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Parallel Learning, Inc. Privacy Policy

Effective Date: August 30, 2021

This Privacy Policy (“Privacy Policy”) describes the data handling practices of Parallel Learning, Inc., a Delaware corporation, and Parallel Learning Behavioral Health, P.C., a Connecticut professional corporation, and their respective affiliates (collectively, “Parallel,” “we,” “our,” or “us”), including when you visit any Parallel website or mobile device that links to this Privacy Policy and those that host the Parallel platform or otherwise communicate with us or use our services, including services provided or hosted via third-party platforms (together referred to as our “Services”).

Please read this Privacy Policy carefully before using our Services and providing your personal information to us.

IF YOU ARE EXPERIENCING A MEDICAL EMERGENCY, CALL 9-1-1 IMMEDIATELY.

1. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
Personal information is information that identifies, relates to, or could reasonably be linked with you or your household.

Directly from You. When you use our Services, we collect the following categories of personal information directly from you:

Identifiers and contact information, such as your name, address, telephone number, email address, account log-in credentials (if you create an account), and your IP address. We generally use this information to provide you with our Services, respond to your communications with us, for identity verification, and to help manage your account, if you create an account with us.

Transactional information, such as your billing information, payment card information, and identity verification information. Our third-party payment processor collects this information on our behalf for purposes of processing your payments in connection with your use of the Services.

Health-related information, such as your behavioral health conditions, treatment options, provider referrals, prescriptions (if applicable), and lab results, or other related health information, such as your physical and emotional characteristics. We generally use this information to provide you with our Services, including to facilitate your interaction and the healthcare related services provided by behavioral health care providers.

Commercial information, such as information about your purchases or other transactions with us. We generally use this information to provide you with our Services and to keep records of the products and services you have purchased from us.

Certain protected characteristics, such as demographic information like your gender and age. We generally use this information to help provide our Services to you.

Professional and employment-related information, such as information you provide to us in a job application, if you apply for a position at Parallel. We use information for purposes of evaluating your candidacy for the position you applied for.

• Any other personal information you choose to directly provide to us, such as user-generated content you post on public forums on our Services.

Automatically Through Tracking Technologies. We may also collect the following categories of personal information automatically when you use our Services:

Internet and other electronic network activity information, such as your IP address, browser type, browser language, operating system, the location from which you access our Services, device IDs, referring and exit pages and URLS, platform type, the number of clicks, files you download, domain names, landing pages, pages your viewed, the amount of time spent on particular pages, the terms you used to conduct searches on our Platform, the date and time you used our Services, error logs and other similar information. We collect this information generally for our own business analytics and marketing purposes as well as to better customize our content and Services to your preferences. You can learn more about how we use tracking technologies in Section 3 entitled “Cookies and Other Tracking Technologies” below.

From Third Parties Partners.  We work closely with third parties, including, for example, psychologists and other medical professionals with whom we partner to provide you with the Services and to help facilitate their provision of their healthcare-related services. These third parties may provide us with your personal information.

From Social Media and Other Content Platforms. When you “like” or “follow” us on Facebook, Instagram, Twitter, or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.

In addition to how we use your personal information as described above in this section, we may also use your personal information for the following purposes:

• Carry out, improve, and manage the Services and, as applicable, facilitate the provision of health care services to you by physicians or other health care providers and ensure that the physicians or health care providers have the services and support necessary for health care operations.
• Engage in internal research to understand the effectiveness of our Services, improve our Services, and better understand our user base. If we publish or provide the results of this research to others, such research will be presented in a de-identified and aggregate form such that individual users cannot be identified.
• Communicate with you about the Services, your use of the Services, or your inquiries related to the Services and send you communications on behalf of psychologists or other health care providers utilizing the Services to meet your needs.
• Communicate with you by email, postal mail, or phone about surveys, promotions, special events or our products and Services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses and those of our third-party partners.
• Provide you with technical support and customer service.
• Verify your identity and administer your account, including processing your payments and fulfilling your orders.
• Take steps designed to ensure that content from our Services is presented in the most effective manner for you and for your computer or device, allow you to participate in interactive features of our Services (when you choose to do so), and as part of our efforts to keep our Services safe and secure.
• Measure or understand the effectiveness of advertising and content we serve to you and others, and to deliver and customize relevant advertising and content to you.• Help us better understand your interests and needs, such as by engaging in analysis and research regarding use of the Services.
• Comply in good faith with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

Aggregate/De-Identified Data.  We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you, your household, or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

2. HOW WE SHARE AND DISCLOSE YOUR PERSONAL INFORMATION
We may share your personal information for our own business purposes in the following ways:

Service Providers. We provide access to or share your personal information with select third parties who use the information to perform services on our behalf (“Service Providers”). They provide a variety of services to us, including for example, billing, sales, marketing, advertising, analytics, research, customer service, shipping and fulfillment, data storage, IT and security, fraud prevention, payment processing, and auditing and legal services. These entities may also include health care organizations, pharmacies, if applicable, and other third parties we use to support our business or in connection with the administration and support of the Services. Our policy is to require Service Providers to only use your personal information for purposes of providing their services to us.

Affiliates and Subsidiaries. We may share information we collect within any Parallel member or group (i.e., our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries) to deliver products and services to you, ensure a consistent level of service across our products and services, and enhance our products, services, and your customer experience.

Health Care Providers. We may share your personal information with health care providers: (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment or health care operations purposes, including pharmacy services (if applicable), upon your request.

