Effective Date: July 15, 2025

Well Behavioral Health ASO LLC (“WellBH,” “Us” or “We”) takes your privacy very seriously.  We created this Privacy Policy to provide you with important information about the privacy practices applicable to the services provided by Us through the WellBH Platform (the “Platform”) and our website at http://wellbh.com (collectively, the “Services”). As used herein, “you” or “your” refers to you. This Privacy Policy describes how We collect, protect, use, disclose and store the information collected through the Services.

Through the Platform, you may connect with independent clinicians employed or contracted by the following organizations: Clinical Therapeutic Support LCSW, P.C. (d/b/a Eating Disorder Recovery Specialists and Mental Health Recovery Specialists), Sanctuary Psychology, P.C., and Dr. Sarah Chipps Psychology Services, P.C. (d/b/a Well Williamsburg) (collectively, our “Providers”). BY DOWNLOADING, ACCESSING, OR USING THE PLATFORM OR SERVICES, AND/OR BY REGISTERING WITH US OR PROVIDING INFORMATION TO US IN CONNECTION WITH THE APPLICATION, YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. IF YOU ARE REGISTERING AN ACCOUNT OR USING THE SERVICES ON BEHALF OF AN INDIVIDUAL OTHER THAN YOURSELF, YOU REPRESENT THAT YOU ARE AUTHORIZED TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL'S BEHALF.

Your use of the Services is also subject to our Terms of Use, which are available here. 

COLLECTION, USE, AND DISCLOSURE OF INFORMATION

What is Personal Information?

Personal Information is any information relating to a natural person who is, or can be, identified either directly or indirectly from such information and includes information such as a user’s name, address, telephone number, email address, Internet activity (such as browsing history), or other information directly linked to that person. You are not legally required to provide Personal Information to Us, but if you refuse to provide such information, We may not be able to register you to use the Platform.

Personal Information that We Collect

WellBH collects Personal Information from users (or such users’ parents or legal guardians) when users submit information through the Site or when users contact Us electronically. WellBH collects the following types of Personal Information which you may provide to Us:

• Name;

• Contact information, such as your address, phone number, and/or email address;

• Records and copies of your correspondence, if you contact Us; 

• Any other information you provide in your communications to Us;

• Details of transactions you carry out through our Site;

• Registration information related to Users and, if applicable, their parents/legal guardians; and

• Details of transactions you carry out through our Platform.

In addition, from time to time, We may use or augment the Personal Information We have about you with information obtained from other sources, such as public databases, social media platforms, and other third parties.

In addition to collecting Personal Information that you provide to Us, We may automatically collect certain Personal Information when you visit our Site and/or use the Services, such as IP address, information about your browser, device or operating system or similar information. IP addresses are ID numbers for the location of your computer or network on the internet. Log files are recordings of the traffic to and from a server. WellBH servers log IP addresses for systems administration and troubleshooting. We track page hits in the aggregate to track the popularity of pages that people visit. With that information We can improve the quality of our Site. We may also use or allow third parties to use web beacons on our Site to monitor the effectiveness of survey qualification. Web beacons are small, graphic images on web pages, web-based documents, or in email messages that allow Us or third parties to monitor who is visiting our Site or if an email has been read. Web beacons collect the IP address of the device where the web beacon is sent, the URL of the page where the web beacon originates, and the time it was viewed. Web beacons may be linked to your Personal Information. We may also use third-party devices, services, links, or electronic mail to deliver surveys to you, which may use cookies, web beacons, or other technology to collect information about your visits to our Site in order to present surveys that may be of interest to you.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites.  Our Services do not support Do Not Track requests at this time, which means that We collect information about your online activity both while you are using the Services and after you leave our Services.

How We May Use Personal Information

We and our third-party service providers may use Personal Information to:

• respond to your inquiries and fulfill your requests;

• provide support services related to the Services and related customer service;

• send to you administrative information, including information regarding the Services, and changes to our terms, conditions and policies;

• provide services to you; 

• schedule appointments with you;

• obtain or facilitate payments for appointments and related services provided and send payment receipts;  

• send to you marketing communications that We believe may be of interest to you;

• personalize your experience on the website by presenting products and offers tailored to you;

• further our business purposes, such as quality assessment, data analysis, audits, developing new products, enhancing the website, improving our Services, identifying usage trends to inform members of the WellBH community which aspects of the website might be useful to them, and determining the effectiveness of our promotional campaigns; and

• act as We believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) at our discretion under emergency circumstances, to notify emergency services or a client’s family members, personal representative, or other individuals involved in a client’s care of such client’s location and condition; or (h) to allow us to pursue available remedies or limit the damages that We may sustain.

