Vertroos Health is devoted to safeguarding our customers and employee private information and ensuring the highest level of confidentiality of records. This Privacy Policy describes the information we collect, how we use it, and the standards and procedures in place to safeguard your personal nonpublic information. Vertroos Health, its personnel, and its affiliates strictly adhere to this Privacy Policy and the security practices and procedures described herein to ensure the confidentiality of customer information. It is Vertroos Health’s policy to comply with all federal and state laws and regulations relating to the privacy of our customers’ private information (PI) and private health information (PHI).

We receive a number of different types of information about you, including:

The information that's required when you sign up for the site, as well as the information you choose to share.

Except as permitted by law or as otherwise described below, Vertroos Health does not disclose any PI/PHI about its customers, or former customers, or employees, to anyone. Vertroos Health does not sell lists or customer information.

Information Vertroos Health Collects for Customers

Vertroos Health collects, retains, and uses PI/PHI from customers to include the following:

  • Required information such as your name, email address, birthday, and gender. We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties unless requested by you for services (e.g., communicating with counselors)
  • Usernames and User IDs, which are a way to identify you on Vertroos Health. A User ID is a string of numbers and a username generally is some variation of your name
  • "Public Information" which means the information you choose to make public, as well as information that is always publicly available
  • Information posted to a group chat or moderated session and information kept within a one on one session
  • “Contact Information” is personal information and or family/friend/relation that Vertroos Health stores confidentially in case of an emergency or mental health crisis (e.g., for your Therapist to access);
  • Banking information for billing purposes; such as account # and routing information for invoicing purposes

Information Vertroos Health Collects for Employees and Sub-Contractors

Federal law requires us to obtain, verify, and record personal information - such as your name, address and date of birth - in order to confirm your identity, social security number and banking information.

Vertroos Health collects, retains, and uses PI from employees and subcontractors including the following:

  • Information Vertroos Health receives on applications or other forms, including, but not limited to, identifying information such as address, telephone number, e-mail address, social security number, date of birth, mother's maiden name, medical history
  • Federal Tax ID #
  • Medical records
  • Investment information
  • “Contact Information” is personal information and or family/friend/relation that Vertroos Health stores confidentially in case of an emergency or mental health crisis (e.g., for your Therapist to access);
  • Background security checks

Information Vertroos Health May Share

We keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies or during an emergency circumstance as judged by your Therapist working with local authorities). Generally, we only use your information within our company. However, sometimes we use third parties to process your information (for example as credit card payment providers) and/or provide requested services (e.g., counseling/therapy). We require these third parties to comply strictly with its instructions and we require that they not use your personal information for their own business purposes.

The Site and Services are designed to be tools for parents and others to use to facilitate safe online interactions for children under their custody or control. Only those over the age of 18 may subscribe to our Services. This Site is not designed nor intended to be attractive to children under the age of 13. While our Services include analysis of online interactions by children, we do not knowingly collect data from children under the age of 13 without first receiving verified consent. If you are under 13 please do not submit any information to us.

We treat your Data with strict confidentiality in accordance with applicable law. However, we may reveal your Data or other information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas (provided that we will notify you of any such communication of your Data to the extent legally permissible), to enforce our Terms of Service or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others; (3) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Data may be one of the transferred assets); (4) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing customer service, processing orders, provided requested counseling and/or support services, etc.); or (5) as otherwise described in this Privacy Policy. Your Data will never be publicly displayed in any way by Vertroos Health or any person or entity acting on Vertroos Health’s behalf.

The Uses of the Collected Data by Vertroos Health

Vertroos Health uses non-identifying and aggregate information to better design our Web site and to use in research and trend analysis. We only provide data to our partners, if any, after we have removed your name and any other personally identifying information from it, or have combined it with other people's data in a way that it no longer personally identifies you.

Vertroos Health uses non-identifying (De-Identified or “Safe Harbor” form) and aggregate information about responses to the clinical outcome assessments (personal assessments), and the frequency of the utilization of the Vertroos Health service.

