By using the Website, you consent to the terms and conditions of this Policy and to our processing and use of your and your child’s Personal Information (defined below) for the purposes identified herein. If you do not agree to the terms and conditions of this Policy, please do not use the Website. This Policy may change from time to time, your continued use of the Website after we make changes is deemed to be acceptance of those changes, please check the Policy periodically for updates.
Information we collect
We collect information from you (“Personal Information”) through the following sources:
- information you provide to us while creating an account through the Website,
- if you are a provider or therapist, that includes, but is not limited to, your name, email address, role, affiliated practice and related practice information, address, and number of bariatric surgeries performed per year.
- if you are a parent of a patient, that includes, but is not limited to, your name, your child’s name, your child’s date of birth, your child’s gender, your email and PHI (as defined below).
- Information associated with your profile, including but not limited to, user ID, dates you were first and last seen, surgery date, and date you were last contacted or we last heard from you;
- information provided when you contact us through the Website, including your name, email, and phone number; and
- general log information automatically collected when you visit or use the Website (e.g., your operating system, the web browser used to access the Website, and your Internet domain and IP address).
The Personal Information that we collect may include personally identifiable information such as your name, e-mail address and company as well as non-personally identifiable information such as your device’s operating system and web browser, your Internet domain and your IP address. You may update your Personal Information through your profile page.
While generally not collected by Thrive, the following information may be collected and used in certain circumstances;
- Protected Classifications under California or federal law: Examples include age, military or veteran status, marital status, nationality, citizenship, medical conditions, genetic information or other similar identifiers. This data may be collected in the course of providing services, human resources purposes, security, or to comply with all applicable legal obligations.
- Internet or other electronic network activity information: Examples include information including (but not limited to) browsing history and search history. This information may be used for Security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your Personal Information and to allow only the appropriate use of your Personal Information or to improve our website, services and products, through testing, research, analysis and product development.
- Inferences drawn from any of the information identified in the above categories used to create a profile about a customer. This information may be used to provide the services or products or customer service.
How we use and/or disclose your Personal Information
Thrive does not sell or rent your Personal Information. Notwithstanding the foregoing, we may disclose your Personal Information to third parties
- To whom you or your agents authorize us to disclose your Personal Information in connection with the services we provide you;
- To our affiliates/subsidiaries and related entities;
- Where disclosure is necessary to protect the safety, property or other rights of Thrive, its employees, officers and members;
- In aggregate form; or
- In any manner to which you provide your consent.
Thrive may also disclose aggregate information or de-identified information about users of the Website that is not personally identifiable to third parties without restriction.
Thrive may also disclose your Personal Information as required by law, with or without notice, when Thrive believes that disclosure is necessary to:
- Comply with the law, including a regulatory requirement, legal process served on Thrive or the Website, government request, or other court order;
- Protect and defend the rights or property of Thrive and its users.
- Protect the personal safety of users of Thrive, or the public.
Thrive may occasionally hire other companies to provide limited services on our behalf including, but not limited to, processing credit card transactions, packaging, mailing and delivering purchases, answering customer questions about products or services, consulting services, website analytics, printing, and sending postal mail. We will provide those companies only the information they need to deliver the service and for no other purposes.
HIPPA Privacy Notice
Thrive’s use and disclosure of certain of your information may be subject to the requirements of the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”) and applicable state law. Any information that you submit to us that constitutes “Protected Health Information,” as defined by HIPAA, is subject to HIPAA and applicable state law. The term “Protected Health Information” or “PHI” refers to individually identifiable health information about you or your child’s past, present or future physical or mental health or condition, the provision of health care to your child or the past, present or future payment for such care.
For more information regarding your rights under HIPPA with respect to your PHI review our HIPPA Privacy Notice.