We may also use aggregate or de-identified data that is not personally identifiable for any legally permissible purposes without restriction.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed to:

• our third-party service providers that provide services such as hosting of the Site, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing and other similar services;

• our affiliates, for the purposes described for Personal Information in this Privacy Policy, including marketing purposes relating to their products and services;

• third parties, to permit them to send marketing communications to you regarding our products or services;

• for other treatment, payment or health care purposes;

• a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding); and

• a third party as We believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce the Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) at our discretion under emergency circumstances, to notify emergency services or a client’s family members, personal representative or other individuals involved in a client’s care of such client’s location and condition; or (h) to allow Us to pursue available remedies or limit the damages that we may sustain.

WellBH does not sell or rent Personal Information that we have collected or retained about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of Personal Information because we do not engage in those practices. 

To the extent you consent to receive SMS communications from Us, your consent will not be shared with any third parties.

We may also disclose to third parties aggregate or de-identified data that is not personally identifiable for any legally permissible purposes.

Third Parties

This Privacy Policy does not address, and We are not responsible for, the privacy, information or other practices of any third parties, including Providers, the manufacturer of your mobile device, and any other third-party mobile application or website to which our Services may contain a link. We encourage you to review the Notice of Privacy Practices of each Provider who provides you with services and the privacy policies of each website and application you visit and use.

HIPAA

WellBH is regulated as a Business Associate under the Health Insurance Portability and Accountability Act (“HIPAA”). Certain demographic, health and/or health-related information that WellBH collects about clients as part of providing the Services may be considered “protected health information” or “PHI” under HIPAA.  Specifically, when WellBH is acting as a Business Associate (as such term is defined in HIPAA) and receives identifiable information from or about a client, this information is considered PHI. This Privacy Policy does not apply to PHI, which is instead regulated by the Providers’ Notice of Privacy Practices and our agreements with the Providers.  

 Please note that, as part of WellBH’s services, you and WellBH may need to transmit PHI to you or Providers. You acknowledge and agree that WellBH may send Personal Information constituting PHI to you via email or text, which are not secure methods of communication.  Please notify WellBH if you do not wish to transmit or receive PHI through these methods, and WellBH will arrange for an alternative secure method of communication.   

Children’s Privacy

WellBH is concerned about the safety and privacy of children online. Because of this, We will make all efforts to comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). COPPA and its accompanying FTC regulations establish United States federal law that protects the privacy of children using the internet. Further, WellBH Services are intended only for minors whose parents/legal guardians have consented to their use of such Services.  However, it is possible that by fraud or deception by others We may receive information given to Us or pertaining to minors, including children under 13. If We are notified of this, as soon as We verify the information, We will immediately obtain parental consent or else delete the information from our servers. If you want to notify Us of our unauthorized receipt of information by minors, including children under 13, please email techsupport@wellbh.com

Notwithstanding the foregoing, depending upon the functionality available in the Platform, you, a partner or legal guardian may register a minor under their supervision for access to our Services as a Patient User. In such cases, our Services may include features through which a parent or guardian may be permitted to view the Personal Information or manage the benefits on behalf of registered minors. The parent or guardian shall have permission to view the Personal Information of the minor they register until such minor reaches the age of majority or otherwise qualifies as an emancipated minor under applicable law and provide WellBH with evidence of such emancipated status.  The availability of the Personal Information of minor’s information to the parent or guardian may depend on the minor’s preferences, available website functionality, and applicable law. Upon turning 18, We will cease providing access to Services to the parent or guardian related to a minor that reaches the age of majority, at which point the minor that reaches the age of majority will be required to take ownership of their own registered account.

Security

We seek to use reasonable physical, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system is 100% secure, and therefore We cannot guarantee against all potential security breaches.  If you have reason to believe that your interaction with Us is no longer secure (for example, if you feel that the security of any account you might have with Us has been compromised), please immediately notify Us of the problem by contacting Us in accordance with the “Contacting Us” section below.

Storage of Data

We will only store Personal Information for as long as it is needed to fulfill the purposes for which it was collected, subject to applicable data retention periods imposed upon Us by applicable law. This may mean that your Personal Information is stored by Us for a number of years, depending on the purpose and need for that data to be processed.

Updates to the Privacy Policy

We may occasionally update this Privacy Policy at any time.  Any changes to this Privacy Policy will become effective when We make the revised Privacy Policy available through the Services. We will update the “Effective Date” date at the top of this Privacy Policy if We make any such changes to this Privacy Policy. Your use of the Services or the submission of any information in connection with the Services following any change means that you accept the revised Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about how We collect, use, and disclose personally identifiable information.

Contacting Us

If you have any questions or comments about this Privacy Policy, please contact Us by e-mail at techsupport@wellbh.com.  Please note that e-mail communications are not always secure; so please do not include health information, credit card information or other sensitive information in your e-mail messages to Us.