The anonymous and aggregated data also may be published through various media platforms/academic journals. No personal identifying information is tied to the results, and Vertroos Health does not share anything that could be used to identify your account or your private information.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will contact you before we use your data for these new purposes to notify you of the policy change and to provide you with the ability to opt out of these new uses.

Vertroos Health stores data only for as long as it is necessary to provide products and services to you and others, including those described above and for legal protections or as required by applicable laws and regulations.

Vertroos Health may enable access to public information that has been shared through our services.

Vertroos Health may allow service providers to access information so they can help us provide services. For example, your information may be shared with vendors providing counseling and therapeutic services requested by you. IP addresses are used to identify the location of users, the number of visits from different countries and also to block disruptive use; and to analyze and improve the services offered on our website, e.g. to provide you with the most user-friendly navigation experience.

Certain information is needed to provide you with services, so we only delete this information after you delete your account. Some forms of processing (sending promotional information, commercial profiling, behavioral advertising, geo-location, etc.) may require the express consent of the User. Specific information may be shown on the pages of the Site in connection with particular services or processing of Data provided by the Site User.

Upon request we provide site visitors with access to a description of information that we maintain about them. Vertroos.com uses industry-standard encryption technologies when transferring and receiving consumer data exchanged with our site. If you feel that this site is not following its stated information policy, you may contact us at addresses or phone number below.

For content that is covered by intellectual property rights, like photos and videos you specifically grant Vertroos Health a non-exclusive, transferable, sub-licensable, royalty- free, worldwide license to use any IP content that you post on or in connection with Vertroos.com (IP License). This IP License ends when you delete your IP content or your account unless your content has been shared with others, and they have not deleted it. This Paragraph does NOT apply to photos, images or other videos shared ONLY with your Therapist (vendors providing counseling services).

When you delete IP content, it is deleted in a manner similar to emptying the recycle bin on a computer. However, you understand that removed content may persist in backup copies for a reasonable period of time (but will not be available to others).

Disclosure of Personal Information

We do not share nonpublic personal information about our customers (present, former and potential) with anyone, except as required by law, or as follows:

  • To any person when you authorize such disclosure (e.g., to receive counseling and/or therapeutic services from our partners/vendors);
  • To computer services consultants and technicians or other security consultants, in order to ensure the confidentiality and security of customer & employee records
  • To financial service providers or consultants to carry out requested services, and/or to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability
  • To independent auditors or consultants in order to carry out institutional risk control
  • To government or regulatory agencies, including self-regulatory organizations and to comply with a legal summons, court order, subpoena or a similar legal process, audit or investigation
  • To swap data repositories.

Protection: How We Protect Personal Information

We restrict access to information about you to those employees who need to know that information as part of their job responsibilities. We also educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and our Code of Conduct. We take appropriate disciplinary measures to enforce employee privacy responsibilities. We have developed precautions that comply with federal regulations to ensure the security and confidentiality of customer records and information, to guard against any anticipated threats or hazards to the security or integrity of such records, and to protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to our customers or our employees.

Vertroos Health maintains strict information security procedures, including physical, electronic and procedural safeguards, to protect the confidentiality of your information. We conduct semi-annual Risk Privacy Assessments and remediate to update our technology to improve the protection of information storage.

We protect nonpublic personal information by

  • Restricting access to customer information to only those personnel for whom the information is necessary
  • Entering into written confidentiality/non-disclosure agreements with third party service providers for certain disclosures
  • Maintaining physical, electronic, and procedural safeguards that comply with the relevant laws and regulations; and
  • Conducting a Security Training and Awareness training program to communicate and educate employees about information security policies and procedures in order to make them aware of their roles and responsibilities in safeguarding information resources.

Vertroos Health uses firewall barriers and digital certifications to maintain the security of your online session and information.

