Overview

StrengthenU is dedicated to protecting its customers’ and employees’ private information and maintaining the highest level of confidentiality of records. This Privacy Policy describes the information we collect, how we use it, and the standards and procedures in place to safeguard your personal nonpublic information.

StrengthenU, it’s personnel, and its affiliates strictly adhere to this Privacy Policy and the security practices and procedures described herein to ensure the confidentiality of customer information. It is StrengthenU’s policy to comply with all federal and state laws and regulations relating to the privacy of our customers’ private information (PI) and private health information (PHI).

We receive different types of information about you, including the information that’s required when you sign up for the service, as well as the information you choose to share.

Except as permitted by law or as otherwise described below, StrengthenU does not disclose any PI or PHI about its customers, or former customers, or employees, to anyone. StrengthenU does not sell customer information to anyone.

StrengthenU is dedicated to protecting its customers’ and employees’ private information and maintaining the highest level of confidentiality of records. This Privacy Policy describes the information we collect, how we use it, and the standards and procedures in place to safeguard your personal nonpublic information.

StrengthenU, it’s personnel, and its affiliates strictly adhere to this Privacy Policy and the security practices and procedures described herein to ensure the confidentiality of customer information. It is StrengthenU’s policy to comply with all federal and state laws and regulations relating to the privacy of our customers’ private information (PI) and private health information (PHI).

We receive different types of information about you, including the information that’s required when you sign up for the service, as well as the information you choose to share.

Except as permitted by law or as otherwise described below, StrengthenU does not disclose any PI or PHI about its customers, or former customers, or employees, to anyone. StrengthenU does not sell customer information to anyone.

What StrengthenU Collects – Employees and Sub-Contractors

Federal law requires us to obtain, verify, and record personal information – such as your name, address, and date of birth to confirm your identity, social security number and banking information.
StrengthenU collects, retains, and uses PI from employees and subcontractors including the following:

  • Information StrengthenU receives on applications or other forms, including, but not limited to, identifying information such as address, telephone number, e-mail address, social security number, date of birth, mother’s maiden name, and medical history.
  • Federal Tax ID #
  • Medical records
  • Investment information
  • Background security checks

What StrengthenU Collects – Members

StrengthenU collects, retains, and uses PI/PHI from customers to include the following:

  • The information that is required when you sign up for the program.
  • Required information such as your name, email address, birthday, and gender. We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties.
  • Usernames and User IDs, which are a way to identify you on StrengthenU.
  • “Public Information” which means the information you choose to make public, as well as information that is always publicly available.
  • Information posted to a group chat and information kept within a one-on-one session.
  • “Contact Information” is personal information and or family/friend/relation that StrengthenU stores confidentially for your Therapist to access in case of an emergency or mental health crisis.
  • Information StrengthenU receives on forms, including, but not limited to, identifying information such as address, telephone number, e-mail address related to customer projects.
  • Banking information for billing purposes, such as account # and routing information for invoicing purposes.

The Usage of Any Collected Data by StrengthenU

StrengthenU uses non-identifying and aggregate information to better design the website and to use for research purposes. For instance, we may tell an advertiser that X number of individuals visited a certain area on our website, or that Y number of men and Z number of women filled out a site survey or form, but we will never disclose anything that could be used to identify individuals. We only provide data to our partners, if any, after we have removed names and any other personally identifying information from it or have combined it with other people’s data in a way that it no longer personally identifies someone.

The anonymous and aggregated data also may be published through various media platforms or academic journals. No personally identifying information is connected to the results, and StrengthenU does not share anything that could be used to identify someone’s private information.

Occasionally, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change in the future, we will communicate this before using that data for these new purposes with the ability to opt out.

StrengthenU stores data only for as long as it is necessary to provide products and services, including those described above and for legal protections or as required by applicable laws and regulations.

StrengthenU may allow service providers to access information so they can help us provide services. IP addresses are used to identify the location of users, the number of visits from different countries and to block disruptive use; and to analyze and improve the services offered on our website, e.g., to provide members with the most user-friendly navigation experience.

Certain information is needed to provide members with services, so we only delete this information after the account is deleted. Some forms of processing (sending promotional information, commercial profiling, behavioral advertising, geo-location, etc.) may require the express consent of the User. Specific information may be shown on the pages of the Site in connection with particular services or processing of Data provided by the Site User.
Upon request we provide site visitors with access to a description of information that we maintain about them. StrengthenU’s therapy platform uses industry-standard encryption technologies when transferring and receiving consumer data exchanged with our site.

Information StrengthenU Could Share

StrengthenU keeps your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies or during an emergency circumstance as judged by your Therapist working with local authorities). Generally, we only use your information within our company, but there may be times we utilize a third party to process your information, such as credit card payment providers. We require these third parties to comply precisely with its instructions and we require that they not use your personal information for their own business purposes.

