Last updated 02/25/2023

PureMind Clinical (“PureMind”, “we” or “us”) are firmly committed to protecting your privacy. You should understand what we do with data relating to you which we collect when you visit our website, https://www.puremindclinical.com/ (the “Platform”) to carry out treatment, payment, or business operations and for other purposes that are permitted or required by law (“Services”) and how we use and disclose the information. We are committed to complying with all data protection laws as are applicable to us. ‍

By using our Platform or by otherwise giving us your personal information you are accepting the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Platform or give us any of your personal information. We reserve the right to make changes to this Privacy Policy at any time. Any changes will be posted in this Privacy Policy. We encourage you to regularly review this Privacy Policy to make sure you are aware of any changes and how your data may be used.

If you have any questions or comments about the Policy, please contact us by reaching out to us via email. This Policy is incorporated into and is subject to the Terms of Service. Your use of Platform and any personal information that you provide on the Platform remains subject to the terms of this Platform Privacy Policy and PureMind Clinical Terms of Service. Please click on any of the following questions to be directed to the relevant answer in the main body of this Policy.

HOW WE COLLECT YOUR PERSONAL INFORMATION

WHY WE NEED TO COLLECT YOUR PERSONAL INFORMATION

TO WHOM WE GIVE YOUR PERSONAL INFORMATION

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

HOW WE PROTECT YOUR PERSONAL INFORMATION

CHILDREN’S PRIVACY PROTECTION

CONTROLLING YOUR PERSONAL INFORMATION

LINKS AND THIRD PARTIES

CONTACT US

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect the following Personal Information relating to you:

• Account Information: You need to register to use our Platform. In the course of installing, accessing and using the Services, we must receive or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). The types of information we receive and collect from you will be Name, birthdate, health information, medical background.
• Device and Location Information: The Platform automatically collects certain technical information relating to the device you use to visit the Platform. Specifically, we use cookies and similar technologies to help us understand your activity on the Platform. A “cookies” is a small piece of data that a website can send to your browser, which may then be stored on your device. Data that we collect automatically includes your internet protocol (“IP”) address, location, your device’s identification information, and the actions taken on our Platform (e.g., links that you click) as well as other sites that you may visit.
  
• Payment Information: If you use the Service to make or receive payments, we will also collect certain financial information, such as credit card or other financial account information.
  
• Children Information: The Service is intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a person younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that PureMind has collected Personal Information from your child, please contact us at [email protected].
  
• Anonymous Information: We sometimes collect anonymous information from visits to the Platform. Anonymous information (or clickstream data) refers to information that does not and will not directly or indirectly reveal your identity, e.g., aggregated data relating to all of our Platform visitors. We may use this data to analyze trends and statistics and to help us provide you with a better experience using our Platform.

If you provide us with Personal Information of third parties (such as the details of your administrative assistant or your emergency contact), you agree to (a) notify each individual before sharing their Personal Information with us, (b) explain that their Personal Information will be processed in accordance with this Privacy Policy, and (c) obtain their consent, where appropriate.

• Social Networking Services. You may register for an account directly with our Platform, or through a social networking service (Facebook/Instagram, Google). If you register with a social networking service, later link your account to one or if you visit the site without logging into the SNS, we will collect certain information about you from that social networking service using website pixels, and what we collect depends on your privacy settings with that social networking service. You may register to join the Service directly via the Service or by logging into your account with a third-party social networking service (“SNS”) via our Service (e.g., Facebook, and other third-party services that let you sign in using your existing credentials with those services). If you choose to register via an SNS, or to later link your account with the Service to your account with an SNS, we will use the Personal Information you have provided to the SNS (such as your name, email address, gender and other information you make publicly available via the SNS) to create your account. Note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your account with the Service to your account with an SNS. Other than what we may share with the SNS as described below, the Personal Information an SNS has about you is obtained by the SNS independent of our Service, and PureMind is not responsible for it.

WHY WE NEED TO COLLECT YOUR PERSONAL INFORMATION

To the extent permitted by applicable law, we use your Personal Information for various purposes, such as to:

• provide you with the Services and information that you have requested.
• manage and maintain our relationship with you, including responding to an inquiry, question, or comment made by you and providing you with other customer support.
  
• communicate important notices to you, such as information about changes to this Platform Privacy Policy and Service updates.
  
• carry out analytics and market research and internal reporting to enable us to plan, develop and improve our Platform, our Services (For example, we may use your IP address to help diagnose problems with our server, to administer the Platform, to refine the Platform based on which features people use most often, to help identify Platform users (such as you) and gather general demographic information about Platform users.)
  
