DSS, the HIPAA Rules, and other applicable laws and regulations, our servers (which may be hosted by a third party service provider) collect personal information and other data from you, including (without limitation) browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. Like most internet services, we automatically gather this information and store it in log files each time you visit our website or access your account on our network.

We may also create anonymous records from Personal Information by excluding information (such as name) that makes the information personally identifiable to a specific consumer or other individual. We may use this anonymous information for certain business purposes of Therapy Partner or its subsidiaries or affiliates, including but not limited to, directing future development efforts, analyzing usage patterns so that we may enhance our services, and providing reports based on anonymous non-personal information. We may also use anonymized PHI/ePHI as authorized by the HIPAA Rules.

Cookies and Similar Technologies

Certain portions of our Services may collect information via cookies, web beacons, pixel tags, and similar digital tracking technologies. These technologies can be used to collect and analyze other information related to the devices you use to access the Services, such as IP addresses, browser types, browser language, unique device identifiers and other information about your computer(s) and/or mobile device(s).

We may also use these technologies to log click-stream or similar data collected from certain portions of our Sites. Generally, this information is collected when you request pages from our Sites, and typically includes information such as the page served, the time, the source and type of browser making the request, the most recent page view, what you clicked on in order to arrive at our Sites, the content you viewed on our Sites, and other similar information relating to your use of our Sites.

We typically use these cookies and similar technologies for essential and functional purposes (e.g. to maintain an active session), to improve the performance and usability of our Sites, and to analyze how users interact with the Services (e.g. to understand how long users stay on a page, how often they return, and how they arrived at our Site). On certain portions of our Sites, we may collect data through these technologies for advertising, remarketing, or other similar purposes. Click-stream and related data is typically used for purposes of system administration, to improve our Services, for marketing and advertising-related purposes, and other similar uses.

Some tracking technologies on our Services may be provided by a third party (which may collect information on its own behalf, or may provide such information to us). For example, we use Google Analytics on our Sites. Google Analytics is a web analytics service provided by Google. Google Analytics uses cookies to collect anonymous traffic data to help use analyze how users use the website. The information generated by a cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for us and providing other services relating to Site activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes described in this Privacy Policy.

To learn more about cookies and similar tracking technologies, and how they can affect your privacy, visit allaboutcookies.org. To learn more about how to opt out of Google’s use of cookies, visit the Google’s Ads Settings, here. Alternatively, you can opt out of certain pieces by visiting the Network Advertising Initiative opt out page or permanently using the Google Analytics Opt Out Browser add on. If you wish to take steps to opt-out of tracking by certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out page at http://www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/optout_nonppii.asp. You may control Facebook’s use of interest-based ads through your Facebook account settings, or may visit the customer support page here. Please note, at this time we do not respond to browser-based "do not track" signals.

When you contact us through the Services

When you submit an online "contact us" or other online inquiry form, create a registered free account, create a free trial account, or when you call, write, fax or otherwise initiate contact with Therapy Partner, we record your contact information (name, address, phone number, and email address) in our CRM (Customer Relationship Management) system. This information is used for answering your questions as well as ongoing marketing communication programs. In some cases, you may be referred to a Therapy Partner online inquiry form via a link on a third party referral website. In that case, any information collected on the Therapy Partner hosted online inquiry form may be shared with the referring party, and that referring party may use it for their own, non-Therapy Partner related, marketing communication programs. If you exchange any messages through our Sites or through our Services, we may store those as well.

From Online Surveys

We may occasionally ask Practitioners to complete optional online surveys. These surveys may ask a Practitioner for contact information and demographic information (like zip code, age or income level). We may use this data to tailor the Practitioner’s experience on the Sites, providing content that we think you might be of interest, and to display content according to the Practitioner’s stated preferences. We sometimes use contact data from our surveys to send a Practitioner information about our company and/or promotional material on behalf of our partners, subsidiaries or affiliates. We never use personal information about a Practitioner’s Clients collected via surveys to contact those Clients directly.

How We Share Information with Third Parties

Except as otherwise set forth in this Privacy Policy or in accordance with any request or consent you provide, Therapy Partner does not sell, share, or in any other way transmit personal information (names, address, phone numbers, financial account information, Protected Health Information (PHI/ePHI), etc.) submitted by non-registered users to any other persons or companies. We reserve the right, however, to use and disclose anonymous information to third parties, at our discretion. Except as limited below, third parties may use information we share with them for any purpose for which we may use such information.

Personal information we collect may be shared with service providers who provide certain services on our behalf or directly on behalf of Practitioners using third party integrations, including but not limited to, identity verification, credit checks, fraud prevention, business intelligence, customer relationship management, bill collection, payment processing, marketing, hosting, and other common technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and in accordance with this Privacy Policy, and in the event that PHI/ePHI will be shared a Business Associates Agreement is established with the third party in compliance with HIPAA Rules. You explicitly consent to our sharing with these parties by using our Service and accepting the terms of this Privacy Policy.

We may provide information, including personal information of registered users to third party service providers and referral partners that work on behalf of or with us to provide some of the aspects of our services, to help us communicate with you, or to provide Practitioners with ancillary services offered by such service providers and referral partners. We may also receive information about you, including personal information, from our third party service providers and referral partners. However, these service providers and referral partners do not have any independent right to disclose this information (except to the same extent we would have a right to disclose that information under this Privacy Policy).

If you make a purchase from a Practitioner via a Client Portal, we may grant access to or share with the Practitioner any and all information we collect as part of that transaction, including credit card and other financial account information and Protected Health Information (PHI/ePHI), except where that disclosure is prohibited by law, regulation or other obligations (e.g. for data security).

If you make an appointment with a Practitioner, message a Practitioner, complete and upload a Practitioner supplied form, or otherwise provide personal information to a Practitioner via a Client Portal we will grant access to and share all information collected with that Practitioner.

