PRIVACY POLICY
This Privacy Policy discloses the privacy practices for Thrive Telehealth LLC (“Thrive,” “us,” “our” or “we”), the https://thrivehrt.com/ website, any available application and various related services (together referred to as the “Site”). Thrive Telehealth LLC, the provider of the services, is committed to protecting your privacy online. Please read the information below to learn the following regarding your use of our Site and services. You acknowledge that this Privacy Policy is part of our Terms of Use, and by accessing or using our Site and services, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use our Site or services. You shall be referred to as “you” or “user.”
Scope of this Web and Mobile Privacy Policy
This Privacy Policy describes the types of Personal Information we collect from visitors of our public Site and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us.
This Privacy Policy does not apply to information collected from visitors who register and log-in (“Members”) to any password-protected and secure portions of our Site, including login pages and registration pages (“Secure Platforms”). Additionally, we may use a third party site for the creation of your account and logging in to the Secure Platforms. All such use shall be subject to those third party site’s terms of service and privacy policies. The Secure Platforms allow eligible members to use the Site. All information collected and stored by Thrive or added by our members into such Secure Platforms is considered Protected Health Information (“PHI”) and/or medical information and is governed by laws that apply to that information, for example the Health Insurance Portability and Accountability Act (HIPAA). How Thrive uses and discloses such PHI is in accordance with the Thrive Health Notice of Privacy Practices. To understand how we use and disclose PHI, you should review our Notice of Privacy Practices. The Notice of Privacy Practices (and not this Privacy Policy) also applies to Personal Information collected on our Websites if specific symptoms or health conditions is also collected, as such information may be considered PHI under HIPAA.
Residents of states with heightened privacy laws should read the information available in the Regional Privacy Statement below about the categories of Personal Information to be collected from them and the purposes for which the Personal Information will be used.
This Privacy Policy is not a contract and does not create any contractual rights or obligations.
IMPORTANT NOTICE REGARDING TEXT MESSAGING DATA
Thrive Telehealth LLC (“we,” “us,” or “our”) DOES NOT share customer opt-in information, including phone numbers and consent records, with any affiliates or third parties for marketing, promotional, or any other purposes unrelated to providing our direct services. All text messaging originator opt-in data is kept strictly confidential.
I. Types of Collected Information
We, or our advertising partners, may receive, collect and store information about you automatically through the use of cookies and other tracking technologies. Information we collect may be from information you enter on our Site or provide us in any other way. In addition, we may collect the internet protocol (IP) address used to connect your computer or other electronic device to the internet; login; e-mail address; password; computer and connection information, purchase history. If you retain us for our services, we will also be collecting PHI for the provision of those services. Use of PHI is governed by the Thrive Health Notice of Privacy Practices.
You acknowledge our minimum age requirements and certify you are at least eighteen (18) years of age. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page or the Site. We may also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information), protected health information (including medical files containing diagnoses), comments, feedback, recommendations, and personal profile.
We also collect the following information related to communications:
• Opt-in records and timestamps for all communication channels (SMS, email, etc.) • Records of inquiries and service requests
• Appointment details and preferences
• Service history and feedback
II. Methods of Collection
We may collect Personal Information using the following methods:
• Directly from you when you provide it to us (such as information you enter into web forms, inquiries, responses, activity on the Site, and during registration to use a Secure Platform).
• From third parties, such as analytics and email marketing service providers. • Automatically through tracking technologies such as cookies, web beacons (also known as pixels) and log files, including over time and across our own and third-party websites or other online services.
“Cookies” are small files that a website stores on a user’s computer or device. The Site may use cookies for various purposes, including to keep the information you enter on multiple pages together. Some of the cookies we may use are “session” cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. We also may use “persistent” cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies.
Our Site may use Google Analytics and/or Adobe’s analytics and on-site personalization services, which use cookies, web beacons, web pixels and/or similar technology to collect and store information about you. You can learn more about their privacy policies and opt-out options by visiting their respective websites.
