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THERAP SERVICES – GENERAL PRIVACY POLICY

Last updated: December 16, 2020

Therap Services, LLC and its affiliates (collectively, “Therap,” “we,” or “us”) is a web-based service organization that provides an integrated software solution, live help, in person training, and other services (collectively, the “Services”) to assist the documentation, reporting, and communication needs of agencies and companies providing support to people receiving long-term services and support.  As such, we understand the importance of your privacy and we take our responsibility to protect it seriously. Our Privacy Policy (the “Policy”) describes the types of information we collect from you, how we share the information, and certain rights and options you have regarding your information. This Policy applies to information we collect from you through our website (www.therapservices.net), registration or attendance at one of our events or trainings, direct communications and inquiries, and otherwise.  Please note that Therap has a different privacy policy for the information that end users collect or process through the Services.

Please review this Policy carefully before sharing information with us so you understand our privacy practices.  If you are a California resident, then Supplement I (attached hereto), which is part of our Policy, applies to you and you should review that as well.  If you are both a California resident and either an employee of Therap or applying for a job with Therap, then Supplement II (attached hereto) which is part of our Policy, applies to you and you should review that as well. By using our website, communicating with us, agreeing to have your agency or company use the Services, attending one of our events or trainings, or registering to receive information from us, you agree to the terms of our Policy.

Personal Information We May Collect About You

Under our Policy, “personal information” is any information that identifies or can be used to contact a particular individual.  As we are a business-to-business company, the personal information that we typically collect directly from you is limited to the information that can be found on a business card—name, business name, position, address, email address, and telephone number.  We also collect information relating to your attendance at events/trainings, inquiries and communications received from you, and your agency or company’s agreement to use the Services.  The specific types of personal information we may process include:

• Identity information – first and last name, name of employer.

• Contact information – physical address of your employer, email address at your employer, country, and business telephone number.

• Employment information – name of your employer and your position at the employer.

• Training and event information – details about trainings you have registered for or taken, events you have attended, and certifications you have achieved.

• Financial data – bank account number, wire information, and payment card details relating to your business or employer’s payment for its use of the Services.

• Transactional data – details about your company or employer’s agreement to purchase the Services and related services, including modules purchased, payments received, customer service-related inquiries and issues, and other information relating to your company or employer’s use of the Services.

• Marketing and communications information – information regarding any requests for information received from you, your marketing or communication preferences, and your responses to surveys we may provide to receive feedback regarding our services. 

• Usage information – details regarding when and how you use our website and the Services.

Please note that we may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”

Other Information We Collect from You

Like most websites, we use the various technologies to automatically collect the following types of information about you:    

• IP Address or Device Identifier.  When you visit our website, we collect your Internet Protocol (“IP”) address, which identifies the computer or service provider that you use to access our website or, if you connect through a mobile device, your mobile device identifier.  We may use these identifiers to collect information about the length of time spent on our website or the specific areas visited.

• Cookies.  Cookies are small text files that can be used by websites to make a user’s experience more efficient.  Our website uses different types of cookies to, among other things, automatically recognize you when you return to our website, store information regarding your preferences, personalize content for you, provide social media functionality, and analyze our website traffic.   For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.  Likewise, to learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.  Please note that if cookies are disabled, you may not be able to enjoy certain features of our website.  We do not honor “Do Not Track” signals.

• Web beacons and other technologies.  Our website may use other tracking tools, including web beacons, which are small electronic images embedded in web content and email messages that are not ordinarily visible to users.  Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.  We use pixels to track visitors.  You can opt out of pixels by adjusting your browser’s cookie settings or adjusting cookie consent options on our website to not accept marketing cookies.

• Hotjar. We use Hotjar in order to better understand our users’ needs and to optimize their website experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our website with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

The information collected through these technologies may be combined with personal information or aggregated with other information on website visits.  

How We Use Your Information

We use the personal information we collect from you for the following purposes:

• To provide the services contracted for by your business or employer;

• To provide customer support services, and to verify, investigate, and respond to any claims, problems, or requests you may make relating to the Services;

• To provide you with trainings for which you have subscribed;

• To register you for and provide you admittance to Therap events at your request; 

• To provide you with information regarding Therap, the Services, and events and trainings, as well as other information that you may request from us;

• To administer user profiles for your business or employer in our Services;

• To enforce our terms of service or agreement with your company or employer;

• To prevent or detect hacking activities, security breaches, or safety risks in connection with our website and the Services;

• To send service announcements and messages;

• To aggregate information to generate anonymous statistics regarding use of our website or Services;

• To develop, update, and improve our Services and operations;

• To optimize your experience on our website and ensure that our content is presented to you in the most effective manner;

• To send you promotional or marketing communications and solicitations, track your marketing preferences, and for our internal marketing purposes;

• To create anonymous summaries of reports and other relevant data for the governmental agencies responsible for the care of “care recipients” (as defined in Therap’s End User Legal Agreement);

• To notify you about changes to our website, including material changes to this Policy; 

• To provide you with surveys or otherwise solicit feedback regarding the Services; and

• To perform other functions as otherwise described to you at the time of collection or that you otherwise consent to.

