This privacy policy (this “Privacy Policy” or “Policy”) governs the manner in which Ask Rose Inc. (“Rose,” “ we,” “our,” “us” and similar terms) collects, uses, maintains, and discloses information collected from users who register for and/or use services (the “Services”) available on or through our user dashboard accessed through our website www.rosehealth.com (the “Site”) and/or mobile application (the “App”).
If you are a California resident, please refer to our California Privacy Notice here [insert link].
THE ACTIVITIES, TOOLS, AND INFORMATION FOUND IN THE SITE AND APP IN NO WAY SUBSTITUTE FOR CARE PROVIDED BY A TRAINED MENTAL HEALTH PROFESSIONAL. PLEASE SEEK HELP FROM A LICENSED MENTAL HEALTH PROFESSIONAL IF YOU BELIEVE THAT YOU MAY BE SUFFERING FROM DEPRESSION OR ANOTHER MENTAL HEALTH DISORDER. IF YOU ARE UNSURE WHETHER A SERVICE IS RIGHT FOR YOU, OR ABOUT HOW TO BEST IMPLEMENT ITS CONTENT, BE SURE TO CONSULT A LICENSED MENTAL HEALTH PROFESSIONAL ABOUT YOUR CONCERNS.
In this Policy, “user” or “you” means any individual using the Site and/or App. This Policy forms part of and is incorporated into our Terms of Use published at www.rosehealth.com/terms.html (the “Terms of Use”).
BY ACCESSING OR USING THE SITE AND/OR APP, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS OF USE. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SITE AND APP.
2. What Information Do We Collect?
a) Personal Information: We may collect certain information that relates to and/or identifies you in connection with the use of the Site and App, including: (a) when you register to use the Site and/or App, we may collect the personal information such as your name, email address, therapist contact information, the fact that you are using that therapist, password, birthday, gender, profile (including profile image) and other information detailed therein (“Registration Information”); (b) if you provide your email or communicate with us by email but do not otherwise register to use the Site or App, we will collect your email address; (c) information a patient may provide in the App, including the patient’s emotional check-ins, surveys the patient complete, and any journals a patient may create (“Mood Information”); (d) text and images uploaded via the chat functionality, and (e) usage information on which activities a patient may have completed in the App and how long you have spent on various pages (“App Information”). All of this information is “Personal Information.” If you contact Rose or your mental health professional through the App and disclose additional personal information, we may also collect and store that communication.
b) User Data: “User Data” means all data other than Personal Information that users provide us regarding or related to themselves or their use of or access to the Site or App.
c) Web Tracking Information and Cookies: The Site and App may use web tracking technologies such as cookies, pixel tags and beacons in order to operate the Site and App efficiently and to collect data related to usage of the Site and App. Such collected data (“Web Tracking Information”) may include the address of other websites you have visited, the type of browser you are using, your Internet Protocol (IP) address, device model, device ID and other unique device identifiers, what webpages in you visit and what links you clicked on, and whether you opened email communications we send to you. We may also use web tracking technologies that are placed in web pages on the Site and App or in email communications to collect information about actions that users take when they interact with the Site and App or such email communications. We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to you. We use this information not to identify individual users, but to analyze trends, administer the Site and App, track users’ movements around the Site and App, and gather demographic information about our user base as a whole which provides us with the ability to determine aggregate information about our user base and usage patterns.
3. How Do We Use the Information We Collect?
a) Information and User Data: Generally, we will use and store your Personal Information (2a.a-a.e) and User Data (2b) for the purpose of delivering the Site and App and to analyze and enhance the operation of our Services. We may also use your Personal Information and User Data for the internal operational and administrative purposes of the Site and App, including the development of enhanced features and updates to the Services and to develop and implement algorithms and machine learning tools. We store Personal Information and User Data using Amazon Web Services (“AWS”). For more information, see AWS’s Privacy Policy.
b) Registration Information: Specifically, we use Registration Information to create an account for you on the Site and/or App and to contact you about our Services. For patients using the App, we may also share Registration Information with your mental health professionals if you provide their information. We store Registration Information and do not share it with third parties except those service providers that make it possible to provide the Site and/or App.
c) Mood Information: We use your Mood Information to provide, maintain, and improve the App. We analyze your Mood Information using artificial intelligence and other tools to assess your mental state; we share the Mood Information with your mental health professionals if you provide their information and your consent. We do not share Mood Information with anyone else without your explicit consent.
d) Web Tracking Information: We use Web Tracking Information to administer the Site and App and to understand how well the Site and App Are working, to store your user preferences, and to develop statistical information on usage of the Site, App and Services. This allows us to determine which features visitors like best to help us improve the Site, App and Services, to personalize your user experience, and to measure overall effectiveness.
e) App Information: We use App Information to improve our services and provide you with a better experience in the App.
f) Aggregate and De-Identified Information: We will also create statistical, aggregated and/or de-identified data from the above Personal Information, User Data, and Web Tracking Information for analytical and commercial purposes. Aggregated and/or de-identified data is derived from Personal Information and User Data but in its aggregated and/or de-identified form, it does not duplicate or reveal any User Data or relate to or identify any individual. This data is used to understand our customer base and to develop, improve and market our services and technology.
g) Legal Exception: Notwithstanding the above, we may store and use Personal Information and User Data to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy and the Terms of Use) with you, if our business is acquired or sold, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.
h) Promotional Communications: If you register and provide your email address along with the applicable consent, we may send you administrative and promotional emails.
i) Account Closure: If any of your account information appears to be incorrect, please contact us and let us know. If you delete or close your account, and subject to applicable state or federal laws mandating data retention, we will delete or anonymize any Personal Information associated with your account, but other information you submitted that is not associated with you personally may not be deleted.
