PRIVACY POLICY

Effective Date: February 11, 2022

Thank you for using our Services. Your privacy is very important to us, and it is our intent to comply with any applicable law regarding the personal information we collect about you. This Privacy Policy explains our processing of the personal data collected through therapha.com (the "Site") and our related mobile application(s) (together with the Site, the "Services"). By using the Services, you agree to this Privacy Policy. The Services are provided by Therapha, Inc. and we are a data controller. We are committed to protecting and respecting your privacy so you can navigate and use the Services safely.

This Privacy Policy discloses what information we collect about you, how we gather it, how we use and share it, and what rights you have. This Privacy Policy may change from time to time, so we recommend that you read it periodically. This Privacy Policy is incorporated into our Terms which, together with this Privacy Policy, govern your use of the Services. We want to make this Privacy Policy as clear as possible. If, however, you have any questions, comments, or concerns about this Privacy Policy, please send us an email at contact@therapha.com.

As a user of our Services or a visitor to our Site, you must accept this Privacy Policy. If you do not consent to the terms of this Privacy Policy, do not access the Site or use the Services. By using the Services or accessing our Site, you agree to this Privacy Policy and to our processing of Personal Information as described in this Policy.

1. Information We Collect About You

Some of the information we collect about you identifies you. If it identifies you, we call it "Personal Information." Personal Information does not include any information that is publicly available or information that has been anonymized to the point where a specific individual or household cannot be identified from the remaining information. If we associate non-identifiable information with information that identifies you, we will treat it as Personal Information.

We only collect and use your Personal Information when we have a legitimate reason for doing so. We only collect Personal Information that is reasonably necessary to provide our Services to you and for the purposes set forth in this Policy. The information we collect can come from information you provide, information we collect through automated means, and information we collect from other sources.

Information You Provide.

You provide Personal Information when you interact with us. For example, when you set up an account ("Account") or interact with the Chatbot we will need to collect demographic and personal details about you. The Personal Information you provide may include the following:

Personal details, including your name, email address, and phone number;
Demographic information, such as age or gender;
Transaction information;
Account information, such as your user name and the password you use to access our Services;
Profile information associated with you;
Health-related information (for more information, see below); and
Other Personal Information you choose to provide us when you interact with us.

You are responsible for the accuracy of the Personal Information that you submit, and we recommend that you personally enter all Personal Information. If you need assistance providing Personal Information to us or using the Chatbot, please contact your healthcare provider. If a third-party enters Personal Information on your behalf, please review and confirm its accuracy. We do not collect Personal Information unless you provide it to us. You can choose whether you provide Personal Information to us, but if you do not provide it to us, we may not be able to offer certain features of the Services.

Information You Provide through the Chatbot.

Our Services provide an interactive Chatbot to collect information from you about your care ("Chatbot"). Any information provided by you through the Chatbot will be saved, translated into a clinical summary, and provided to your healthcare provider. Any information you provide through the Chatbot may become a part of your medical records.

Health-Related Information.

Your Healthcare Provider. Some of our Services are interactive and may request that you submit health-related information, along with other information such as your age and gender. We use this information to provide the Services to you and to provide information to your designated healthcare professional. We may obtain health information from you or from your health care provider upon your request and prior approval. We will not collect your health information without first obtaining your consent.

Some health information may be considered Protected Health Information ("PHI"). PHI is identifiable health information that we create, receive, maintain, or transmit on behalf of an entity regulated by the Health Insurance Portability and Accountability ("HIPAA") Act. Not all of your health data is PHI, even if it identifies you. When you give your health care provider permission to send data to us, the information may not be protected by HIPAA. Ask your health care provider for more information when you authorize the disclosure of information to us. If we have PHI, we will use and disclose it only in accordance with HIPAA.

Patient Portal.

The Patient Portal is a secure place to gather, store, manage, and share your Personal Information with your healthcare professional and provides tools and services to better manage your health. You must register with the Services to use the Patient Portal. The Patient Portal uses information that you provide to send you and/or your healthcare professional personalized emails or secure electronic messages.