Please note that if you signed up to receive promotional emails from us, you may opt out of receiving such communications by following the “unsubscribe” link at the bottom of the email or by calling 1-866-THERAP-0.

Disclosure of Your Information

When the information we collect is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

In addition, we may share information that we collect or that you provide in the following circumstances:

• With service providers that we use to assist us with management and coordination of events and trainings that we host.

• With vendors that we use for our contract management and fulfillment processes.

• With our third-party marketing service providers that assist us with promotional materials, campaigns, and communications.

• With website analytics vendors in order to understand our website traffic and usage patterns, optimize our website, and identify potential new clients.

• With our customer relationship management vendors as necessary for customer service and support, sales, marketing, and lead generation.

• With our email service provider, who enables us to communicate with you and our other contacts.

• With our cloud-hosted server provider(s), who enables us to store, retain, and otherwise process necessary information.

• With vendors that provide support for the training services we offer.

• With other third parties that provide necessary services for our business, but only for the purpose of those services.  

• With our controlled affiliate for the purposes of product development related to our Services.

• With governmental or supervisory agencies responsible for the care of care recipients, as defined in Therap’s End User Legal Agreement.

• For any other purpose disclosed by us when you provide the information.

We reserve the right to disclose your information as necessary to comply with a subpoena or similar investigative demand, court order, request for cooperation from law enforcement or other governmental agency, to exercise our legal rights, to defend against legal claims, or as otherwise required by law.

We also reserve the right to disclose your information to a buyer or other successor prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.

Your Choices About Collection and Use of Your Information

We strive to provide you with choices regarding the personal information you provide to us.  As mentioned above, you can opt out of receiving marketing and promotional communications from us.  

You can also choose not to provide us with certain information requested through our website, but that may result in you being unable to use certain features of our website, to request information about products or services, or to initiate other transactions with us. 

Protection of Your Information

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification.  Please be aware that no data transmission over the Internet is 100% secure.  While we strive to protect your personal information, we cannot ensure or guaranty the security of any information you transmit to us and you do so at your own risk. You are responsible for maintaining the confidentiality of the username and password for your Therap website account portal. 

Links to Third-Party Websites

Our website may contain links to third-party websites.  Such websites have separate privacy policies that you should review.  We cannot take responsibility for the content of linked websites or those companies’ data-handling practices.

GDPR and EEA Residents’ Rights

The General Data Protection Regulation (“GDPR”) is a privacy law that affords certain rights relating to the personal information of individuals in the European Economic Area (“EEA”).  Therap is not established in the EEA, does not target goods or services to individuals in the EEA, and does not monitor the behavior of individuals located in the EEA.  Further, Therap does not currently process personal information about individuals in the EEA.  As a result, Therap is not subject to the GDPR or privacy laws of countries in the EEA.

Children’s Privacy

Our website is a general audience site and is not directed at, or intended for use by, children under the age of 16 years.  Accordingly, we do not knowingly collect personal information from children under age 16.  Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information. 

Data Storage and Retention

We keep your personal information for as long as necessary to fulfill your requests or the purposes for which it was obtained.  The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you, (ii) as required by a legal obligation to which we are subject, and (iii) as necessary to comply with legal obligations.

Changes to this Policy

Please note that we may change this Policy from time to time.  If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes.  Accordingly, we encourage you to check the Policy periodically for updates.

How to Contact Us

If you have any questions about this Policy or our information-handling practices, please contact:

Therap Services, LLC

Attn: Privacy Department

Address: 562 Watertown Avenue, Waterbury, CT 06708-2240

Phone: 1-866-THERAP-0

Email: privacypolicies@therapservices.net

SUPPLEMENT I TO PRIVACY POLICY FOR CALIFORNIA RESIDENTS

Last revised: December 16, 2020

Therap Services, LLC and its affiliates (collectively, “Therap,” “we,” or “us”) is a web-based service organization that provides an integrated software solution, live help, in person training, and other services (collectively, the “Services”) to assist the documentation, reporting, and communication needs of agencies and companies providing support to people receiving long-term services and support.  As such, we understand the importance of your privacy and we take our responsibility to protect your information seriously.  We have prepared this privacy notice (the “Notice”) pursuant to the California Consumer Privacy Act (the “CCPA”) to provide information regarding the categories of information we collect from California residents, how we use and share that information, and rights and obligations relating to that information.  