III. Reason for Collection of Information
We collect such non-personal and Personal Information for the following purposes: • To provide and operate the Site and services;
• To provide you with ongoing customer assistance and technical support; • To be able to contact you with general or personalized service-related notices and promotional messages;
• To create aggregated statistical data and other aggregated and/or inferred non-personal information, which we or our business partners may use to provide and improve our respective Site and services;
• To comply with any applicable laws and regulations.
IV. How We Use Your Information
We may use your Personal Information for the following purposes:
• Operate, maintain, supervise, administer, and enhance the Site, including monitoring and analyzing the effectiveness of content on the Site.
• Provide you with a tailored and user-friendly experience as you navigate our Site. • Promote and market our Site to you.
• To complete the activity you specifically asked for, e.g., register on a Secure Platform, obtain more information or request an appointment.
• Conduct research on users’ demographics, interests, and behavior.
• Aggregate information for analytics and reporting.
• Respond to law enforcement requests and court orders and legal process. • Authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Site.
• Send you SMS text messages that you have consented to receive.
• Maintaining records of your communication preferences and consent.
• Any other purpose with your consent.
V. How We Share Your Information
We may share Personal Information with third parties including service providers in certain circumstances or for certain purposes, including:
• For business purposes. We may share your Personal Information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security. We also may share Personal Information with professional advisors, such as auditors, law firms, and accounting firms. We may disclose your name, email address, date of birth, phone number, and address if you provided it to us via a form on the website or during an incomplete or failed registration to Service Providers.
• With your direction or consent. We may share your Personal Information with third parties if you request or direct us to do so. This includes your use of social media widgets on our Site.
• With affiliates within our corporate group. We may share your Personal Information with any subsidiaries or affiliates within our corporate group.
• Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• In the context of a transaction. We may share your Personal Information in connection with an asset sale, merger, bankruptcy, or other business transaction.
• For other business reasons. We may share your Personal Information to enforce any applicable legal disclaimer or indemnification, and to ensure the safety and security of the Site and/or our users.
• For advertising. Using cookies and web beacons, we may disclose Personal Information regarding your activity on our Site to third-party advertising partners to optimize marketing.
• Influencer marketing. If you signed up with us through a link provided by one of our influencer marketers (“Influencer”), we may share your deidentified patient identification number, along with the amount of money you spend, with the Influencer for tracking or billing purposes only. We will not disclose any health or other information to the Influencer. By signing up with us via an Influencer link, you agree to allow such disclosure to the Influencer. In the event you withdrawal your consent, we may have to terminate our services with you, at our sole discretion, because of our agreement with the Influencer.
• SMS aggregators and providers solely for the purpose of delivering messages you have consented to receive. All service providers are contractually obligated to maintain confidentiality and security.
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services.
We also may disclose deidentified information. Note that if you make any Personal Information publicly available on the Site, anyone may see and use such information.
VI. SMS/Text Messaging & Compliance
Text Message Program Terms & Conditions
By opting into our SMS messaging services, you agree to receive text messages related to our services, including appointment reminders, lab result notifications, service updates, and promotional offers from Thrive Telehealth LLC.
Opt-In & Consent
• You will only receive messages if you have explicitly opted in
• We maintain timestamped records of all opt-in actions
• We comply with the Telephone Consumer Protection Act (TCPA) and all applicable laws
Opt-Out Instructions
• You can cancel SMS notifications at any time by replying “STOP”
• You will receive a final confirmation message, and no further messages will be sent unless you re-opt in
• All opt-out requests are processed immediately
Message Frequency & Content
• Message frequency varies based on your interactions with our business • Messages will be directly related to the services you have requested or consented to receive
• We do not send promotional content without specific consent
Help & Support
• Reply “HELP” for assistance or contact us at clinic@thrivehrt.com
• Customer support is available during regular business hours
Carrier Information
• Standard message and data rates may apply
• Carriers are not liable for delayed or undelivered messages
• Supported carriers include AT&T, Verizon, T-Mobile, and most regional carriers
SMS Data Protection Statement
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support
services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Text messaging originator opt-in data and consent will not be shared with any third parties, except for aggregators and providers of the Text Message services.