We may gather and analyze information regarding usage of our website, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using cookies. Vertroos Health uses cookies and similar technologies to track usage of the website and to address security issues. We may also use cookies to store your preferences relating to use of our website. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet, phablet, cell phone or other electronic device (referred to here as a "device") browser from a website's computer and is stored on your device's hard drive. Each website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track traffic flows.

Cookies record information about your preferences and allow us to tailor Vertroos Health to your interests. During the course or any visit to the Site, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things such as finding out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking for the cookie left there on the previous visit. Information supplied by cookies can help us to analyze the profile of our visitors so we can provide you with a better user experience.

Protecting the Privacy of your fellow Vertroos Health Users

During the use of Vertroos Health services, you will not send or otherwise post unauthorized commercial communications (such as spam) on Vertroos.com or any site part of Vertroos Health, Inc.

You will not collect users' content or information, or otherwise access Vertroos.com, using automated means (such as harvesting bots, robots, spiders, or scrapers) without our permission.

You will not upload viruses or other malicious code.

You will not solicit login information or access an account belonging to someone else.

You will not bully, intimidate, or harass any other User.

You will not post content that: is hateful, threatening, or pornographic; incites violence; or contains nudity or graphic or gratuitous violence.

You will not provide any false personal information on Vertroos.com, or create an account for anyone other than yourself without permission. You will not create more than one personal profile.

Privacy Enforcement

Personnel using Vertroos Health’s information resources in opposition to this policy may be subject to limitations on the use of these resources, suspension of privileges (including internet access), as well as disciplinary and/or legal action, including termination of employment. Employees, contractors, consultants, interns, and all personnel affiliated via third parties sign the Privacy Policy agreement to comply and be governed by this policy and the Vertroos Health Information Security Policies upon hire and again annually.

Copyrights: Vertroos Health and Protecting Other People's Intellectual Property Rights

We respect other people's rights, and expect you to do the same. You will not post content or take any action on Vertroos.com that infringes or violates someone else's rights or otherwise violates the law. We can remove any content or information you post on Vertroos.com if we believe that it violates this Privacy Policy or the Terms of Use on this Site. You will not use our copyrights or any confusingly similar marks, without our written permission. If you collect information from Vertroos Health Users, you will: obtain their consent, make it clear you (and not Vertroos.com) are the one collecting their information, and post a privacy policy explaining what information you collect and how you will use it. You will not post anyone's identification documents or sensitive financial information on Vertroos.com. You will not tag Vertroos Health fellow Users or send email invitations to non-users without their consent.

Portable Electronic Devices

The Vertroos Health Platform is available on a multitude of portable electronic devices. We provide our connection to mobile services for free, but please be aware that your carrier's normal rates and fees, such as text messaging fees, may still apply. You provide all rights necessary to enable Vertroos Health Users to sync (including through an application) their contact lists with any basic information and contact information that is visible to them on Vertroos.com, as well as your name and profile picture.

Privacy in International Use and The GDPR

The Vertroos Health Platform advises both its Client/Users and practicing Platform Providers to be aware of and respect and comply with the local laws of any international based Client. Vertroos Health is cognizant and respects the formal promulgation of the existing European Union (EU) data privacy regulations. The General Data Protection Regulation 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It also addresses the export of personal data outside the EU and EEA and is commonly referred to as “GDPR.” Vertroos Health has always respected our Client’s Privacy (see our Privacy Policy) and we follow HIPAA stringent data privacy rules.

The basic tenants of the promulgated GDPR regulations include, but are not limited to the following:

Disclosure when you sell, transfer or third party marketing of User’s data: As outlined in this Terms of Use, Vertroos Health does not sell or transfer Client data and any marketing efforts are focused solely on internal information updates to our registered Clients.

Access to collected data: At Vertroos Health, you already have the ability to access your shared data (Your personal information, your emergency contact information and all your interactions with your Providers) and use it as you wish.

Clear Consent: At Vertroos Health our Terms of Use are clear on what consent we seek with regards to your data and prior to your engagement with your Provider, you review and agree to a further “informed consent” process.