This Notice applies to the personal information we collect from California residents who use our website (www.therapservices.net), attend one of our events, communicate or request information from us, or purchase one of our products.  This Notice does not, however, apply to personal information that our customers may upload, provide, or collect through their use of the Service.  Our customers are solely responsible for determining the purposes and means of processing personal information through the Services and, as to such information, Therap is only a “service provider” under the CCPA. 

This Notice does not apply to employment-related personal information we collect from our California-based employees or job applicants.  (Any California-based employee or job applicant  should review Supplement II to our General Privacy Policy, which is attached). In addition, it does not apply to personal information we collect in connection with written or verbal business-to-business communications or transactions—which is the vast majority of personal information we collect—which is currently subject to a temporary exemption from some of the CCPA’s requirements.  

Please note that this is Supplement I to our General Privacy Policy.

Personal Information We Collect and How We Collect It

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident, household, or device.  It does not include information that is publicly available from government records or information that has been de-identified or aggregated and can no longer be associated with a particular individual, household, or device.

In the past 12 months, we have collected the following categories of personal information from California residents.

Direct collection: We collect this information directly from you when you choose to provide it to us by downloading information from our website, filling out forms on our website, requesting information with us, communicating with us (whether via email, website chat feature, or phone), attending one of our events, registering to receive emails or information from us, and signing up for an online training or certification.  

Indirect and technology-based collection:  We also collect certain information from you indirectly when you visit, use, and navigate across our website, your internet domain and IP address, the browser and operating system you use, the date and time you access our website, searches or entries you make on our website, the pages you visit, and whether you linked to our website from a different website (and that website’s web address).  We do so by using the following technologies:

• Cookies (or browser cookies).  A cookie is a small data file that our website transfers to your computer.  We deliver these cookies and collect data on our website, and we may also use a third-party agent to deliver cookies and collect data.  We use the data we collect using cookies to help support the integrity of the registration and buying processes on our website, retain your preferences and account settings, and improve our site and your experience.

• Flash Cookies.  We may also use flash cookies (local shared objects) to enhance your online experience.  Flash cookies are small files similar to browser cookies and are used to remember the site’s settings to personalize the look and feel of the site. 

• Web Beacons.  Web beacons are electronic images that may be used on our site or in our emails.  We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness, and to tell if an email has been opened or acted upon.

How We Use Your Personal Information

We use the personal information that we collect from you for the following business and commercial purposes:

• To present our websites and their contents to you and make any necessary improvements to our website. 

• To register you for an event or training and provide you access to training materials. 

• To respond to your comments and questions and provide information or training requested.

• To fulfill any other purpose for which you provide it, such as subscribing you to an e-mail newsletter or contacting you in response to your request for us to do so. 

• To send you communications and information about our services, offers, promotions, news, and upcoming events for Therap.

• To notify you about changes to our website. 

• To allow you to participate in interactive features on our website, if any.

• To comply with applicable laws, regulations, and legal process.

• In any other way we may describe when you provide the information or to which you consent.

• As otherwise necessary or useful for us to conduct our business, provided the use is permitted by law.  For example, analyzing audience and use patterns from the websites, storing information about your preferences and allowing us to direct or customize specific content to you, and recognizing you when you return to our website.

• For the protection of our operations or those of any of our affiliates, or to protect our rights, privacy, safety or property, or that of our affiliates, you, or other parties.

Disclosure and Sale of Personal Information

Therap only shares your personal information as set forth in this Notice or our General Privacy Policy.  We do so only for business purposes.  Therap does not “sell” your personal information, as defined by the CCPA, and has not done so during the past 12 months.  Third parties with whom we may share your information include:

• Service providers, but only as necessary for us to conduct business and provide the agreed-upon services to you or related services.

• Governmental agencies, as may be required by law.

• With our controlled affiliate for the purpose of product development related to our Services.