Personal Information Disclosure

We do not share nonpublic personal information about our customers (present, former, or potential) with anyone, except as required by law, or as follows:

  • To any person whom you authorize such disclosure.
  • To computer services consultants and technicians or other security consultants, in order to ensure the confidentiality and security of customer & employee records.
  • To financial service providers or consultants to carry out requested services, and/or to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.
  • To independent auditors or consultants to carry out institutional risk control.
  • To government or regulatory agencies, including self-regulatory organizations and to comply with a legal summons, court order, subpoena or a similar legal process, audit, or investigation.
  • To swap data repositories.

How Personal Information is Protected

We limit access to information about you only to those employees who need to know that information as part of their job responsibilities. Additionally, we educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our Code of Conduct. We take appropriate disciplinary measures to enforce employee privacy responsibilities. We have developed precautions that comply with federal regulations to ensure the security and confidentiality of customer records and information, to guard against any anticipated threats or hazards to the security or integrity of such records, and to protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to our customers or our employees.

StrengthenU maintains strict information security procedures, including physical, electronic and procedural safeguards, to protect the confidentiality of your information.

Personal Information is Protected by

  • Restricting access to customer information to only those personnel for whom the information is necessary.
  • Entering into written confidentiality/non-disclosure agreements with third party service providers for certain disclosures.
  • Maintaining physical, electronic, and procedural safeguards that comply with the relevant laws and regulations; and
  • StrengthenU uses firewall barriers and digital certifications to maintain the security of your online session and information.
  • We do not collect any non-public personal information about visitors on our website unless information is provided to us voluntarily or derived from website navigation and usage of the StrengthenU website and online platforms.
  • We may collect and analyze information regarding usage of our website, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using cookies. StrengthenU uses cookies and similar technologies to track usage of the website and to address security issues. We may also use cookies to store your preferences relating to use of our website. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet, phablet, cell phone or other electronic device (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track traffic flows. Cookies record information about your preferences and allow us to tailor StrengthenU to your interests to enhance the experience. During the course or any visit to the Site, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things such as finding out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking for the cookie left there on the previous visit. Information supplied by cookies can help us to analyze the profile of our visitors so we can provide you with a better user experience.

Protecting the Privacy of All StrengthenU Users

  • During the use of StrengthenU services, you will not send or otherwise post unauthorized commercial communications (such as spam) on StrengthenU.
  • You will not collect users’ content or information, or otherwise access StrengthenU, using automated means (such as harvesting bots, robots, spiders, or scrapers) without our permission.
  • You will not upload viruses or other malicious code.
  • You will not solicit login information or access an account belonging to someone else.
  • You will not bully, intimidate, or harass any other User.
  • You will not post content that: is hateful, threatening, or pornographic; incites violence; or contains nudity or graphic or gratuitous violence.
  • You will not provide any false personal information on StrengthenU or create an account for anyone other than yourself without permission. You will not create more than one personal profile.
  • Privacy Enforcement
  • Personnel using StrengthenU’s information resources in opposition to this policy may be subject to limitations on the use of these resources, suspension of privileges (including internet access), as well as disciplinary and/or legal action, including termination of employment. Employees, contractors, consultants, interns, and all personnel affiliated via third parties sign the Privacy Policy agreement to comply and be governed by this policy. All Employees have background checks performed. All Therapists, as contractors, go through a rigorous vetting process that meets or exceeds national credentialing standards.

StrengthenU and Protecting Other People’s IP Rights

We respect other people’s rights and expect you to do the same. You will not post content or take any action on StrengthenU that infringes or violates someone else’s rights or otherwise violates the law. We can remove any content or information you post on StrengthenU if we believe that it violates this Privacy Policy or the Terms of Use on this Site. You will not use our copyrights or any confusingly similar marks, without our written permission. You will not share anyone’s identification documents or sensitive financial information on StrengthenU.

Portable Electronic Devices

The StrengthenU Platform is available on a variety of electronic devices. We provide our connection to mobile services for free, but please be aware that your carrier’s normal rates and fees, such as applicable data charges, may still apply. You provide all rights necessary to enable StrengthenU Users to sync (including through an application) their contact lists with any basic information and contact information that is visible to them on StrengthenU, as well as your name and profile picture.

California Consumer Privacy Act (CCPA) Use And Disclosure Of Personal Data

StrengthenU recognizes that California has articulated specific privacy rights of StrengthenU Users in that State. California Users should understand that StrengthenU does not sell User data to third parties. Further, StrengthenU is a medical records retention company. As such, almost all User data is kept in encrypted storage as a medical record, including all User created transcripts. State Law requires StrengthenU to retain such records for at least seven years. The CCPA does not generally apply to medical information governed by the California Confidentiality of Medical Information Act (CMIA) or protected health information collected by a covered entity or business associate governed by the privacy, security, and breach notification rules of the Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009.

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request, once a year, if StrengthenU has shared their personal information (non-medical record data only) with other companies for direct marketing purposes during the preceding calendar year. This is California’s “Shine-the-Light Law.”