Security: At Vertroos Health we have encrypted our data from day one and has always been stored all Private Health Information with full HIPAA compliance and in an anonymized form as required by the GDPR.

Notice/Audit: At Vertroos Health, we will provide our Clients notice of any data breach and we employ a full time security Officer, as well as engaging a third party security firm to periodically audit both or code and technology security as well as our HIPAA policies and procedures around data security.

Finally, dependent of your EU country or origin, the GDPR takes into account what was previously termed the right “to forget” or request deletion of your data once you cease using a particular application or site. This particular tenant of the GDPR may conflict with applicable medical records retention laws. In the United States, this requires at least seven years of retention, which is common around the world and is sometime up to ten years or more in certain countries. So, unlike some data platforms, Vertroos Health cannot erase private health data directly upon a Client’s request, as it may be considered essential for other medical file retention purposes. Applicable individual country medical retention laws are generally considered an acceptable exception to the GDPR regulations regarding the right to deletion of certain data.

Privacy Disputes

You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Statement or Vertroos.com exclusively in a state or federal court located in North Carolina. The laws of the State of Delaware will govern this Statement, as well as any claim that might arise between you and us, without regard to conflict of law provisions.

If anyone brings a claim against us related to your actions, content or information on Vertroos.com, you will indemnify and hold us harmless from and against all damages, losses, and expenses of any kind (including reasonable legal fees and costs) related to such claim.

Social Networks and Vertroos Health

These services allow the web site to access the data on your profile in the social networks, and to interact through your post. These services are not activated automatically, but require express authorization by the User.

Vertroos Health Users can share information and Data supplied to this Site with the social networks with which the User is registered, accepting their privacy policy. Facebook social buttons/widgets (Facebook) Facebook Social button is a service run by Facebook Inc., a company that complies with the “Safe Harbor” Privacy Policy Framework initiative, guaranteeing the handling of Personal Data.

Twitter is managed by Twitter, a company that complies with the “Safe Harbor” Privacy Policy Framework initiative, guaranteeing the handling of Personal Information.

Final Words from Vertroos Health

We try to keep Vertroos.com safe, but you use it at your own risk. We are providing Vertroos.com “As Is” without any express or implied warranties. We do not guarantee that Vertroos.com will be safe or secure. Vertroos.com is not responsible for the actions, content, information, or data of third parties, and you release us, our directors, officers, employees, and agents from any claims and damages, known and unknown, arising out of or in any way connected with any claim you have against any such third parties.

We strive to create a global community with consistent standards for everyone, but we also strive to respect local laws. You consent to having your personal data transferred to and processed in the United States. If you are located in a country embargoed by the United States, or are on the U.S. Treasury Department's list of Specially Designated Nationals you will not engage in commercial activities on Vertroos.com (such as advertising or payments). By content we mean anything you post on Vertroos.com that would not be included in the definition of information. By data we mean content and information that third parties can retrieve from Vertroos.com or provide to Vertroos.com through Platform. By post we mean post on Vertroos.com or otherwise make available to us (such as by using an application). By use we mean use, copy, publicly perform or display, distribute, modify, translate, and/or create derivative works.

Vertroos.com openly volunteers its practices of collecting information, its targeting capabilities, and its use of cookies. If you have any questions pertaining to this privacy policy and its contents, please direct your correspondence to Vertroos.com at the "contact us" link on the website.

Understand, that we treat your use of our platform with the utmost respect to your privacy. Vertroos Health is not responsible for data lost/exposed/used due to the nature of the Internet and digital environments, including illegal actions of hackers and criminals, technical malfunctions of servers and database etc. These are the accepted risks of our Users and users of the Internet in general. You are agreeing to this standard in using our site.

Vertroos Health reserves the right to amend this Privacy Statement at any time without notice, and only the current Privacy Statement may be deemed effective. Regardless of later updates or changes to our privacy notice, we will never use the information you submit under our current privacy notice in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.

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