Your Rights Regarding Your Information
This section applies to you if you are a natural person who lives in California, as defined in the California Consumer Privacy Act (CCPA). The CCPA provides you various Privacy-Related Rights (“Rights”) with respect to your Personal Information. This section provides you with general information regarding these Rights. The following resources include more specific information about the CCPA and your respective rights thereunder (if applicable):
Right to Notice: At or before the point of collection of Personal Information, customers, employees, job applicants and other individuals residing in the State of California are entitled to a notice that provides the categories of Personal Information collected about them, and the purposes for that collection.
Right to Know/Right to Access: A customer has the right to request information regarding our collection, disclosure, sale and/or use of their Personal Information over the previous twelve (12) months. A customer may request that Thrive disclose:
- Categories of Personal Information that We have collected about you;
- Categories of sources from which your Personal Information is collected;
- Categories of Personal Information about you that We have sold or disclosed for a business purpose;
- Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose;
- The business or commercial purpose for collecting or selling Personal Information; and
- Specific pieces of Personal Information that We have collected about you.
When providing you with your information electronically, Thrive will, to the extent possible, deliver the information in a portable manner that allows you to transfer the information to another entity.
Thrive may reject your request to know if your identity cannot be verified (your request is not a verifiable customer request), or if the information has already been provided twice within a twelve (12) month period. Thrive may also refuse to provide you with specific pieces of information that We have collected about you if disclosure creates a substantial, articulable, and unreasonable risk to the security of that Personal Information, your account with Thrive or the security of our systems.
Right of Deletion: A customer has the right to request the deletion of any Personal Information that We have collected from them, or that We maintain about them. Following our receipt of your verifiable customer request, Thrive will delete (and direct our Service Providers to delete) your Personal Information, subject to the exceptions permitted under the CCPA, or other applicable privacy law, and any legal obligations that We have to retain that information.
Right to Opt-Out of the Sale of your Personal Information: The CCPA provides a customer with the right to opt-out of the sale (as defined under the law) of his/her Personal Information. Thrive does not sell Personal Information, and thus does not provide you with a mechanism for opting-out.
Right to Non-Discrimination: Thrive will not discriminate against a customer in response to the decision to exercise any of the privacy rights granted to you under the CCPA.
Asserting Your Rights – Submitting a Request to Know or Delete: As previously stated, Thrive may reject your request if We cannot verify your identity. Please follow the instructions below, and provide the requested information to allow us to adequately address your request.
- If you have provided Thrive with your information via our website and reside in the State of California, you may submit your request via email at email@example.com.
- Your full name and email address, as provided by you to Thrive via our website;
- Your preferred contact phone number; and
- A brief description of why you believe Thrive has your Personal Information (i.e. you have submitted a “contact us” form through our website). Please note that any information you provide to Thrive under this section will be used solely for verification purposes and deleted once verification is established.
- If you are a current or former employee of Thrive residing in the State of California, you may submit your request via email at firstname.lastname@example.org. In the email, please indicate which Right you are exercising. In order to verify your identity, your request must include the following:
- Your full name and email address associated with your profile;
- Your preferred contact phone number; and
- Your hire date. Where possible, we require your hire date to be provided in the MM/DD/YY format.
- If you previously applied for employment with Thrive (job applicants) and reside in the State of California, you may submit your request via email at email@example.com. In the email, please indicate which Right you are exercising. In order to verify your identity, your request must include the following:
- Your full name and email address associated with your profile;
- Your preferred contact phone number; and
- The number of employment opportunities you have applied for with Thrive, as well as the Job Title and Job Code associated with each application, to the extent available.
Authorized Agents: You may exercise your right to know or your request for deletion of your Personal Information, through the use of an authorized agent. A request from an authorized agent on your behalf will only be accepted if the authorized agent provides us with written proof they are authorized to act on your behalf. We may also first require the authorized agent to verify their identity, before accepting the request. Thrive may deny requests from authorized agents that fail to provide proof of their status as an authorized agent or verification of their identity.
What are cookies?
Browser cookies are pieces of information stored within your computer’s Internet browser that automatically identify your browser to our server whenever you interact with the Website. They are widely used in order to make websites work, or work in a more efficient way, and provide information about our users’ experience during use of, or interaction with, the Website. Some cookies last only for the duration of your web session and expire when you exit your browser; other cookies may last for longer than your web session, including after you exit your browser, for example by remembering you when you return to a website.