Other Third Parties. We may share your personal information with third-party companies or individuals outside of Parallel (a “Third Party”). For example:

o Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). For example, if you submit a product review on our Platform, we may display your review (along with the name provided, if any) on other Parallel websites and on third-party websites. Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.

o From time to time, we may be required to provide personal information to a Third Party in response to a court order, subpoena, government investigation, or as otherwise required by law or legal process.

o We may share your personal information with Third Parties, such as law enforcement agencies, other government agencies, or health authorities (i) when we, in good faith, believe you or others are acting unlawfully, (ii) when we believe it is necessary or appropriate to satisfy any law, regulation or other governmental request, (iii) to operate our business and Services properly, (iv) to protect or defend our rights or the rights or well-being of our users, even without a subpoena, warrant or court order, or (v) we believe disclosure is necessary to protect the health and safety of our personnel, clients, guests, and the general public.

Business Transfers. We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (a "Reorganization Event"), transfer or assign your personal information to parties involved in the Reorganization Event. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.

With Your Consent. We may also disclose your personal information in other ways you direct us to and when we have your consent.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES
We may use “cookies” and other tracking technologies to keep and sometimes track, information about you when you use our Platform. Cookies are small data files that are sent to your browser or related software from a web server and stored on your computer’s hard drive. Cookies track where you travel on the Platform and what you look at. Most web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. We may use cookies and tracking technologies in the following ways.

Online Analytics. We may use third-party web analytics services, such as those of Google Analytics (including Google Signals, Google User-ID, and other Google Analytics features) and MixPanel on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; try to locate the same unique users across multiple browsers or devices to better tailor services and features; and provide certain features to you. To learn more about Google Analytics, you can visit “How Google uses data when you use our partners’ sites or apps” (located here). If you have a Google account with personalized advertising enabled, through Google Signals, Google will also be able to gather for us analytics and engagement information from across the various devices you use to access the Services. To prevent Google from using your information for analytics (including cross-device tracking for personalization purposes), you may install the Google Analytics Opt-out Browser Add-on by clicking here. And to opt out of Google Signals, please open your “Settings” app, locate and tap “Google,” select “Ads,” and turn ON “Opt out of Ads Personalization.” You may also be able to disable cross-device tracking through your Android or Apple device-based settings.

Online Advertising. The Services may integrate third-party advertising technologies (e.g., ad networks and ad servers such as Facebook, Google Ad Words, Criteo and others) that use cookies and other technologies to deliver relevant content and advertising for Parallel products on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your searches, demographic data, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the services by non-affiliated third party advertising network services. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. If you are interested in more information about Criteo’s privacy practices or opting-out of Criteo’s advertising services, you may view their Privacy Policy. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt-out choices above, you will still see advertising when you use the Services, but it may not be tailored to you based on your online behavior over time.

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.

4. YOUR MARKETING CHOICES
You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational or administrative emails, such as those reflecting our relationship or transactions with you.

5. HOW WE SAFEGUARD YOUR PERSONAL INFORMATION

Parallel takes a variety of reasonable technical and organizational security measures designed to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet, and that any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password that enables you to access the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user of the Services.

6. RETENTION OF YOUR PERSONAL INFORMATION

We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

7. THIRD PARTIES
Our Services may contain references or links to third-party websites and services. Except as described above regarding Service Providers, we do not control what information third parties track or collect. Any access to and use of such third-party websites and services is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.

8. INFORMATION FOR VISITORS OUTSIDE OF THE UNITED STATES
If you use our Services or provide us your personal information from outside the United States, your information will be transferred to, stored and processed in the United States and other countries where Parallel or its vendors operate in accordance with this Privacy Policy and applicable laws. Please note that data protection and consumer protection laws of the United States and such other countries may differ from the data protection or consumer protection laws in your country. By using our Services or providing us with your personal information, you understand that your personal information will be collected from and processed in the United States and other countries where Parallel or its vendors operate, and acknowledge that your information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions.

9. INFORMATION ABOUT CHILDREN

The Service does not intend to collect personal information directly from children without first obtaining verifiable parental consent.  If a child is under the age of 13, the child may use the Service only with the consent of or under the supervision of the parent or legal guardian. Consistent with the principles underlying the Children’s Online Privacy Protection Act (“COPPA”), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Service and subsequently we will delete that information. If you believe we might have collected any information from or about a child under age 13 without parental consent, please contact us at legal@parallellearning.com and indicate “Under 13” in the Subject field.

10. FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT

The Family Educational Rights and Privacy Act (“FERPA”) is a federal law that protects student education records and the student personally identifiable information (“FERPA PII”) they contain from unauthorized disclosure.  FERPA applies to educational institutions that receive federal funding.  Education service providers, although not directly regulated by FERPA, become subject to certain provisions when they receive student educational records or FERPA PII from a covered educational institution. In the event Parallel becomes or is subject to certain provisions under FERPA because it receives student educational records or FERPA PII from a covered educational institution,  Parallel will comply with FERPA and to the extent any provisions in this Privacy Policy contradict or violate FERPA, the terms are considered modified to the extent necessary to comply with FERPA.  

11. CONTACT US

If you have any questions about this Privacy Policy or Parallel’s privacy practices, please contact us at: legal@parallellearning.com

12. CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, and we suggest you review it periodically. The date this Privacy Policy was last revised is identified at the top of the document. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. If we make a material change to the Privacy Policy, we will endeavor to provide you with appropriate notice in accordance with legal requirements. Your continued use of our Services after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes to this Privacy Policy.