Privacy Policy

  • Purpose

This Privacy Policy applies to information collected by 2gether Forward and its parents, subsidiaries, and affiliates (collectively, “2gether Forward,” “We,” “Our” or “Us”), in connection with the mental health counseling communications platform (“Platform”) that We offer. This Privacy Policy includes information that is or may be collected online through Our website www.2getherforward.com (the “Site”), mobile application(s), if any, SMS Text or other chat messaging, and any other online, or other communications. Information includes information that is linked to You and/or to Your household, such as name, email address, phone numbers, device IDs, which may be directly or indirectly collected by Our communications Platform.

 

By engaging in the clickwrap agreement and subsequently accessing and using the Site, Your confirm Your acceptance of this Privacy Policy. Do not access or use the Platform if You do not agree to the provisions of this Privacy Policy or Our Terms and Conditions

 

This Policy explains how information may be collected, used, or disclosed through Our Platform and explains Your rights related to it. This Policy is incorporated into the Terms and Conditions of Our Platform. By using and accessing Our Platform, You are accepting Our Privacy Policy and Terms and Conditions of use. Additional terms may apply depending on the user portal through which You elect to proceed. We do not use Your information for direct marketing purposes. Yet, under the applicable privacy laws of the states of which You are a resident, You are or may be, entitled to request a copy of all personally identifiable information (“PII”) disclosed for direct marketing purposes, have it deleted, and opt-out of such information being sold to third parties. Send such requests to [email protected].

 

The purpose of this Policy is to explain the technical aspects of data processing and storage in a simple and clear way. Please feel free to email [email protected] if You have any questions about this Policy, or any suggestions for Us to improve it.

  • Application to Therapists and Users Only

This Policy applies to any visitors to the public portions of Our Site and mobile applications, if any, users of the paid portions of Our Platform, and independent contractor therapists who are using the Platform to perform therapy services.

This Policy does not apply to the collection and use of information for employees or independent contractors (not including therapists) of 2gether Forward, its parent company, or its affiliates or subsidiaries. If You’re a current or former 2gether Forward job applicant, employee, owner, director, officer, or independent contractor other than therapist, please contact Us at [email protected] for the appropriate notice governing those portions of the Platform.

  • Service Provider and Third Parties

We define a service provider as a person or company that We may have a legal agreement with to store and process data collected by Us or on Our behalf (“Service Provider”). For the purposes of this Policy, a third party means an entity that is not a therapist or any other parties that are specifically called out in this Policy (“Third Party” or “Third Parties”).

We may share Your information with the following Service Providers and Third Parties to perform services on Our behalf such as:

  • Data warehouses, servers, and storage providers
  • Data analytic, data connectivity and customer data providers and platforms
  • Customer engagement or relationship management platforms
  • Advertising networks, advertising software tools, advertising servers, advertisers, sponsors and partners that market and advertise to You and measure performance of marketing and advertisements
  • Cloud computing providers
  • Survey and customer feedback providers and platforms
  • Printers
  • Mailing houses and delivery services
  • Data providers
  • Software development tools
  • Referral program platforms
  • Entities in the healthcare ecosystem
  • Data providers, email delivery, and analytics software
  • Text delivery and analytics platform
  • Customer service software
  • Patient advocacy support providers to handle Your requests
  • Privacy management platform, such as to manage deletion requests
  • Prepaid card and gift card vendor
  • Information security, fraud detection and prevention providers
  • Identity and professional credential verification providers
  • Auditors, third parties conducting security assessments and services, law firms, staff augmentation firms and other professional services providers
  • Government agencies and services in compliance with any applicable law, regulation, subpoena, or legal process

  • Information We collect about You.