• create a profile about you to help us personalize our communications to you, including to ensure that you receive relevant marketing communications based on your actions on this particular Platform or your geographic location based on your IP address.
  
• prevent and detect unlawful behavior, and protect or enforce our legal rights, for example defending us in case of legal disputes.

TO WHOM WE GIVE YOUR PERSONAL INFORMATION

We will not sell your Personal Information for reasons other than those described in this Privacy Policy. However, we may need to disclose your Personal Information to third parties in the following instances:

• Service providers: We will disclose your Personal Information to companies that provide services to us, such as companies that assist us in operating our Platform and vendors that assist us with marketing campaigns. We shall also share your Personal Information to service providers like Google who help us with the Google Analytics, Jotform and Typeform for helping us with online form and surveys. The service providers are required to keep your Personal Information confidential and are not permitted to use your Personal Information for any other purpose than to carry out the services they are performing for us.
  
• Third parties to meet applicable legal requirements: We may need to disclose your Personal Information to a third party if it is necessary to comply with a legal obligation or the decision of the judicial authority, a public authority, or a government body, or if the disclosure is necessary for national security, law enforcement or other public interest.
  
• Business partners: We will disclose your Personal Information to our business partners if it is necessary for providing Services to you, such as your healthcare or other licensed medical providers, payment gateway, certain software and related services.
  
• Third parties in connection with a business sale: If we make a sale or transfer of assets, or are otherwise involved in a merger or business/asset transfer, we may transfer your Personal Information to one or more third parties as part of that transaction.
  
• Other third parties with your consent: We may also share your Personal Information with other third parties when you separately consent to such sharing.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

Your Personal Information will be retained only for so long as reasonably necessary for the purposes set out in this Platform Privacy Policy in accordance with applicable laws, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.  Your information may persist in copies made for backup and business continuity purposes for additional time. If you choose to provide us with Personal Information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.

HOW WE PROTECT YOUR PERSONAL INFORMATION

PureMind implements appropriate security measures designed to prevent unlawful or unauthorized processing of Personal Information and accidental loss of or damage to Personal Information. The data collected via our Platform is stored in a secure server with our ISP who will take periodic backups of such data.  

CHILDREN’S PRIVACY PROTECTION

The Platform are not intentionally targeted to, or intended for, children under the age of 18. We do not knowingly collect data relating to children.

CONTROLLING YOUR PERSONAL INFORMATION

Accessing of Personal data

1. If you would like request information about your personal data which we have collected, or inquire about the manner in which your personal data may have been used or disclosed by us within the past year, please contact us. In order to facilitate processing of your request, we may need to ask for further information relating to your request.

2. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days from the date of your request, we will inform you in writing. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable laws and regulations).

Updating or modifying your Personal Data

1. It is crucial that you provide us with accurate personal data. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, or out of date. You can update your personal data by accessing your account on the Website. If you are unable to update your personal data through your account, you can do so by contacting us via the homepage by filling out the questionnaire.

Withdrawal of consent and deletion of Personal Data

1. You may communicate the withdrawal of your consent to the continued use or disclosure of your personal data for any of the purposes mentioned in this Privacy Policy, or request the deletion of your personal data, by contacting us through the contact details provided on the Website.

2. Please note that if you communicate the withdrawal of your consent to our use or disclosure of your personal data as mentioned above, or request the deletion of your personal data, we may not be in a position to continue to provide our Services to you or perform on any contract we have with you, and we will not be liable in the event that we do not continue to provide our Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event. 

LINKS AND THIRD PARTIES

The Platform contains links to other websites, including sites controlled by third parties independent of us. PureMind is not responsible for the privacy practices or the contents of such websites that is not owned by PureMind. We encourage you to read the privacy notices of such websites before providing any Personal Information to them. We do not take responsibility for any other party’s site hyperlinked to PureMind website or in which any part of the PureMind website has been hyperlinked or for the opinions of third parties expressed on or through our Platform.

CONTACT US

Any questions, concerns, or complaints about our processing operations and our commitment to this Platform Privacy Policy should be addressed to PureMind’s Data Protection Officer at [email protected] In addition to contacting us, in certain countries you have the right to lodge a complaint with your local data protection authority if you so choose.)

               Annex for California Residents 

California Online Privacy Protection Act (CalOPPA) – “California Do Not Track Disclosures”

In accordance with the CalOPPA, we may collect Personal Information about your online activities when you use the Services. While we give our users many avenues to opt-out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals. California’s “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to refrain from gathering your Personal Information, please submit your request in writing to the contact details set out on page 1 above. 