4. What Information Do We Disclose to Third Parties?
a) Personal Information: We will not disclose your Personal Information to any third parties except as follows:
i. To third-party contractors engaged to provide services on our behalf (“Contractors”), such as analyzing data and usage of the Services, hosting and operating the Services, providing marketing or support and maintenance services for the Services, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us. We currently only use AWS and The MathWorks, Inc., doing business as MATLAB, as Contractors that process your Personal Information.
ii. If you have a mental health professional and want to share your Personal Information with him or her for the purposes of improving your therapy experience or mental health, we will share your Personal Information with your mental health professional and that professionals’ organization with your consent, including your Mood Information, App Information, and Registration Information.
iii. We will share your Personal Information when we otherwise have your consent to do so.
b) Web Tracking Information: We may disclose Web Tracking Information to Contractors, in order to analyze the performance of the Site and App and the behavior of users, and to operate and improve the Services.
c) Aggregate and De-Identified Information: We may disclose aggregated and/or de-identified data that does not contain Personal Information, including at times User Data, to any third parties, such as Contractors, potential customers, business partners, marketers, and funding sources, in order to describe our business and operations.
d) Network Operators: Use of the Services may involve use of the services of third-party telecommunications carriers. Such carriers are not our Contractors, and any information that a carrier collects in connection with your use of the Services is not Personal Information and is not subject to this Privacy Policy. We are not responsible for the acts or omissions of telecommunications carriers.
e) Disclosures in Connection with our Business Operations: If Rose is involved in a merger, acquisition, or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different privacy policy.
f) Disclosures Required by Law: Under certain circumstances, Rose may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
g) Additional Disclosures: Finally, we may disclose your Personal Information in the good faith belief that such action is necessary to:
i. comply with a legal obligation;
ii. protect and defend the rights or property of Rose;
iii. prevent or investigate possible wrongdoing in connection with the Services;
iv. protect the personal safety of users of the Services or the public; or
v. protect against legal liability.
5. Privacy Settings and Personal Rights Requests
If provided for by applicable law, you may exercise your right to deletion, right to know, right to portability, right to opt out, or right of access by contacting us at Rose.Help@precisebh.com or following the prompts in the App.
If required by applicable law, we will respond to any such request, and any appropriate request to access, correct, update or delete your Personal Information within the time period specified by such applicable law. We will promptly fulfill requests to delete Personal Information unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).
Your removal from the mailing list or database will not remove data you have submitted to us or records of past use of the Site and/or App, nor delete information stored in our data backups and archives. Such data will be maintained and/or deleted in the ordinary course of Rose’s business.
If you wish to opt out of promotional emails (but would not like to have your information permanently removed from our database), you may do so by following the “unsubscribe” instructions in the email, or by modifying your account settings. All users receive administrative emails, and so you cannot opt out of them while you remain registered in the Site and/or App.
6. General
a) Security: We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this Policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures. We take reasonable steps to protect user privacy consistent with the guidelines set forth in this Policy and with applicable U.S. state and federal laws. WE TAKE THESE PRECAUTIONS IN AN EFFORT TO PROTECT YOUR INFORMATION AGAINST SECURITY BREACHES. HOWEVER, THIS IS NOT A GUARANTEE THAT SUCH INFORMATION MAY NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF SUCH FIREWALLS AND SECURE SERVER SOFTWARE. BY USING THE SITE AND/OR APP AND SERVICES, YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND AGREE TO ASSUME THESE RISKS.
b) Links: The Site and App may contain links to other websites. Rose is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave the Site and/or App and review the privacy statements of each third-party website. This Privacy Policy applies solely to information collected by the Site and App. We encourage our users to read the privacy policies of these other websites before proceeding to use them.
c) Amendments: Rose may modify or amend this Policy from time to time. If we make any material changes, as determined by Rose, in the way in which Personal Information is collected, used or transferred, we will notify you of these changes either by email, by changing the “Last Updated” date above, or by notification in a particular Service itself. Notwithstanding any modifications we may make, any Personal Information collected by Rose from you will be treated in accordance with the privacy policy in effect at the time such information was collected, unless we obtain your consent otherwise.
d) Minors: Rose does not knowingly collect or maintain personally identifiable information from persons under 18 years of age, and no part of the Service is directed at persons under 18. If you are under 18 years of age, then please do not use the Service. If Rose learns that personally identifiable information of persons less than 18 years of age has been collected, then Rose will take the appropriate steps to delete this information. To request the deletion of any such information, please contact us at Rose.Help@precisebh.com.
e) Users from Outside the United States: Rose and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access the Site and/or App, you consent to the use and disclosure of information in accordance with this Privacy Policy and subject to such laws.
f) Retention. We will retain your Personal Information for as long as necessary to provide you with the services you request through the Site and/or App. After several years of inactivity, we may delete or anonymize your Personal Information.
Please contact us with any questions at: Rose.Help@precisebh.com, or at
Ask Rose Inc.
Attention: Privacy Policy
1616 17th St, Suite 564
Denver, CO, 80202