The information We collect about You may include personal identifiable information (“PII”), protected health information (“PHI”) or electronic protected health information (“ePHI”). To the extent We collect PII, PHI or ePHI, We will seek the required waiver(s) and/or authorization(s) as set forth in applicable laws, including the Health Insurance Portability and Accountability Act’s Privacy Law (“HIPAA”) if applicable, and state or other federal regulations. You understand, acknowledge, and agree to use Your best efforts to avoid revealing PII, PHI, and ePHI when using any chat feature that may be available for communication with Your Therapist agree to indemnify the Company against loss or damages that may arise in connection thereto. Therapist understands, acknowledges, and agrees to use his/her/their best efforts to avoid revealing their own and/or a user’s PII, PHI, and ePHI when using any chat feature that may be available for communication with the user and agrees to indemnify the Company against loss or damages that may arise in connection thereto.

This information may include the following categories:

  • Personal Identifier: Your name, date of birth, postal and email address, phone number, driver’s license or other government identification number, username, and password.
  • Account Data: Along with standard PII, the Site, upon registration may store the account name the user selects, the email registered to the account, and whether said account is verified.
  • Commercial Information: Your purchase and usage history, goods and service preferences, insurance information, demographic information, interest information, payment and account information, and communications with Us.
  • Therapist Personal and Commercial Data: We may store and process therapist information such as the therapist’s name, bank account information, gender, date of birth, governmental identification numbers (SSN/FEIN), e-mail address, phone number, address, NPI number (if applicable), license information, CAQH number (if applicable), and areas of interest/expertise, education, and job history.
  • Therapist Activity Data: We may store and process data about therapist logins to the Platform, the number of user sessions conducted by a therapist, number of messages exchanged by a therapist, and number of notes shared by a therapist. Additionally, We may store and process communications via the Site and related information users share with their therapist to facilitate live sessions.
  • Session Quality Data: We may store and process user feedback about their therapist, including all ratings and reviews of their therapist, actions regarding switching therapist or quitting therapy, and the reason selected by the client. Additionally, We store and process therapist session availability, session cancellations and no-shows.
  • Internet/Electronic Activity, Device Information, Usage Information: Your geolocation information, Internet Protocol (IP) address information that may identify Your computer, mobile device, tablet or other device or browser, information about Your operating system and browser, including the hardware model and mobile network information web/app browsing and search history related to Our Platform, and information regarding Your interaction(s) with the Platform or 2gether Forward advertising may be collected by Us or other companies We work with. Our URLs, pages, screens, and content may include drug names and information and condition names and information. In addition to other uses described herein, We and other companies may use this information to, among other things, provide the Platform, help diagnose problems with Our servers, analyze trends, track users’ web page, email, and mobile application movements/activities, help identify or gather demographic information, and target and retarget online and mobile advertisements to You across computers or devices You may use.
  • Profile Inferences: Inferences that We may draw from the above categories of information and web activity to create a personalized profile so We can better identify goods and services that may be of interest to You.
  • Customer Service Data: We may store, process, and monitor all communications between users and Our customer service team.
  • Professional Information: For healthcare providers, if applicable, Your National Provider Number (“NPI”), medical specialty or other professional credential information.

  • Why data is stored and processed.

There are many reasons We may store and process Your data, either intentionally, or automatically (or passively) by virtue of Our internal software and technical infrastructure, or with third parties with which We may contract, which include, but are not limited to, the following:

  • To connect and match You with a licensed therapist.
  • To verify Your identity and secure Your account.
  • To improve the quality of Our services.
  • To improve the Site.
  • To personalize the Site and experience to Your preferences.
  • To comply with relevant laws and regulations.
  • To protect Your safety and the safety of other users.
  • To monitor and protect the security of the Site.
  • To gather information on how to improve the Site and Our services in general.

There are many reasons We may store and process therapist data specifically, either intentionally, or automatically (or passively) by virtue of Our internal software and technical infrastructure, which include, but are not limited to, the following:

  • Recruiting therapists and assisting in the hiring and onboarding process.
  • Match clients to You based on each other’s preferences.
  • Verify Your identity and secure Your account.
  • Run background checks and other screening required for credentialing and re-credentialing purposes.
  • To pay Therapists and comply with all applicable tax laws.
  • Provide feedback.
  • Send communications regarding the status and security of Your account.

  •  Who can see the interactions You have with Your Therapist

You and Your therapist are able to see the messages You send to one another. If You consent, a licensed therapist who may be employed as part of the 2gether Forward’s Operations Team may review correspondence with Your therapist for quality assurance purposes.