We implement strict data protection measures to safeguard your SMS opt-in information and consent records.
VII. How Long Do We Keep Your Information
We keep your information as long as we need it to provide our Site and services, comply with legal obligations or protect our or other’s interests. We decide how long we need information on a case-by-case basis. SMS opt-out requests are honored and retained for a minimum of 10 years in compliance with applicable state laws.
VIII. How Do We Safeguard Your Information
We rely on many mechanisms for data transfers, including but not limited to, contractual clauses and use of software with industry standard security. Your PHI will be stored using a HIPAA compliant software. Despite these measures, no method of transmission over the Internet or electronic storage is 100% secure. We strive to use commercially acceptable means to protect your personal information but cannot guarantee absolute security.
IX. Third Party Websites and Links
Our Site may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook, Instagram, LinkedIn or Twitter) may also be viewable by other users of the Site and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such a link does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Site. WE EXPRESSLY DISCLAIM ANY AND ALL LIABILITY FOR THE ACTIONS OF THIRD PARTIES, INCLUDING BUT WITHOUT LIMITATION, TO ACTIONS RELATING TO THE USE AND/OR DISCLOSURE OF PERSONAL INFORMATION BY THIRD PARTIES. ANY INFORMATION SUBMITTED BY YOU DIRECTLY TO THESE THIRD PARTIES IS SUBJECT TO THAT THIRD PARTY’S PRIVACY POLICY.
X. Communication with Site Users
We may contact you for notifications regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about us, or as otherwise necessary to contact you to enforce our Terms of Use or other policies, applicable laws, and any agreement we may have with you. For these purposes, we may contact you via email, telephone, text messages, and postal mail.
XI. Cookies and Information Used for Advertising
On our Site we may collect and disclose Personal Information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. We participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons (also known as pixels). The networks use this information to show you advertisements that may be tailored to your individual interests.
You may disable or delete browser cookies through your browser settings. Cookies generally are easy to disable or delete, but the method varies between browsers. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts or functionality of our Site may not work properly.
If you have additional questions about the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.
XII. Your Rights & Choices
You have the right to:
• Access, update, or delete your personal information
• Opt-out of marketing emails by clicking “unsubscribe” in our emails
• Opt-out of SMS messages by replying “STOP”
• Request information on how we process your data
• Withdraw consent at any time for future communications
• Lodge a complaint with a supervisory authority if you believe your rights have been violated
To exercise these rights, please contact us using the information in Section XIV.
XIII. Privacy Policy Updates
We reserve the right to modify this Privacy Policy at any time for any reason. It is your sole responsibility to check our policies so please review them frequently. Changes and clarifications
will take effect immediately upon their posting on the Site. Should we make material changes to this policy, we will notify you here that it has been updated so that you are aware of what information we collect and how it is used.
XIV. Contact Us
If you have questions about this Privacy Policy or how your information is handled, contact us at:
Thrive Telehealth LLC
Phone: 941-326-3665
Email: clinic@thrivehrt.com
Website: https://thrivehrt.com
By using our website and services, you consent to this Privacy Policy.
UNITED STATES REGIONAL PRIVACY STATEMENT
This Privacy Statement is for residents that reside in the States of California, Utah, Virginia, Texas, Connecticut, and Colorado (“consumers” or “you”). We adopt this Statement to comply with the various laws applicable to those states.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:
Category A. Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name or other similar identifiers. COLLECTED: YES
Category B. Personal Information categories: A name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. COLLECTED: YES
Category C. Protected classification characteristics under State or federal law: Age (40 years or older), race, color, ancestry, national origin, religion or creed, marital status, sex, sexual orientation, veteran or military status, genetic information. COLLECTED: YES
Category D. Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. COLLECTED: NO
Category E. Biometric information. COLLECTED: NO
Category F. Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. COLLECTED: YES
Category G. Geolocation data. COLLECTED: NO
Category H. Sensory data. COLLECTED: NO
Category I. Professional or employment-related information. COLLECTED: NO Category J. Non-public education information. COLLECTED: NO
Category K. Inferences drawn from other Personal Information. COLLECTED: NO
Personal Information does not include publicly available information from government records, de-identified or aggregated consumer information, or information excluded from the applicable law’s scope such as health or medical information covered by HIPAA.