Except for providing information to your healthcare professional, we do not allow any third parties to gather any data about you in connection with your use of the Patient Portal including through the use of cookies and other tracking technologies. The Patient Portal does not use any information that you submit to deliver any advertisements to you on or off the Site.

Therapha Inc. is committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone, and applying the relevant accessibility standards.

Usage and Device Information.

When you use our Services, we automatically collect certain browser or device-generated information by using various types of technology. This information includes, but is not limited to:

Your IP address or other device addresses or IDs;
Web browser and/or device type;
The pages or other content you view or interact with on the Services;
The server from which you are accessing our Services; and
The date, time, and place of accessing our Services.

We may also use these technologies to collect information regarding your interaction with email messages, such as whether you have opened, clicked on, or forwarded a message.

Cookies and Other Tracking Technologies.

Like most online services and mobile applications, we use cookies and similar tracking technologies like web beacons, to record details of your activities through our Services ("Usage Information"). Usage Information does not identify you as an individual. Please see Section 7 for more information.

Analytics.

We may work with different companies that offer services that can assist us in better understanding how users interact with and use the Services. For example, we may use a product called [Google Analytics by permitting Google] to use technologies such as web beacons and cookies to collect certain non-personally identifiable information that helps us understand your use of our Services. We may permit [Google] and other third-party analytics providers to combine information collected through our Services with information collected from third-party services, and these analytics providers may use this information to help us better understand our users. These analytics providers may also use this information to help their other customers better understand their users.

Information from third parties.

We may, from time to time, supplement the information we have about you with information from third parties for various purposes, including to enhance our ability to serve you and to offer you opportunities that may be of interest to you. We do not intentionally seek out any information about you from third-parties that you have not consented to providing or sharing.

Other sensitive information.

When you contact customer support or communicate with us in any other way, we'll collect whatever information you volunteer or that we need to resolve your question. Note that our ability to resolve your question could be dependent upon you disclosing the information we require.

2. How We Use This Information

We use your information to improve your experience and to deliver the Services you have requested. We use the information for our business purposes, which include the following:

Planning and managing our activities, including better marketing of our Services, through researching and analyzing your use of the Services and the collection of feedback or use of customer surveys;
Customizing or personalizing your experience with our Services;
Providing you with requested customer support or other services;
Contacting and communicating with you;
Administering our Services, such as managing agreements with our suppliers or your healthcare provider;
Monitoring aggregate usage metrics such as total number of visitors and tracking behavior on the Services;
Developing new features, functionalities, and services;
Operating, evaluating, maintaining, improving, or developing our Services and Site operation;
Protecting and ensuring safety of the Services, our confidential and proprietary information, and our employees;
Managing, protecting against and investigating fraud, risk exposure, claims and other liabilities, including but not limited to violation of the Terms of Service, laws or regulations;
For internal recordkeeping purposes;
Anonymizing your Personal Information for further internal and external uses in a manner that does not identify you;
The ways we describe elsewhere in this Privacy Policy.

When you communicate with us through any means such as chat/ email, we may use your contact details for marketing communications. You can unsubscribe from such communications anytime you wish to do so.

3. How we Share Your Information

Except as described elsewhere in this Privacy Policy and below, we do not disclose your Personal Information without your consent.

Related Parties and Affiliates.

We may share Personal Information with a parent, subsidiary, or affiliate of our company.

Our Services.

We may share Personal Information as necessary to provide our Services, complete a transaction, or fulfill your requests. We may share your information to monitor, improve, or better market our Services such as with third party cookie providers.

Healthcare Providers.

We provide personal and medical health information that you voluntarily disclose to the healthcare professional you designate when you register with our Services.

Service Providers and Professional Advisors.

We work with third party service providers to help us provide the Services and to assist us in operation, including, without limitation, in the areas of email management and deployment, analytics, marketing, advertising, market research, identity and professional credential validation, content distribution, customer service, payment fulfillment, even logistics, website maintenance and data storage and security, and we share your Personal Information so they can fulfill their obligations to us. We may also share your Personal Information with our professional advisors such as our legal representatives or insurance brokers.

Aggregate and Anonymous Information.