In addition, Our legal and/or operations teams may review correspondence for specific accounts if We have a reason to believe that there is a security, legal, fraud or abuse issue occurring on that specific account. Finally, Service Providers and their officers and agents, and other third parties with which we may contract to operate the Platform may access or see communications between You and Your Therapist. Messages with Your therapist are not shared with any Third-Party, and Your live sessions are not recorded. We also do not share when You send a message, or have a session with Your therapist, with any Third-Party.

  •  How We may use and share Your data

Here’s some more information about the purposes for which We may share Your data:

  • Your data may be shared to comply with applicable laws. We defer to Your chosen therapist to decide to produce (or not produce) any psychotherapy notes or messages You have had with them. Many jurisdictions have strict rules governing therapist/client relationships and the confidentiality requirements associated with that. We encourage You to discuss with Your therapist early on if You have concerns about their disclosure obligations.
  • Your data may occasionally be handled by a select group of support services employees. These employees are under strict duties of confidentiality.
  • We may share certain data with Service Providers that provide limited services that help Us operate the Platform.
  • We may sell some of Your data to third party data brokers and/or marketing entities in accordance with this Privacy Policy and applicable federal and state laws.
  • We may share some of Your data with Service Providers to ensure the safety and security of the Platform and that of Our users.
  • We may share or transfer Your information if We are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control. If another entity acquires Us or any of Our assets, information We have collected about You may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against Us, such information may be considered an asset of Ours and may be sold or transferred to third parties. Should such a sale or transfer occur, We will use reasonable efforts to try to require that the transferee use information provided through the Services in a manner that is consistent with this Privacy Policy.
  • The location You share while these tools are running may be read, accessed, and collected by a Third-Party Site in accordance with their Privacy Policy.
  • We may use Your information to advertise and market to You on websites, mobile applications, and third-party platforms, as well as via text messages, emails, direct mail, and other forms of advertising. This may include retargeting You on third-party platforms. We may use and share Your information to send advertising and marketing of Our Platform and other services We believe You may find interesting and may share information with advertisers and other third parties. We may also use and share Your information to measure the effectiveness of advertising and marketing, to predict effectiveness of advertising and marketing, to find audience for advertising and marketing and other analytics and operations, and to achieve other business, and profitmaking objectives related to advertising and marketing. We do not share private communications You have with Your therapist on the Platform.

Note that if You make any information publicly available on the Platform, such as with a public post, anyone may see and use such information.

  • Location Data

We may use Your address and location when and if You provide it as part of Your emergency contact information when You start therapy on the Platform. Your contact information is required to comply with therapy regulations and ethical code. It can be used, for example, in the event Your therapist believes You are in immediate danger. Additionally, Your domicile is needed when connecting with a therapist. The therapist matched should be licensed to practice in Your state.

We may use ReCaptcha or other similar mechanism to identify potentially malicious actors trying to access Our Site. The ReCaptcha or other similar mechanism’s privacy policy is incorporated herein by reference.

  • Cookies and Do Not Track

A cookie is a piece of data from a website that is stored within a web browser that the website can retrieve at a later time. Cookies are used to tell the server that users have returned to a particular website.

We may use Our own and/or Third-Party cookies and web beacons to deliver a faster and safer experience, to monitor and analyze usage, to comply with laws, and for advertising purposes.

We, or other parties We do business with, may place or recognize unique cookies or other similar technologies on Your browser when You use Our Platform and visit Our Site to collect information about Your use of the Platform and Your other online activities over time and across different websites and apps, and may use that information to serve interest-based advertisements to You as You browse the Internet. You may adjust Your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, the performance of Your device or browser may prevent You from being automatically recognized upon revisiting and You may not be able to use certain features of the Platform or take full advantage of all of Our offerings. Please refer to Your device’s settings or Your Internet browser’s “Help” section for more information on how to delete and/or disable Your device or browser from receiving cookies or controlling Your tracking preferences.