We obtain the categories of Personal Information listed above from the following categories of sources: directly from you or our service providers; third party partners such as analytics and marketing partners; directly and indirectly from activity within our Site, such as tracking technologies.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes: to fulfill or meet the reason for which the information is provided; to provide you with information, products or services that you request from us; to carry out our obligations and enforce our rights; to improve our Site and present its contents to you; to promote safety, security and integrity; for analytics, testing, research, analysis and product development; as necessary to protect rights, property or safety; to respond to law enforcement requests; as described to you when collecting your Personal Information.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose: Category A (Identifiers), Category B (Customer Records personal information categories), and Category D (Commercial information).
We disclose your Personal Information for a business purpose to the following categories of third parties: contractual service providers; affiliated advertising networks, internet service providers and data analytics providers; third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
Your Rights
You may have the following rights regarding your Personal Information maintained by Thrive: request to know and access the Personal Information we collect, use, and disclose; request deletion of Personal Information; request to opt-out of the sale or sharing of Personal Information; right to limit use and disclosure of sensitive Personal Information; and not receive discriminatory treatment by Thrive for exercising these rights.
Requests to Know and Access
You may have the right to request that we disclose to you the categories of Personal Information collected, the categories of sources, the categories of third parties with whom we share, the business purpose for collecting, and specific pieces of Personal Information collected. You may only make a request for access twice within a 12-month period.
Requests to Delete
You may have the right to request that we delete Personal Information associated with you, subject to applicable law and certain exceptions.
Request to Correct Inaccurate Personal Information
You may have the right to request that Thrive corrects Personal Information that is inaccurate.
Requests to Opt-Out of the Sale or Sharing of Your Personal Information
You may have the right to submit a request to opt out of any sale or sharing of your Personal Information or the processing of your Personal Information for purposes of targeted advertising. However, Thrive does not sell your Personal Information and does not use or share Personal Information collected from users of our public websites to engage in targeted advertising unless you have opted-in to such use. And, in the last 12 months, Thrive has not sold or shared Personal Information (as those terms are defined under the applicable law).
How to Exercise Your Rights
To submit a request to exercise any of your rights, please email us at clinic@thrivehrt.com. As required under applicable law, we must take steps to verify your request before we can provide Personal Information to you, delete Personal Information, or otherwise process your request. We will further verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We will deliver Personal Information that we are required by law to disclose to you within forty-five (45) days after receipt of a verifiable request.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may designate an authorized agent to request any of the above rights on your behalf.
Right to Nondiscrimination
You have the right to be free from discriminatory treatment for exercising the privacy rights conferred by applicable law.
Updating This Privacy Statement
This Privacy Statement may be updated periodically to reflect changes in our privacy practices. It is your responsibility to review the Privacy Policy from time to time to view any such changes.
How to Contact Us
If you have any questions about our privacy practices or this Privacy Policy or Privacy Statement, please email us at clinic@thrivehrt.com.
THRIVE TELEHEALTH NOTICE OF PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
I. Effective Date
This Notice of Privacy Practices (“Notice”) took effect on August 1, 2024. It will remain in effect until Thrive Telehealth LLC (“Thrive,” “we,” “us,” “our”) replaces it. Thrive shall abide by the terms of this Notice while it is in effect.
II. Thrive’s Commitment To Your Privacy
Thrive is a clinically integrated care setting in which our members receive health care services (“Services”) from more than one health care provider. Thrive respects and is committed to protecting the privacy of your medical information. In performing its Services, Thrive will receive, create, and disclose your protected health information (“PHI”). Thrive is required by law to maintain the privacy and security of your PHI and to provide you with notice of our legal duties and privacy practices with respect to your PHI. For information about our collection, use, and disclosure of personal information other than PHI, please see our Privacy Policy and related privacy notices posted on our Site.
