LAST UPDATED: NOVEMBER 25, 2024
Privacy Policy
Getting Support Together, LLC is focused on user knowledge and wants to ensure you understand how we may collect and use or disclose your personal information in accordance with laws applicable to our business. This Privacy Policy describes our practices regarding information collected from you at any point during your browsing on getsupporttogether.com (the "Website"), through our social media pages you may engage in where you may be accessing this Privacy Policy, through any software applications made available by us for use on or through computers and mobile devices (the “Apps”), and from any HTML-formatted email messages sent by Getting Support Together that link to this Privacy Policy (all of the foregoing, collectively referred to as the “Services”).
Personal Information We May Collect
“Personal Information” is information that identifies you as an individual or relates to an identifiable person, including: name, email address, and health information in connection with the forms, surveys, and questionnaires (the "Knowledge Base") we make available to assist in evolving the Website to continue offering needed resources. If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
We may collect Personal Information in a variety of ways, including:
- Through the Services: We may collect Personal Information directly from you through the Knowledge Base, e.g., when you answer a survey or register for an account.
- From Other Sources: We may receive your Personal Information from other sources with your consent or as permitted by applicable law, public databases, joint marketing partners, and other third parties.
How We May Use Personal Information:
- To respond to your inquiries, fulfill your requests, and send you requested communications, such as the results of any Knowledge Base you have submitted. To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions and policies.
- To personalize your experience on the Website, for example, by presenting resources which match your inquiries.
- For our internal management and business purposes, such as data analysis, developing new services, enhancing, improving or modifying the Knowledge Base, audits, fraud monitoring and prevention, and identifying usage trends.
- As we believe to be necessary or appropriate, and only as permitted under the Health Insurance Portability & Accountability Act and amendments thereto (HIPAA) or other applicable law: (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (c) to protect our operations or those of any of our affiliates, including in connection with investigating security incidents; or (d) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- For such other purposes as you may consent or as may be authorized or required by applicable law.
Your Personal Information may be transferred or disclosed:
- To our third party service providers who assist us to provide the Services (such as website hosting, data analysis, information technology and related infrastructure provision, email delivery, auditing and other services), and with whom we have a contract that includes appropriate privacy obligations.
- As we believe to be necessary or appropriate, and only as permitted under HIPAA or other applicable law: (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (c) to protect our operations or those of any of our affiliates, including in connection with investigating security incidents; or (d) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- To such third parties and for such purposes to which you consent or which may be authorized or required by law.
Other Information
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- General demographic information
- Aggregated information
If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
How We May Collect Other Information
We may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Through your use of the Apps: When you download and use the Apps, we may track and collect usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), and compile statistics about usage of the Services and response rates.
- Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
- IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
- Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. You may be permitted to allow or deny such use, but, if you do, we may not be able to provide you with the applicable personalized services and content.
- From you: Information such as your preferred means of communication is collected when you voluntarily provide it.
How We May Use and Disclose Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information if it is combined.
Third Party Services
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Services.
Security and Retention
We seek to use administrative, physical, and technical safeguards that are reasonable and appropriate for the protection of the Personal Information in our custody or control. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below. We will retain your Personal Information in a file specific to you at our offices in 60 Madison Ave., 2nd floor, New York, NY 10010 and the data centers of our service providers. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. As our operations are conducted from the US, all Personal Information that we collect is used and stored in the US, is subject to US laws, and may be subject to disclosure to US governments, courts or law enforcement or regulatory agencies pursuant to those laws.
Individual Rights
The following six rights are collectively referred to as the “Individual Rights.”
- The right to access – You have the right to request copies of your personal data that Spring Care, Inc. possesses. We may charge you a small fee for this service;
- The right to rectification – You have the right to request that Spring Care, Inc, correct any information you believe is inaccurate. You also have the right to request that Spring
Care, Inc. complete information you believe is incomplete; - The right to erasure — You have the right to request that Spring Care, Inc. erase your personal data, under certain conditions;
- The right to restrict processing – You have the right to request that Spring Care, Inc, restrict the processing of your personal data, under certain conditions;
- The right to object to processing – You have the right to object to Spring Care, Inc.’s processing of your personal data, under certain conditions; and
- The right to data portability – You have the right to request that Spring Care, Inc. transfer
the data that we have collected to another organization, or directly to you, under certain conditions.
If you would like to exercise any of your Individual Rights regarding Personal Information that you have previously provided to us, you may do so by logging into your account within the Services or by contacting us in accordance with the “Contacting Us” section below. In your request, please make clear what Individual Right you are exercising. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in compliance with applicable law. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information. We may be prevented from complying with a request to exercise an Individual Right. In such circumstances, we will respond to your request to exercise your Individual Right with a response stating that we cannot comply with such a request and, if legally allowed, why.
Use of Services by Minors Under Age 13
We are committed to protecting the privacy of children in connection with the use of our Services. This section explains our online information collection, disclosure, and parental consent practices with respect to information collected from children under the age of 13 (“child” or “children”) in accordance with the U.S. Children’s Online Privacy Protection Act and its rules (collectively, “COPPA”). For purposes of this section, any references to a parent also encompasses legal guardians. This section only applies to children under the age of 13 and supplements the other provisions of this Privacy Policy.