  • Data Security

2gether Forward takes information security seriously. We use commercially reasonable efforts to prevent unauthorized third-party access to Your information. However, We cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose Your information. Please note that We cannot and do not ensure or warrant the security of any information You transmit to Us over the internet or other electronic means (such as text messages). Our systems infrastructure, encryption technology, operation and processes are all designed, built, and maintained with Your security and privacy in mind. You use the Platform and provide Us with Your information at Your own risk, and We accept no liability for unintentional disclosure.

  • Requesting and Deleting Data

To receive a summary copy of Your data, including without limitation, Your contact information You provided, answers to any questionnaires, emergency contact information, and messages between You and Your Therapist, or to request that Your information be deleted, please contact [email protected]. Please note that prior to fulfilling Your request, We will need to verify Your identity, which may require additional pieces of information. This information is strictly used for verification purposes. There is usually no charge. In exceptional circumstances, We may charge a reasonable fee after discussing the fee with You.

Please note that if You’ve started therapy, We may retain some of Your data for an extended period based on applicable data retention laws.

Requirements:

  • Only You or Your authorized representative may make a request on Your behalf. You may also make a request on behalf of Your minor child depending on the applicable laws.
  • We reserve the right to deny information requests that are unduly burdensome as allowed by law.
  • You must provide sufficient information that allows Us to reasonably verify Your identity or status as an authorized representative.
  • You must provide details that allow Us to understand, evaluate, and respond to Your request.

If You have any questions about Your rights, want to exercise them, or want to appeal Our response to Your request, please contact Us by email at [email protected].

We will not discriminate against You for exercising any of Your privacy rights. We will not deny You services, charge You different prices or rates, impose penalties, or provide a different quality of service.

  • Data from Children

We don’t knowingly collect or solicit any data or information from anyone under the age of 18 or knowingly allow such persons to become Our users, without the appropriate parental or guardian consents and in accordance with applicable federal and state laws. The Platform is not directed at and not intended to be used by children under the age of 18. If You’re aware that We have collected personal information from a child under age 18 please let Us know by contacting Us, and We’ll delete that information.

The Platform is only for users of the age of 18 or older. If You are under the age of 18, please do not attempt to register with Us or provide any personal or other information about Yourself to Us at any time to access and use the Platform.

  • Compliance with Law

Where We are required by law, We cooperate with government agencies. This is not unique to 2gether Forward and is applicable to in-person therapy as well. For example, a court might subpoena information from Us where We would be required to share certain information requested in the subpoena. Keep in mind that, as a general rule, We defer to Your chosen therapist to decide to produce (or not produce) any psychotherapy notes or messages You have had with them. Many jurisdictions have strict rules governing therapist/client relationships and the confidentiality requirements associated with that. We encourage You to discuss with Your therapist early on if You have concerns about their disclosure obligations.

You should also be aware that therapists may be obliged to disclose information to authorities to meet professional and legal responsibilities. Specifically, some laws require mental health professionals to disclose information and/or take action for: (a) reported or suspected abuse; (b) serious suicidal potential; (c) threatened harm; and (d) court-ordered treatment. You should speak with Your therapist if You have concerns about this.

  • Policy Updates

We may modify this Privacy Policy at any time. When We do so, We will post the revised Privacy Policy on the Site.

  •  Additional privacy notice for residents outside of New York

Under the applicable privacy laws of the States of California, Colorado, Connecticut, Utah, and Virginia, and any other applicable state laws of which You are a resident, You are or may be, depending on your state of residence, entitled to request a copy of all PII we may share, have it deleted, and opt-out of such information being sold to third parties. Send such requests by mail to PO Box 346, Lincolndale, New York 10540 or by email to [email protected].

  • European Union Visitors

Please do not use the Platform if You are not a resident of the United States. The Platform is intended for use only by residents of the United States. Use by visitors from the European Economic Area (“EEA”) is prohibited.

  • Who You can contact with questions or concerns 

Please address comments or questions to Us about this Policy to:

 

2gether Forward

PO BOX 346

Lincolndale, New York 10540

E-Mail: [email protected]

 

Last Updated and Effective: July 5, 2023