California Right to Know: You may request access to the specific pieces of personal data we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal data we have collected about you, the sources of such collection, the categories of personal data we share for a business or commercial purpose, and the categories of third parties with whom we share your personal data. You may make these requests by contacting us on StrengthenU via the “contact us” link on the website. Please allow reasonable time for a response.

California Designated Agent. You may designate an agent to make a request on your behalf. That agent must have access to your account in order for us to verify the request.

California Non-Discrimination. StrengthenU will never discriminate against you, including by denying or providing a different level of service should you choose to exercise your rights under the CCPA.

Privacy in International Use and The GDPR

The StrengthenU Platform advises both its Client/Users and practicing Platform Providers to be aware of and respect and comply with the local laws of any international based Client. StrengthenU is cognizant and respects the formal promulgation of the existing European Union (EU) data privacy regulations. The General Data Protection Regulation 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It also addresses the export of personal data outside the EU and EEA and is commonly referred to as “GDPR.” StrengthenU has always respected our Client’s Privacy (see our Privacy Policy) and we were already a HIPAA certified platform following stringent data privacy rules.

The basic tenants of the promulgated GDPR regulations include, but are not limited to the following:
Disclosure when you sell, transfer or third-party marketing of User’s data: As outlined in this Terms of Use, StrengthenU does not sell or transfer Client data and any marketing efforts are focused solely on internal information updates to our registered Clients.

Access to collected data: At StrengthenU, you already have the ability to access your shared data (Your personal information, your emergency contact information and all your interactions with your Providers) and use it as you wish.

Clear Consent: At StrengthenU our Terms of Use are clear on what consent we seek with regards to your data and prior to your engagement with your Provider, you review and agree to a further “informed consent” process.

Security: At StrengthenU we have encrypted our data from day one and has always been stored all Private Health Information with full HIPAA compliance and in an anonymized form as required by the GDPR.

Notice/Audit: At StrengthenU, we will provide our Clients notice of any data breach.
Finally, dependent of your EU country or origin, the GDPR takes into account what was previously termed the right “to forget” or request deletion of your data once you cease using a particular application or site. This particular tenant of the GDPR may conflict with applicable medical records retention laws. In the United States, this requires at least seven years of retention, which is common around the world and is sometime up to ten years or more in certain countries. So, unlike some data platforms, StrengthenU cannot erase private health data directly upon a Client’s request, as it may be considered essential for other medical file retention purposes. Applicable individual country medical retention laws are generally considered an acceptable exception to the GDPR regulations regarding the right to deletion of certain data.

Privacy Disputes

You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Statement or StrengthenU exclusively in a state or federal court located in Iowa.
If anyone brings a claim against us related to your actions, content, or information on StrengthenU, you will indemnify and hold us harmless from and against all damages, losses, and expenses of any kind (including reasonable legal fees and costs) related to such claim.

Conclusion

We try to keep StrengthenU safe, but you use it at your own risk. We are providing StrengthenU “As Is” without any express or implied warranties. We do not guarantee that StrengthenU will be safe or secure. StrengthenU is not responsible for the actions, content, information, or data of third parties, and you release us, our directors, officers, employees, and agents from any claims and damages, known and unknown, arising out of or in any way connected with any claim you have against any such third parties.

We strive to create a global community with consistent standards for everyone, but we also strive to respect local laws. You consent to having your personal data transferred to and processed in the United States. If you are located in a country embargoed by the United States or are on the U.S. Treasury Department’s list of Specially Designated Nationals you will not engage in commercial activities on StrengthenU (such as advertising or payments). By content we mean anything you post on StrengthenU that would not be included in the definition of information. By data we mean content and information that third parties can retrieve from StrengthenU or provide to StrengthenU through Platform. By post we mean post on StrengthenU or otherwise make available to us (such as by using an application). By use we mean use, copy, publicly perform or display, distribute, modify, translate, and/or create derivative works.
StrengthenU openly volunteers its practices of collecting information, its targeting capabilities, and its use of cookies. If you have any questions pertaining to this privacy policy and its contents, please direct your correspondence to StrengthenU at the “contact us” link on the website.

Understand, that we treat your use of our platform with the utmost respect to your privacy. We keep all information not disclosed above private between the Therapist and the User, keeping only non-decimated “file” copies for reference in case of legal dispute or by court order as we are required to under Federal Laws for period up to seven years or by the applicable State Regulation. File retention protects both the User and the Therapists safety. StrengthenU is not responsible for data lost/exposed/used due to the nature of the Internet and digital environments, including illegal actions of hackers and criminals, technical malfunctions of servers and database etc. These are the accepted risks of our Users and users of the Internet in general. You are agreeing to this standard in using our site.
StrengthenU reserves the right to amend this Privacy Statement at any time without notice, and only the current Privacy Statement may be deemed effective. Regardless of later updates or changes to our privacy notice, we will never use the information you submit under our current privacy notice in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.

Last updated on February 26, 2021