Headway California Privacy Notice for Business Customers
Last Updated: August 8, 2023
This Headway California Privacy Notice for Business Customers (“CA Business Privacy Notice”) describes how Therapymatch, Inc. d/b/a Headway and our subsidiaries and affiliated companies (collectively, “Headway”, “we”, “us”) collect, use, and disclose information from and about those who engage with Headway in a commercial or business capacity, including mental health care providers (“Providers”) and those that work for or on behalf of health plans (“Plan Representatives”) (collectively, “Business Customers”, “you”, “your”). This CA Business Privacy Notice applies to information we collect when you access or use our websites, mobile applications, and other online products and services, or when you otherwise interact with us where we provide this CA Business Privacy Notice, such as through our customer support channels (collectively, the “Services”). In some circumstances, we may provide different or additional notices of our privacy practices to the extent they apply to you because of the product or services you obtain from us or different laws that may apply. For example, if you interact with us as a consumer for products and services covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), our Notice of Privacy Practices apply to you and not this CA Business Privacy Notice. In addition, if you interact with us as a consumer with respect to our non-HIPAA covered products and services our Privacy Policy applies to you as described therein. If you are a Business Customer that resides in California, the Additional California Notice and Privacy Rights section below applies to you.
We may change this CA Business Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this CA Business Privacy Notice. We encourage you to review this CA Business Privacy Notice regularly to stay informed about our information practices and the choices available to you.
Contents
Notice of Collection and Uses of Information
We collect and use your information in a variety of ways. We collect information you provide directly to us. For example, we collect information directly from you when you create an account, fill out a form, request Services or customer support, or otherwise communicate with us. We also collect certain information from you or your device automatically when you interact with our Services such as activity or usage information. We use this information to provide you Services and for other business purposes. The types of information about you that you provide and that we collect automatically are listed below along with our uses of that information.
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- We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
- In addition, we may use the above categories of information to create de-identified, anonymized, or aggregated information that no longer identifies or relates to a specific person. We use such de-identified, anonymized, or aggregated information in accordance with applicable law.
- We may also use the personal information listed above to comply with legal and financial obligations and/or to carry out any other purpose described to you at the time the information was collected.
- Additionally, if you make a payment through our Services, we work with a third-party payment processor that collects and processes your payment information, and we do not directly handle your payment card information.
Information We Collect from Other Sources
In addition to collecting information from you, we obtain information from other sources. For example, we may collect information from other Providers who refer you to Headway, credentialing service providers, background check, and mailing list providers. This information includes your name, address, email address, professional information such as degrees and certifications and work history, criminal history, credit history.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.
Retention of Personal Information
We will retain your Personal Information for as long as reasonably necessary to carry out the purposes disclosed in this policy.
Disclosure of Information
We disclose the following categories of personal information to the recipients described below for the following business purposes or as otherwise described in this policy:
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In addition, we may disclose any of the categories of personal information listed above for the following purposes:
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Headway, our users, the public, or others.
- We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is disclosed between and among Headway and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We disclose personal information with your consent or at your direction.
We also use and disclose aggregated or de-identified information that cannot reasonably be used to identify you.
Advertising and Analytics
We engage service providers and/or contractors to provide analytics services. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. Headway and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
Google Analytics. We use analytic services such as Google Analytics to manage our operations and better understand how you engage with the Services we provide to you. More specifically, we use Google Analytics to analyze information regarding visits to our Services, including, for example, to measure traffic and flow to our Services, frequency and duration of visits to our site, and how visitors come to our site. Click here to learn about the different ways How Google uses information from sites or apps that use its services, including for analytics, and see the Google Privacy Policy to learn more about its privacy practices and how you can manage your privacy preferences.
Transfer of Information to the United States and Other Countries
Headway is headquartered in and offers Services to those in the United States, and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law.
Your Choices
Account Information
You may update and correct certain account information at any time by logging in and updating your information. If you wish to deactivate your account, please contact compliance@findheadway.com, but note that we may retain certain information as required by law or for our legitimate business purposes.
Location Information
When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile apps from your device.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
Additional California Notice and Privacy Rights
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act (“CPRA”), affords Business Customers residing in California certain rights with respect to their personal information. So, in addition to the notices provided above, if you are a California resident, this section applies to you as indicated.
California Sales and Sharing of Personal Information
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act (“CPRA”), affords Business Customers residing in California certain rights with respect to their personal information. So, in addition to the notices provided above, if you are a California resident, this section applies to you as indicated.
We do not knowingly sell or share personal information about consumers under the age of 16.
Privacy Rights
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request correction of your personal information, (3) request deletion of your personal information, and (4) not be discriminated against for exercising these rights. You may make these requests by sending an email to privacyrights@findheadway.com. If we need to further verify your request, we may do so by asking you to provide information related to your interactions with us.
If we deny your request, you may appeal our decision by contacting us at privacyrights@findheadway.com.
Opt-out Preference Signals
Some browsers allow you to enable privacy-controls in the browser's settings to automatically signal your opt-out preference to the websites you visit (e.g., Global Privacy Control). To the extent we are required to offer opt-outs through Global Privacy Control, we honor Global Privacy Control signals as a valid request to opt-out of the sharing of information linked to your browser. Please be aware, however, that opt-out preference tools are limited to the browser or device you are using. Also, to maintain your privacy preferences, your browser may save some information in its cookies and cache, and if you clear cookies, you may remove your opt-out preferences so that you may have to opt-out again.
If we receive your request from an authorized agent and they do not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you are an authorized agent seeking to make a request, please contact us at privacyrights@findheadway.com.
Contact Us
If you have any questions about this CA Business Privacy Notice, please contact us at compliance@findheadway.com.