III. Your Information and Rights; Our Responsibilities
A. Information We Collect About You
To provide you with the Services, we collect PHI about you from a few sources including directly from you. PHI is information about you that may be used to identify you (such as your name), and that relates to your past, present or future physical or mental health or condition, the provision of healthcare to you, or your past, present, or future payment for the provision of healthcare.
PHI Collected From You: As you use our Services, you will need to provide us with information about yourself and your medical history, past treatment, and potential future treatment options. As you communicate with us your telephone calls, emails, and other communications between you and us may be recorded and logged.
PHI Collected from Third Parties: Connected with our Services, we may collect information about you from third parties such as past or current health care providers, your pharmacy, your medical file that you provide, or other organizations that may contract with us to give you access to the Services.
PHI Collected Automatically: When you register or log in to our Site from the third party software we use for account creation and management, we may automatically collect information about you including IP address, device information, general geographic information, and date and times you accessed and used our Site.
B. When We Use and Share Your Information
Treatment Activities: We will use your PHI within Thrive to treat you and provide you with services. We may also disclose your PHI to other physicians or health care providers so that they can treat you, and we may be required to disclose your PHI to third party labs and pharmacies so they can ship you any prescription you may be prescribed.
Payment Activities: We can use and share your PHI to get paid and for other payment activities.
Healthcare Operations Purposes: Thrive may use and disclose your PHI to run our business, including contacting you about the Services available to you, monitoring the qualifications of providers, improving medical services, providing customer service, and conducting quality reviews.
C. When We Must Share Your Information
There are limited times when we may be permitted or required by law to use or disclose your PHI without your authorization. These may include: for public health activities; to protect victims of abuse or neglect; for workers compensation claims; for judicial and administrative proceedings; when required by law for law enforcement purposes; for specialized government functions; to prevent or lessen a serious and imminent threat of harm; for research approved by an Institutional Review Board; to coroners, medical examiners, and funeral directors; and for organ donation and transplantation.
D. When We Need Your Authorization
We will not share your PHI for other purposes not described in this Notice. If we want to use or disclose your PHI for any other purpose, we will seek your authorization using a HIPAA authorization form. You have the right to revoke any authorization that you previously provided.
E. Your Rights Regarding Your PHI
You have the following rights regarding your PHI maintained by us. Additionally, your medical power of attorney or legal guardian can exercise these rights on your behalf.
• Right to Access PHI: Most of your PHI that we maintain will be available to you through your portal. To request access to information that is not available to you online, please submit a request to us in writing.
• Right to Request Amendment of PHI: You have the right to request that we amend your PHI if you believe that it is incorrect.
• Right to Request Restrictions On Uses and Disclosures of PHI: You have the right to request that we do not use or disclose your PHI for treatment, payment, or health care operation purposes.
• Right to Request Confidential Communication: You may request that we communicate with you through alternate means or an alternate location.
• Right to Request an Accounting of Disclosures: You have the right to receive an accounting of disclosures we have made of your PHI.
You also have the right to obtain a digital copy of this notice from us upon request, file a complaint with your Secretary of State if you believe that your privacy rights have been violated, and obtain more information about our privacy practices by contacting us at clinic@thrivehrt.com.
F. How We Keep Your PHI Safe
The security of your PHI is very important to us. We use administrative, technical, and physical safeguards to keep your PHI from unauthorized access, and other threats and hazards to its security and integrity. We base our security program on complying with state and federal law, including the HIPAA security regulation guidelines as well as industry best practices. If your PHI is disclosed to an unauthorized person, despite our security safeguards, we will notify you promptly if such disclosure may have compromised the privacy or security of the PHI.
G. Changes To This Notice
We reserve the right to change the terms of this Notice at any time, as long as the changes are in compliance with applicable law. If we change the terms of this Notice, the new terms will apply to all PHI we maintain. If we change this Notice, we will post the new Notice on our Site and it will be available at the bottom of the Site.