We may make automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third-parties for various purposes, including: (a) for compliance with various reporting obligations; (b) for business or marketing purposes; (c) to assist us in improving the products or Services; or (d) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain content, services, advertisements, promotions, and/or functionality available through the Services.

Legal Requirements and Law Enforcement.

We will disclose your Personal Information if we have a good faith belief that such disclosure is necessary to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order and to meet national security or law enforcement requirements. We will also disclose your Personal Information to respond to a physical threat to you or others or to defend or assert legal rights of us or others.

Dispute Resolution.

We will disclose your Personal Information as necessary to resolve disputes, inquiries or complaints. We may disclose your Personal Information if we believe you have violated our Terms of Service.

Sale of Personal Information for Marketing.

We do not pass on, sell, rent or lease any Personal Information, healthcare, or medical information to any third party for commercial or marketing purposes without your consent. There are some programs or features that automatically pass on Personal Information, but you will have the ability to opt-in or opt-out of this feature at the time.

Business Transfers.

We may also share your information in the event we are transferred or sold to another entity as a result of a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

Other Sharing.

We reserve the right to disclose personal information that we believe, in good faith, is appropriate or necessary to: (a) take precautions against liability, (b) protect us or others from fraudulent, abusive, or unlawful uses or activity, (c) investigate and defend us against any third-party claims or allegations, (d) protect the security or integrity of the Services and any facilities or equipment used to make the Services available, or (e) protect our property or other legal rights, or the rights, property, or safety of others.

Your Consent.

We may disclose your Personal Information to a third party in a manner not addressed by this Privacy Policy, subject to your consent at such time.

We may share information that is not personally identifiable or is not otherwise subject to restrictions in this Policy.

We expressly disclaim any and all liability for the actions of third parties. The privacy practices of any third parties are outside the scope of this Privacy Policy and their use or disclosure of your information (including your Personal Information) are governed by their own privacy practices.

4. Your Responsibilities

You are responsible for securing and maintaining the privacy of your login information and password(s) and verifying that your Personal Information is accurate and current. We are not responsible for the privacy or security of any information on the Services that you make publicly available or what others do with information you share with them. Please think carefully before deciding what information you share, including Personal Information, in connection with your use of the Services.

Be aware that certain Personal Information and other information in connection with your use of the Services may be stored on your Device (even if we do not collect that information). You are solely responsible for maintaining the security of your Device from unauthorized access.

We at Therapha™ strongly encourage our users (both patients and clinicians) to provide us with feedback, suggestions to improve the efficiency and efficacy of the tool for the benefit of the medical community and the population in general.

5. Your Choices and Rights

You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you sign up for or use our Services or in the context of your use of our Services. You may be provided with instructions and prompts within the experiences as you navigate the Services. If you do not want your Personal Information used or shared as provided in this Privacy Policy, you should not use the Services.

You may, of course, decline to share certain Personal Information with us in which case, we may not be able to provide some of the features and functionality of the Services.

Commercial Email Opt-Out.

When you sign up to receive digital communications for any of our Services, you can choose to opt-out of receiving additional digital communications from us or our advertisers or sponsors. You can unsubscribe from email and other digital communications by following the instructions in the communication or by sending a request to us using the contact information listed below or through the Contact Us link provided at the bottom of every page of the Site.

If you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Services.

We do not share Personal Information with third parties for their own direct marketing purposes unless you give us permission to do so.

Applicable Law.

Subject to applicable law, you may have different rights regarding our use of your information. For example, you may have the following rights:

Right to request access to and to check what Personal Information we maintain about you;
Right to request copies of your Personal Information;
Right to update and correct inaccuracies in your Personal Information;
Right to have your Personal Information deleted;
Right to request restriction of the collection, processing, or use of information about you;
Right to request data portability;
Right to lodge a complaint with a supervisory authority;
In some cases, the right to object to our processing of your information and to withdraw your consent to our processing of your information.

You can perform many of these actions by going back to the specific Service, logging-in, and making the desired change.

When you request the deletion of your information, object or withdraw your consent to the processing of your information, we may not be able to provide all the features of the Services to you. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to the Services from our servers.