During the past 12 months, Therap has disclosed the following categories of personal information relating to California residents that have used its website, communicated with Therap, or requested information from Therap: 

Please note that we may also use, disclose, or transfer your information in connection with the sale, merger, dissolution, restructuring, divestiture, or acquisition of our company or its assets.  We may also disclose your personal information in response to a court order, subpoena, search warrant, law, or regulation.

Your Rights Under the CCPA

The CCPA provides California residents with the rights discussed below.  For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

1. Right to Request Access Information.  You have the right to request that we disclose certain information about our collection and use of your personal information during the past 12 months.  Specifically, you may request that we disclose:

• The categories of personal information we collected about you;

• The categories of sources for the personal information we collected about you;

• The business and commercial purposes for collecting your personal information;

• The categories of third parties with whom we shared your personal information;

• The specific pieces of personal information we collected about you; and

• If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.

1. Right to Data Portability.  You have the right to request that we provide copies of the specific pieces of personal information we collected about you.  If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically.  If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible.

1. Right to Request Deletion.  You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by calling us at 1-866-THERAP-0 or submitting a request via email at privacypolicies@therapservices.net.  Your request must allow us to reasonably verify that you are the individual regarding whom we collected the personal information and must describe the request with enough detail that we can understand and respond to it.  Specifically, to verify you and the legitimacy of your request, you must initially provide your name, address, and email address, as well as a detailed explanation of your request.  If you do not provide this information, we will not be able to respond to your request or provide you with the personal information requested.  We may, however, need to request additional information for verification purposes.  Please do not provide social security numbers, government identification numbers, payment card information, bank account information, or any similarly sensitive information as part of your request.    

You may only submit requests for access or data portability twice within any 12-month period.  As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

The CCPA requires us to respond to a verifiable consumer request within 45 days, but permits us to extend that period by an additional 45 days, provided we notify you of the reason for the extension in writing.  We will notify you that we have received your request within 10 days of its receipt.  In general, we will not charge a fee to respond to a verifiable request, unless it is excessive, repetitive, or unfounded.  

Our Commitment Not to Discriminate

If a California resident exercises the rights discussed above, consistent with the CCPA, we will not discriminate against that resident by denying goods or services, charging different prices or rates for goods or services, providing different levels or quality of goods or services, or suggesting that the resident will receive a different price, rate, or quality of goods or services.

Changes to this Notice

Please note that we may change this Notice from time to time.  We will post changes here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes.  Please check this Notice periodically for updates.

Our Contact Information

To contact us regarding this Notice, your rights under the CCPA, or to exercise those rights, please contact us using the information below.
Therap Services, LLC
Phone: 1-866-THERAP-0
Email: privacypolicies@therapservices.net

SUPPLEMENT II TO PRIVACY POLICY FOR CALIFORNIA RESIDENTS WHO ARE EMPLOYEES OR JOB APPLICANTS

Last updated: December 16, 2020

Therap Services, LLC and its affiliates (collectively, “Therap,” “we,” or “us”) understands the importance of privacy to our job applicants, employees, and contractors.  We take our responsibility to protect their information seriously.  Pursuant to the California Consumer Privacy Act of 2018, as amended, (the “CCPA”) this privacy notice (the “Notice”) provides information regarding the categories of information we collect from job applicants, employees, and contractors who reside in California and the purposes for our collection of those categories of information.  

Categories of Personal Information We Collect

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device.  It does not include publicly-available information from government records or information that has been de-identified or aggregated.

In the past 12 months, we have collected the following categories of personal information from California residents through our websites and from job applicants.

How We Use This Information

We use the personal information that we collect from job applicants, employees, and contractors for the following purposes:

• To consider job applicants for current and potential future employment opportunities.

• To evaluate job applicants’ employment applications and corroborate the information contained in the applications and any supporting documents.

• To schedule job applicants for interviews and communicate with them about their application and employment opportunities.

• For all employment-related purposes, including (but not limited to): (1) administration and coordination of benefits; (2) payroll and reimbursement; (3) performance reviews, promotions, disciplinary actions, and other Human Resource functions; (4) to administer and facilitate employees’ performance of their job duties; and (5) any other employment-related purpose. 

• To negotiate, perform, and review any contracts with, and services being provided by, service providers.

• To comply with applicable laws, regulations, and legal process.

• In any other way we may describe when you provide the information.

• To keep a record of our interactions and communications with job applicants, employees, and contractors.

• As otherwise necessary or useful for us in conducting our business, provided the use is permitted by law.  

• For the protection of our operations or those of any of our affiliates, or to protect our rights, privacy, safety or property, or that of our affiliates, employees, or other parties.

• For any other purposes with your consent.