1. About Your Privacy and This Privacy Policy
    Your privacy is extremely important to us. We are constantly putting a great deal of thought, effort, tools, resources and procedures in place in order to protect and safeguard your privacy. This document is our “Privacy Policy,” and it contains details on issues related to your privacy when using our services. This Privacy Policy applies to visitors to the public websites owned and operated by GroTru, the registered users of GroTru’s associated mobile and web application (collectively with the websites, the “Platform”), and to the therapists that provide the Therapist Services (“Therapists”). It is intended to inform you of our policies, procedures, and practices regarding the collection, use and disclosure of any information that you provide through the Platform.
    The Privacy Policy does not apply to the collection and use of certain employment-related information for employees of GroTru or its parent company. If you are a current or former GroTru job applicant, employee, owner, director, officer, or contractor, please contact us at hello@GroTru.com for the appropriate notice.
    If you are visiting our website as a California, United Kingdom, or European Union resident, your rights under the privacy laws applicable in your jurisdiction are represented in an addendum to this policy. If you do not see this addendum below, please contact us at hello@GroTru.com to receive the additional information describing your rights under these laws.
    The Privacy Policy is part of our Terms and Conditions. The terms in the Privacy Policy (such as, but not limited to, “we”, “our”, “us”, “Platform”, and “Therapist Services”) have the same meaning as in our Terms and Conditions document. When you use our Platform, you accept and agree to both the Terms and Conditions and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Platform immediately or cease to provide the Therapists Services, as applicable. By accessing and using our Platform or providing the Therapist Services, as applicable, you affirm that you have read the Terms and Conditions and the Privacy Policy and that you understand, agree to and acknowledge all the terms contained in both of them.
  2. Information Collection, Use, and Disclosure
    Categories of Information Collected
    To let us operate the Platform effectively and to let you use the Platform, including the Therapists Services, we may collect, use, and store the information described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Platform. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy.

    Visitor Data
    GroTru collects, uses, and stores data regarding user visits to its website and use of the GroTru application (“Visitor Data”), including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to the GroTru “FAQ” page, and information about the browser or device used to access the website and application, such as the user’s mobile device ID and IP address. These practices apply to users who visit pages for prospective new customers as well as those who visit pages for prospective Therapists.

    Onboarding Data
    In addition to the questionnaire responses provided by users (including Therapists) in the process of initial registration, GroTru collects, uses, and stores certain additional data from users during the onboarding process (“Onboarding Data”). This data includes the pages viewed by the user, whether the user clicks the “Get started” link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.

    Account Registration Data
    GroTru collects, uses, and stores certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number (“Account Registration Data”). GroTru also assigns each user (including Therapists) who creates a GroTru account an anonymized, sequentially-generated client ID.

    Transaction Data
    GroTru collects, uses, and stores certain information regarding payment for its services by users and related transactions on its website, such as whether a user completed payment for GroTru’s services, signed up for GroTru’s services using a trial offer, canceled or otherwise ended a trial, or completed a request to receive financial aid for GroTru’s services (“Transaction Data”).

    Login Data
    GroTru collects, uses, and stores data regarding logins to GroTru’s Platform by registered users (including Therapists) and activity conducted during that log in such as when a user logs in, the number of messages received or sent through GroTru’s website or app during that log in, and whether a user has been assigned, started, or completed a Therapist goal (“Login Data”). Login Data does not include the content of any messages sent or received by users or the content of any Therapist goals.

    GroTru collects, uses, and stores certain data from users that have signed up for GroTru’s services such as a user’s self-reported name or nickname, age, e-mail address, phone number, and emergency contact information (“Customer Data”).

    Communications Data
    GroTru collects, uses, and stores communications between users and Therapists on the Platform, and communications between users and GroTru’s customer service team (“Communications Data”).
    Protecting this information is important for us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless you requested or approved us to do so.
  3. Purposes for Which Information Is Used
    We may use the information we collect for one or more of the following purposes:
    Communication with you
    • To contact you or provide you with information, alerts and suggestions that are related to the Platform.
    • To verify your identity.
    • To complete an activity you requested, such as register for the Platform or obtain more information.
    • To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.

    Delivery of services to you
    • To create your account on our Platform and let you log in to your account and use the Platform.
    • To manage your account, provide you with customer support, and ensure you are receiving quality service.
    • For billing and transaction processing purposes.
    • To match users with Therapists and facilitate the Therapists Services.
    • To provide, support, personalize, and develop our Platform and the Therapist Services.

    Administration and improvement of services
    • To supervise, administer and monitor the Platform.
    • To measure and improve the quality, effectiveness, and delivery of our services.

    • To personalize the website experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads.

    Compliance with law
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and safety.
    • To allow therapists to comply with the licensure, legal and quality requirements in their jurisdictions.

    Other uses with consent
    • Any other purpose with your consent.