To exercise any of these rights please contact us using the contact information listed below or through the Contact Us link provided at the bottom of every page of the Site. We will promptly review all such requests in accordance with applicable laws.

6. Children's Privacy

The Services are designed and intended for use by adults and are not intended for nor designed to be used by children under the age of eighteen (18) years, except minors sixteen (16) and older with the permission of and oversight by their parents or legal guardians. We do not intend to collect Personal Information from any person we know is under the age of sixteen (16). We direct potential users under sixteen (16) years of age not to use the Services. If we learn that Personal Information of persons younger than sixteen (16) years of age has been collected, then we will take the appropriate steps to delete this information. To make such a request or if there are any questions or concerns about this Privacy Policy or its implementation, please contact us using the contact information listed below or through the Contact Us link provided at the bottom of every page of the Site.

7. Cookies and Other Tracking Technologies

"Cookies" are alphanumeric identifiers that are stored on a computer, browser, laptop, tablet, mobile phone, or other device (each, a "Device"), which collect information about your activity, browser, and Device. A "web beacon" (sometimes referred to as pixels and tags) is a small object or image that is embedded into a web page, application, or email, and is used to track activity.

We may use both session (for the duration of your visit) and persistent (for the duration of a fixed period of time) cookies and tracking technologies. A cookie does not provide us with access to your computer or to Personal Information beyond what you provide to us. We do not store Personal Information in cookies.

Some cookies are necessary to use the Services, and these cannot be disabled. Other cookies are not required to use our Services and may be disabled or deleted, but this may prevent you from properly using the Services. Most browsers allow you to adjust your cookie settings.

We may use cookies to collect information about the areas within our Services that you view, your access times and frequency of your visits, your IP address, and the URL that has referred you to our Services. This helps us identify users, track behavior on the Services, keep the Services secure, and improve the Services' performance. We may also use this data to help us understand our users and to shape our marketing.

8. How Your Information is Secured

We follow generally accepted industry standards, including the use of appropriate administrative, physical, and technical safeguards, to protect the Personal Information submitted to us. For example, when you enter Personal Information, we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology.

Therapha™ is hosted entirely on Amazon Web Services (AWS), providing end-to-end security and privacy features built in. Our team takes additional proactive measures to ensure a secure infrastructure environment. For additional, more specific details regarding AWS security, please refer to https://aws.amazon.com/security/.

Despite efforts to protect your Personal Information, no method of electronic transmission or storage is 100% secure, and 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.

If we learn of a security system breach, then we may attempt to notify you so that you can take appropriate protective steps. We may post a notice through the Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing, and we will follow all applicable laws.

9. How Long We Keep Your Personal Information

We will retain your Personal Information as long as your Account is active or as needed to provide you Services. At any time, you can remove your Personal Information or instruct us to remove it, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our servers. See “Your Choices and Rights” for more information on how you can remove your Personal Information.

Even though you may make changes or request deletion of your Personal Information, we may retain all information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

10. Note to Users Outside of the United States

Therapha™, our technical infrastructure, and our Services are located and operated in the United States and India. The Personal Information that you provide to us is stored on servers located in the India. If you are located in another jurisdiction, you should be aware that in order to provide the Services to you, we must transfer your Personal Information to the United States and India where it will be stored and processed in accordance with this Privacy Policy.

We may transfer your information outside the United States and India to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in the United States, India, and elsewhere. The United States, India, and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take commercially reasonable steps to protect your Personal Information.

If you do not consent to such transfer, you may not use the Services. If you choose to access and use the Services from outside the United States, you acknowledge that you are doing so on your own initiative, at your own risk, and are responsible for compliance with applicable laws.

11. Changes to our Privacy Policy

We reserve the right to amend our Privacy Policy at any time and as needed. When we make changes to this Privacy Policy, we will post the updated Privacy Policy on our Site and update the Privacy Policy’s effective date. Your continued use of any of the Services following the posting of changes constitutes your acceptance of such changes.

12. Contact Us

If you have any questions about the Services, or this Privacy Policy, please contact us at:

Therapha, Inc
467 Phillips Hill Road,
New City,
New York,
USA.
contact@therapha.com