Our Services include online services that may be used to facilitate mental health care for a child. Children under the age of 13 cannot directly register for Spring Health services; we require that all child accounts be created by a parent or legal guardian, and associated with the parent’s or legal guardian’s account, in order to ensure that we can comply with our notice and consent obligations under COPPA. Please note that certain state privacy laws may permit a child to directly obtain certain types of health care services independent of their parent or legal guardian, which is a right separate from registering for an account with Spring Health.
During the account registration process, the parent or legal guardian can create a child’s account by following our instructions for doing so and providing certain information about the child, such as name, date of birth, email address, and/or mailing address. Please do not provide account credentials to your child. If your child directly uses your Spring Health account, either with or without your permission, we may collect information directly from your child.
When creating an account for a child, parents and legal guardians are asked to review and consent to our COPPA Notice, which provides parents and guardians with direct notice of our information practices before we collect any Personal Information about their child. Parents and guardians give their consent by checking the appropriate boxes on the account registration page. If a parent or legal guardian chooses not to consent to the collection and use of their child’s Personal Information, they may not create an online account for the child. At any time, a parent or legal guardian may revoke their consent. Once consent is revoked, a child may not use any Services online, unless a new consent is obtained.
The above sections of this Privacy Policy contain details about the information we collect, which extend to information we collect about children. The information we collect will be used and disclosed for the purposes described above. We will not require a child to disclose more information than is reasonably necessary to participate in an activity.
No Personal Information about a child will be made available to the public or sold. We may engage employees and third-party services providers to work with us to administer and provide the Services or to promote our Services. These employees and third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf, always in accordance with all applicable laws, including HIPAA, and are expressly obligated not to disclose or use your Personal Information for any other purpose. You have the right to agree for us to collect and use your child’s Personal Information but still not allow disclosure to third parties unless such disclosure is part of our Services.
In addition to your right to revoke your consent for the collection of your child’s Personal Information, you may request to review the Personal Information we have collected from your child or ask to delete the information we have collected from your child unless we are required by law to maintain that information. Please submit your request or any questions to us at privacy@gettingsupporttogether.com.
California Residents
If you are a resident of California the following information and rights are provided to you as required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA), and all implementing regulations, as may be further amended from time to time (collectively, the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice. Personal information under CCPA does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
- Financial Information covered by the Gramm-Leach-Bliley Act, and implementing regulations.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
- Identifiers: Name, residential address, Internet Protocol (IP) address, email address, or other similar identifiers
- Customer records information: Name, address, telephone number, medical information, health insurance information
- Characteristics of protected classifications under California or federal law: Race, gender identity, age
- Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
- Geolocation data: physical location or movement
- Professional or employment-related information
- Education information
We may also collect the following Sensitive Personal Information:
- Social security, driver’s license, state identification card, or passport number
- Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
- Precise geolocation
- Racial or ethnic origin, religious or philosophical beliefs, or union membership
- Health information
- Information concerning a consumer’s sex life or sexual orientation
This information is collected as noted in the Sections above entitled How We May Collect Personal Information and How We May Collection Other Information. The business purposes for which we collect and disclose this information are:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business
- Helping to ensure security and integrity
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business
- Providing advertising and marketing services, except for cross-context behavioral advertising, to consumers
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance the services
In the past 12 months, we have disclosed your Personal Information for a business purpose to the following categories of third parties:
- Service Providers: Cloud hosting, email delivery, medical record management, telehealth video platform, service desk management, platform usage analytics, business analytics, SMS delivery, log aggregation, geolocation
In addition to the above, we may disclose any or all categories of Personal Information to any third-party (including government entities and/or law enforcement entities) as necessary to
- comply with federal, state, or local laws, cooperate with law enforcement agencies, or to comply with a court order or subpoena to provide information
- cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law
- comply with certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury
- exercise or defend legal claims
“Sale” or “Sharing” of Personal Information
The categories of sources that we collect Personal Information and Sensitive Personal Information and our business and commercial purposes for using this information are set forth above. We do not "sell" or "share" your Personal Information. You may remove or adjust your cookie preferences on your device or browser as they permit, and you may contact us exercise your rights at any time (see “Contacting Us” below).
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information, including:
- Access – The right to request access to certain information about our collection and use of your Personal Information over the past 12 months;
- Data Portability – The right to request a copy of the specific Personal Information that we have collected about you or to transmit such Personal Information to another entity;
- Deletion – The right to request deletion of Personal Information that we have collected and retained (subject to certain exceptions);
- Correct – The right to correct Personal Information that we have collected to ensure that it is complete, accurate, and as current as possible;
- Opt-out – The right to opt-out of selling and sharing the information we collect (see above).
You may submit a verifiable consumer request to us to exercise any of these rights by contacting us as indicated below. We will process such requests in accordance with applicable laws.
Response Timing and Format
We will respond to a verifiable consumer request within 10 days of its receipt. We will generally process these requests within 45 days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Verification
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. For privacy protection, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through
- Granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Updates to This Privacy Policy
We may change this Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.
Contacting Us
If you have any questions about this Privacy Policy, please contact us at privacy@gettingsupporttogether.com or by calling 1-___-___-____. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.