Therap Privacy Notice for California Residents

Last updated: February 23, 2021

Therap Services, LLC and its affiliates (collectively, “Therap,” “we,” or “us”) is a web-based service organization that provides an integrated software solution, live help, in person training, and other services (collectively, the “Services”) to assist the documentation, reporting, and communication needs of agencies and companies providing support to people receiving long-term services and support. As such, we understand the importance of your privacy and we take our responsibility to protect your information seriously. We have prepared this privacy notice (the “Notice”) pursuant to the California Consumer Privacy Act (the “CCPA”) to provide information regarding the categories of information we collect from California residents, how we use and share that information, and rights and obligations relating to that information.

This Notice applies to the personal information we collect from California residents who use our website (www.therapservices.net), attend one of our events, communicate or request information from us, or purchase one of our products. This Notice does not, however, apply to personal information that our customers may upload, provide, or collect through their use of the Service. Our customers are solely responsible for determining the purposes and means of processing personal information through the Services and, as to such information, Therap is only a “service provider” under the CCPA.

This Notice does not apply to employment-related personal information we collect from our California-based employees or job applicants. In addition, it does not apply to personal information we collect in connection with written or verbal business-to-business communications or transactions—which is the vast majority of personal information we collect—which is currently subject to a temporary exemption from some of the CCPA’s requirements.

Please note that this Notice is a supplement to our Privacy Policy, which can be viewed here, https://www.therapservices.net/privacy-policy/.  We encourage you to review our Privacy Policy.

Personal Information We Collect and How We Collect It

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident, household, or device. It does not include information that is publicly available from government records or information that has been de-identified or aggregated and can no longer be associated with a particular individual, household, or device.

In the past 12 months, we have collected the following categories of personal information from California residents.

Direct collection: We collect this information directly from you when you choose to provide it to us by downloading information from our website, filling out forms on our website, requesting information with us, communicating with us (whether via email, website chat feature, or phone), attending one of our events, registering to receive emails or information from us, and signing up for an online training or certification.

Indirect and technology-based collection: We also collect certain information from you indirectly when you visit, use, and navigate across our website, your internet domain and IP address, the browser and operating system you use, the date and time you access our website, searches or entries you make on our website, the pages you visit, and whether you linked to our website from a different website (and that website’s web address). We do so by using the following technologies:

• Cookies (or browser cookies). A cookie is a small data file that our website transfers to your computer. We deliver these cookies and collect data on our website, and we may also use a third-party agent to deliver cookies and collect data. We use the data we collect using cookies to help support the integrity of the registration and buying processes on our website, retain your preferences and account settings, and improve our site and your experience.
• Flash Cookies. We may also use flash cookies (local shared objects) to enhance your online experience. Flash cookies are small files similar to browser cookies and are used to remember the site’s settings to personalize the look and feel of the site.
• Web Beacons. Web beacons are electronic images that may be used on our site or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness, and to tell if an email has been opened or acted upon.
• Hotjar – We use Hotjar in order to better understand our users’ needs and to optimize their website experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our website with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

How We Use Your Personal Information

We use the personal information that we collect from you for the following business and commercial purposes:

• To present our websites and their contents to you and make any necessary improvements to our website.
• To register you for an event or training and provide you access to training materials.
• To respond to your comments and questions and provide information or training requested.
• To fulfill any other purpose for which you provide it, such as subscribing you to an e-mail newsletter or contacting you in response to your request for us to do so.
• To send you communications and information about our services, offers, promotions, news, and upcoming events for Therap.
• To notify you about changes to our website.
• To allow you to participate in interactive features on our website, if any.
• To comply with applicable laws, regulations, and legal process.
• In any other way we may describe when you provide the information or to which you consent.
• As otherwise necessary or useful for us to conduct our business, provided the use is permitted by law. For example, analyzing audience and use patterns from the websites, storing information about your preferences and allowing us to direct or customize specific content to you, and recognizing you when you return to our website.
• For the protection of our operations or those of any of our affiliates, or to protect our rights, privacy, safety or property, or that of our affiliates, you, or other parties.

Disclosure and Sale of Personal Information

Therap only shares your personal information as set forth in this Notice or our Privacy Policy. We do so only for business purposes. Therap does not “sell” your personal information, as defined by the CCPA, and has not done so during the past 12 months. Third parties with whom we may share your information include:

• Service providers, but only as necessary for us to conduct business and provide the agreed-upon services to you or related services.
• Governmental agencies, as may be required by law.
• With our wholly-owned affiliate for the purpose of product development related to our Services.

During the past 12 months, Therap has disclosed the following categories of personal information relating to California residents that have used its website, communicated with Therap, or requested information from Therap:

Please note that we may also use, disclose, or transfer your information in connection with the sale, merger, dissolution, restructuring, divestiture, or acquisition of our company or its assets. We may also disclose your personal information in response to a court order, subpoena, search warrant, law, or regulation.

Your Rights Under the CCPA

The CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

1. Right to Request Access Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past 12 months. Specifically, you may request that we disclose:
   • The categories of personal information we collected about you;
   • The categories of sources for the personal information we collected about you;
   • The business and commercial purposes for collecting your personal information;
   • The categories of third parties with whom we shared your personal information;
   • The specific pieces of personal information we collected about you; and
   • If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.
2. Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible.
3. Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by calling us at 1-866-THERAP-0 or submitting a request via email at privacypolicies@therapservices.net. Your request must allow us to reasonably verify that you are the individual regarding whom we collected the personal information and must describe the request with enough detail that we can understand and respond to it. Specifically, to verify you and the legitimacy of your request, you must initially provide your name, address, and email address, as well as a detailed explanation of your request. If you do not provide this information, we will not be able to respond to your request or provide you with the personal information requested. We may, however, need to request additional information for verification purposes. Please do not provide social security numbers, government identification numbers, payment card information, bank account information, or any similarly sensitive information as part of your request.

You may only submit requests for access or data portability twice within any 12-month period. As indicated above, please be aware that the CCPA provides certain limitations and exception to the foregoing rights, which may result in us denying or limiting our response to your request.

The CCPA requires us to respond to a verifiable consumer request within 45 days, but permits us to extend that period by an additional 45 days, provided we notify you of the reason for the extension in writing. We will notify you that we have received your request within 10 days of its receipt. In general, we will not charge a fee to respond to a verifiable request, unless it is excessive, repetitive, or unfounded.

Our Commitment Not to Discriminate

If a California resident exercises the rights discussed above, consistent with the CCPA, we will not discriminate against that resident by denying goods or services, charging different prices or rates for goods or services, providing different levels or quality of goods or services, or suggesting that the resident will receive a different price, rate, or quality of goods or services.

Changes to this Notice

Please note that we may change this Notice from time to time. We will post changes here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Please check this Notice periodically for updates.

Our Contact Information

To contact us regarding this Notice, your rights under the CCPA, or to exercise those rights, please contact us using the information below.

Therap Services, LLC
Phone: 1-866-THERAP-0
Email: privacypolicies@therapservices.net