Information We Obtain Through Cookies
How We Use Cookie Information
How You Can Manage Cookies
You may customize the browser settings of your computer to notify you when a browser cookie is sent or to refuse browser cookies altogether. Most browsers will tell you how to change your browser settings to notify you when a cookie is being set or updated, or to restrict or block certain types or all cookies. Please consult the “Help” section of your browser for more information or by visiting www.allaboutcookies.org. Your device settings may also allow you to prohibit mobile app platforms (such as Apple or Google) from sharing certain information obtained by automated means with us.
Third Party Cookies
Thrive will take reasonable steps to provide that your Personal Information is accurate, complete, and current, to its intended use. We provide individuals with reasonable access to the Personal Information that they provide to us, as well as the ability to review and correct such information. For access requests please contact us as set forth in “How to Contact Us” below
How We Store and Protect Your Information
To prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your Personal Information, we utilize physical, technical, and administrative controls and procedures to safeguard the information we collect.
To protect the confidentiality, integrity, and availability of your Personal Information, Thrive utilizes a variety of physical and logical access controls, firewalls, intrusion detection/prevention systems, network and database monitoring, anti-virus, and backup systems. We use encrypted sessions when collecting or transferring sensitive data through our websites.
We limit access to your Personal Information and data to those persons who have a specific business purpose for maintaining and processing such information. Thrive’s employees who have been granted physical access to your Personal Information are made aware of their responsibilities to protect the confidentiality, integrity, and availability of that information and have been provided training and instruction on how to do so.
Thrive will retain your Personal Information so long as your account is active or it is reasonably needed for the purposes described in this policy or to comply with our legal obligations, resolve disputes, and as applicable to agreements with our customers.
Third Party Websites
Thrive may also permit advertisers, third party ad networks or other advertising companies to serve advertisements on the Website. Please be advised that such advertising companies may gather information about your visit to the Website or other websites (such as through cookies, web beacons and other technologies) to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which websites you were viewing when such ads were delivered. Please note that this Policy does not cover the collection and use of information by such advertising companies.
To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of Personal Information, we employ procedural and technological measures that are reasonably designed to help safeguard the information we collect. Only authorized Thrive personnel have access to the Personal Information, including server logs and cookie utilization data, that we collect. Thrive may use encryption, secure socket layer, firewall, password protection and other physical and logical security measures to help prevent unauthorized access to such. Thirve may also place internal restrictions on who in the company may access data to help prevent unauthorized access to such information.
Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Therefore, despite our efforts, we cannot guarantee its absolute security. We do not warrant or represent that personal information about you will be protected against, loss, misuse, or alteration by third parties.
You are responsible for maintaining the confidentiality of your access information and password. You are responsible for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your password. We cannot secure any personal information that you release on your own, that you request us to release or that is released through another third party to whom you’ve given access.
Where required under applicable law or by contract, we will notify the appropriate parties or individuals of any loss, misuse or alteration of personal information so that such parties or individuals can take the appropriate actions for the due protection of their rights. If such Personal Information is information of a Thrive customer, we will notify such customer and coordinate with them regarding any required notices to particular individuals.
Privacy of children online
The Website is not intended to be used by children. Thrive does not knowingly collect information from children to sell or promote our services. No one under the age of 16 may provide information to Thrive on or through our Website, and if we learn that we have received information from a child under the age of 16, we will delete that information. If you believe we may have collected information from your child, please contact us immediately and we will take reasonable steps to delete it.
In the event that all or a portion of Thrive’s assets are acquired by another party, you hereby acknowledge and agree that Thrive may assign the Personal Information to such purchaser.
Changes to the Policy
Please check our Policy periodically for changes. We will notify you of material changes or updates. Any changes will be posted on this page and effective upon updating this Website.
How to contact us
If you have any questions, comments, or requests regarding this Policy, you can contact us via electronic mail at firstname.lastname@example.org.