  4. Purposes for Which Information Is Disclosed to Third Parties
    Information about you may be disclosed to third parties for one or more of the following purposes:
    For business purposes
    Only as necessary for facilitating the Therapists Services, we may share a user’s information with a Therapist and a Therapist’s information with a user. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.
    With your direction or consent
    We may share your information with third parties if you request or direct us to do so.
    With affiliates within our corporate group
    We may share your information with any subsidiaries or parent companies within our corporate group.
    For advertising
    If you opt-in to the use of targeting cookies and web beacons, information regarding your activity on our websites, excluding activity when you are logged in and have started therapy, may be disclosed to our advertising partners to optimize marketing. We do not share with any advertising platform private information like member names, email addresses, phone numbers, diagnosis, sessions data, journal entries, messages, worksheets, or any other type of communication you have with your therapist.
    Compliance with law 
    We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.
    In the context of a transaction
    We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.
    For other business reasons
    We may share your information to enforce any applicable Terms and Conditions and Terms of Use, and to ensure the safety and security of the Platform and our users.
    Note that if you make any information publicly available on the Platform, anyone may see and use such information.
  5. Opting-out of Marketing Communication
    You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.
  6. Cookies and Web Beacons
    Like many websites, we use “cookies” and “web beacons” (also known as pixels) to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record-keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. A “web beacon” is a tiny and sometimes invisible image or embedded code, placed on a Web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users at a website for the purpose of web analytics, advertising optimization, or page tagging.
  7. Additional information regarding web beacons is available on Wikipedia.
    You can change your browser’s settings so it will stop accepting cookies and web beacons or to prompt you before accepting a cookie or web beacon.
  8. Use of Cookies, Web Beacons, and Similar Technology for Analytics
    We may use third party cookies or web beacons for the purposes of web analytics, attribution, and error management. Our Platform may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, indicate that you heard about us on television, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, and your response as to the referral source to the Platform.Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our websites for purposes of analytics and analysis of certain Platform usage.
  9. Use of Cookies, Web Beacons, and Similar Technology for Advertising Networks
    If you opt in to the use of targeting cookies and web beacons, you and others may see certain ads for our services or for the Platform on other websites because we participate in ad networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track individuals’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites.
  10. Social and General Information Tools
    We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, and others (collectively “Social and General Information Tools”). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.
  11. Phishing
    Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).
  12. Advertising Disclosure
    We may occasionally feature advertisements or sponsored content. These advertisements may be displayed in various formats, including banners, text links, and sponsored articles.
  13. Advertisement Identification
    We strive to make it clear when content is advertising material. Advertisements will typically be labeled as “Advertisement,” “Sponsored,” “Promoted,” or similar terms. However, please be aware that while we make every effort to distinguish advertising from regular content, some advertisements may blend in with the site’s design to enhance user experience.
  14. Third-Party Advertisers
    Our website may partner with third-party advertising networks and advertisers to display these advertisements. These third parties may use technologies such as cookies, web beacons, and similar tracking technologies to collect information about your interactions with their ads and tailor content to your interests. Please refer to our [Cookie Policy](link to your cookie policy) for more information on how we and our advertising partners use cookies.
  15. Affiliate Marketing
    In some cases, we may participate in affiliate marketing programs. This means that if you click on certain links on our website and make a purchase through those links, we may receive a commission from the affiliate program. Rest assured, this does not affect your purchase price, and we only recommend products or services that we genuinely believe will be of value to our readers.
  16. Privacy Policies of Third Parties
    When you click on an advertisement or a link that takes you to a third-party website, you should review the privacy policies of those websites. We have no control over the content and practices of these websites and are not responsible for their privacy policies.
  17. Your Choices
    You can manage your preferences regarding online advertising by adjusting your browser settings or using ad-blocking software. Please consult the documentation or support resources for your browser or ad-blocking software for instructions on how to do this.By using this website, you acknowledge and agree to the practices described in this Advertising Disclosure. We encourage you to review this policy periodically, as it may be updated from time to time to reflect changes in our advertising practices or applicable laws and regulations. If you have any questions or concerns about our advertising practices or this disclosure, please contact us at hello@grotru.com.
  18. Your CCPA Rights
    The CCPA grants California residents certain rights concerning their personal information. If you are a California resident, you have the right to:
    • Request Disclosure: You have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months. This includes the specific pieces of personal information we have collected, the categories of sources from which we collected personal information, the purposes for which we used the personal information, and the categories of third parties with whom we shared the personal information.
    • Request Deletion: You have the right to request the deletion of your personal information collected or maintained by us, subject to certain exceptions under the CCPA.
    • Opt-Out of Sale: If we sell your personal information, you have the right to opt-out of the sale of your personal information. We do not sell your personal information, as “sale” is defined under the CCPA.
    • Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. This means we will not deny you goods or services, charge you a different price, or provide a different level or quality of services if you exercise your rights under the CCPA.
    • Exercising Your CCPA Rights
      To exercise your rights under the CCPA, you may submit a verifiable consumer request to us by [provide a method for submitting requests, such as an email address or a web form]. We will respond to your request within the timeframes required by law.
    • Verification Process
      To help protect your privacy and maintain the security of your personal information, we will verify your identity before fulfilling your CCPA rights request. We may request additional information from you to verify your identity.
    • Contact Us
      If you have any questions or concerns about your CCPA rights or how we handle your personal information, please contact us at [Contact Information].
    • Changes to this CCPA Privacy Notice
      We may update this CCPA Privacy Notice from time to time to reflect changes in our data practices or legal requirements. We will update the “Last Updated” date at the bottom of this notice when we make changes.
  19. Links
    The Platform may contain links to other websites, services, or offers that are owned, operated, or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third-party websites and services, and we do not have control over their privacy policies and terms of use.
  20. Security of Information
    While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built, and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable federal laws, state laws, and regulations regarding data privacy.
  21. Service Providers
    We may employ third-party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational, or other services for us. These tasks include, but are not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.
  22. Children’s Privacy
    We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you are aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.
  23. Compliance with Laws and Law Enforcement
    We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal processes (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Therapists may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases:
    (a) reported or suspected abuse of a child or vulnerable adult;
    (b) serious suicidal potential;
    (c) threatened harm to another person;
    (d) court-ordered presentation of treatment.
  24. Changes to the Privacy Policy
    We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform.
  25. Contacting us
    If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by clicking the “Contact” link on any page in our website.

Last Updated and Effective: September 2023


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