You hereby agree that we may share some or all of your personal information with a parent company, subsidiaries, joint ventures, or other companies under common control with us (collectively, "Affiliates"). We will require our Affiliates to comply with this Privacy Policy. If our company or some or all of our assets are acquired by another company, any personal or other information we possess may be a part of the assets transferred, and that company will possess any rights granted to us under this Privacy Policy.

Finally, in extraordinary circumstances, we may share any personal or other information we possess, including but not limited to credit card and other financial account information and Protected Health Information (PHI/ePHI) when necessary or appropriate to: comply with the law; cooperate with law enforcement or national security requirements; respond to lawful requests; comply with law or credit card rules; participate in a lawful federal, state or local government investigation; protect the rights of Therapy Partner, other Therapy Partner Practitioners or Clients, and third parties; or to investigate violations of or to enforce our Terms of Service, Client Terms or Acceptable Use Policy. However, in doing so, we may: (i) dispute demands for release to the extent we believe, in our sole discretion, are unwarranted, illegitimate or overbroad; and (ii) when we determine that it is necessary or appropriate, we will notify you of any requests for release.

In all cases where we share Personal Information with third parties, we will use a "minimum necessary" standard to disclose only that information required to perform the service for which the information is disclosed.

Data Retention Policy, Managing Your Information

We will retain personal information for as long as you remain an active Therapy Partner Paid Account Holder, and/or Therapy Partner Trial Account User, and for a reasonable time thereafter.

We may store on behalf of Practitioners, for as long as a valid business reason exists, which may be indefinitely, any Personal Information, including but not limited to financial account information and Protected Health Information (PHI/ePHI), collected about a consumer or other individual (Client), whether entered directly into our systems by the consumer, or entered by an authorized Practitioner User.

We may retain anonymized and aggregate data indefinitely.

Upon termination of a contract with a Covered Entity, we will remove any ePHI stored in our systems on behalf of that Covered Entity where required by applicable law or the Business Associate Agreement with the Covered Entity; any PHI that we continue to maintain, will be stored and protected per the terms of our Business Associate Agreement with the Covered Entity.

Security

Therapy Partner has security measures in place designed to protect against the loss, misuse and alteration of the information under our control, as described in our security page.

Choice/Opt-Out

You may opt-out of receiving marketing communications from us by following the opt-out instructions we include in such communications.

To the extent required by law, you may choose to opt out of sharing with any other parties with whom we may share your personal information; however, you may be unable to use the Services or certain features if you wish to limit such sharing.

Accessing, Correcting and Deleting your Information

Therapy Partner acknowledges the right of individuals to access their personal data. If you are a Practitioner, you may access and modify your personal and other account information using your account settings page. You may also access, change and modify information previously provided or collected by sending an email to Therapy Partner at privacy@therapypartner.com to initiate changes or modifications or to obtain a file for review. Note that Therapy Partner will require you to verify your identity prior to releasing any personal information.

You may close your Therapy Partner account by emailing Therapy Partner at info@therapypartner.com To fully close your Therapy Partner account you may also be required to complete a merchant account closure form with the third party provider of those integrated services.

Further, you may request that your personal information be removed from all Therapy Partner systems. This request must be made in writing to the address provided below. Note that if you request removal of your personal information you will no longer have access to any existing Therapy Partner account and will not be able to use any Therapy Partner product or service. Therapy Partner reserves the right to retain certain account information for its recordkeeping or compliance purposes.

If you are a patient, customer, or otherwise do business with a Covered Entity that utilizes Therapy Partner systems as part of providing service to you, you can request that the Covered Entity provide you with access to the Personal Health Information (PHI/ePHI) stored in Therapy Partner systems on its behalf, that it make changes to that ePHI, and/or that the ePHI be deleted from Therapy Partner systems.

Note that using the system delete function to remove any data related to your Clients, or to remove any personal data about your company or its authorized Users, only restricts viewing that data from any system interface and prevents utilizing that data for any system function. It does not permanently delete the data from Therapy Partner systems. To have any personal data permanently deleted from Therapy Partner systems, you must make an official request in writing, to the address provided below or by emailing privacy@therapypartner.com, that includes the specific information that you would like permanently deleted from Therapy Partner systems. Note that Therapy Partner will require you to verify your identity prior to executing any request to permanently delete data.

California residents may request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. You may make one request each year by contacting us as set forth below.

Dispute Resolution

If you have any questions or concerns, please contact Therapy Partner by e-mail at privacy@therapypartner.com. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If we are unable to reach a resolution to the dispute, you and Therapy Partner will settle the dispute exclusively as set forth in the Terms of Service.

A Note About Children

We do not intentionally gather information about visitors who are under the age of 18, do not offer Practitioner accounts to children under the age of 18, and prohibit Providers from granting Client Portal access to children under the age of 18 without explicit permission from an authorized parent or legal guardian. If you are under the age of 18 you should not use our Sites or Service without permission.

International Transfers

If you are accessing our Services from outside of the United States, any information provided will be transferred to us or our service providers in the United States. Regardless of where your information is collected or transferred, the information will be treated in accordance with this Privacy Policy. You consent to such transfer through your continued use of our Services. Please note that Therapy Partner processes information on behalf of its Practitioners. Practitioners may be responsible for obtaining your consents relating to the collection, use, transfer and other processing of your Personal Information, may provide additional notices affecting our processing of your Personal Information, and may provide for additional limitations or permissions with respect to our processing of your information in order to comply with applicable law.

Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at therapypartner.com/privacy.html. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

Contacting Us

Therapy Partner
1515 Wynkoop St, Suite 250
Denver, CO 80202
P: 877-232-9847
E: privacy@therapypartner.com