California Consumer Privacy Act (CCPA) –The CCPA gives California consumers enhanced rights with respect to their Personal Information that is collected by businesses.  First, California consumers may opt-out of having their Personal Information sold to other persons or parties.  Second, California consumers have a right to know:

• What specific pieces of information a business has about the consumer;
• Categories of Personal Information it has collected about the consumer;
• Categories of sources from which the Personal Information is collected;
• Categories of Personal Information that the business sold or disclosed for a business purpose about the consumer;
• Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling Personal Information.

Third, California consumers can request that the Personal Information a business has collected about them be deleted from the business’s systems and records.

With your consent, PureMind may sell Personal Information to third parties. You can request to opt out of the sale of your Personal Information at any time by completing the questionnaire on our homepage or by sending as email at [email protected] -  We have fifteen (15) days after receipt to implement a request to opt out.

To make a “request to know” or request to delete your Personal Information, send us an e-mail at [email protected]. (Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.)

We will confirm receipt of your request to know or delete within fifteen (15) days along with a description of what steps we will take to verify and respond.  We must provide the requested information or delete your Personal Information within forty-five (45) days of receipt of your request but can use an additional forty-five (45) days, but we will let you know additional time is needed.

When contacting us, we may ask you to provide certain, limited Personal Information, such as your name, email address and/or username to verify your request and to match with our records and systems.  We will not retain this Personal Information or use it for any other purpose.  And we need to search our records and systems only for the preceding twelve (12) months. the following personal information a Site or submit your personal information to one 

HIPAA Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION (“PHI”) ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. 

We are required by Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) law to maintain the privacy of PHI to provide individuals with notice of our legal duties and privacy practices with respect to protected health information, and to notify affected individuals following a breach of unsecured protected health information. We must follow the privacy practices that are described in this Notice while it is in effect. This Notice takes effect 6/1/2021, and will remain in effect until we replace it. We reserve the right to change our privacy practices and the terms of this Notice at any time provided such changes are permitted by applicable law, and to make new Notice provisions effective for all protected health information that we maintain. When we make a significant change in our privacy practices, we will change this Notice and post the new Notice clearly and prominently at our practice location, and we will provide copies of the new Notice upon request. You may request a copy of our Notice at any time. For more information about our privacy practices, or for additional copies of this Notice, please contact us using the information listed at the end of this Notice.

HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU

We may use and disclose your health information for different purposes, including treatment, payment, and health care operations. For each of these categories, we have provided a description and an example. Some information, such as mental health records may be entitled to special confidentiality protections under applicable state or federal law. We will abide by these special protections as they pertain to applicable cases involving these types of records.

Treatment. We may use and disclose your health information to provide, coordinate, or manage your health care and any related services for your treatment. For example, we may disclose your health information to a specialist providing treatment to you. We would like to highlight that all the medical records shared by you shall further shared only with the licensed clinicians.

Payment. We may use and disclose your health information to obtain compensation for the treatment and services you receive from us or another entity involved with your care. Payment activities include billing, collections, claims management, and determinations of eligibility and coverage to obtain payment from you, an insurance company, or another third party. 

Healthcare Operations. We may use and disclose your health information in connection with our healthcare operations. For example, healthcare operations include quality assessment and improvement activities, conducting training programs, and licensing activities.

Required by Law. We may use or disclose your health information when we are required to do so by law.

Law Enforcement. We may disclose your PHI for law enforcement purposes as permitted by HIPAA, as required by law, or in response to a subpoena or court order

Judicial and Administrative Proceedings. If you are involved in a lawsuit or a dispute, we may disclose your PHI in response to a court or administrative order. We may also disclose health information about you in response to a subpoena, discovery request, or other lawful process instituted by someone else involved in the dispute, but only if efforts have been made, either by the requesting party or us, to tell you about the request or to obtain an order protecting the information requested

Worker’s Compensation. We may disclose your PHI to the extent authorized by and to the extent necessary to comply with laws relating to worker’s compensation or other similar programs established by law

National Security. We may disclose to military authorities the health information of armed forces personnel under certain circumstances. We may disclose to authorized federal officials, health information required for lawful intelligence, counter intelligence, and other national security activities. We may disclose to correctional institution or law enforcement official having lawful custody the protected health information of an inmate or patient.

Health Oversight Activities. We may disclose your PHI to an oversight agency for activities authorized by law. These oversight activities include audits, investigations, inspections, and credentialing, as necessary for licensure and for the government to monitor the health care system, government programs, and compliance with civil rights laws

Coroners, Medical Examiners. We may release your PHI to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. 

Other Uses and Disclosures of PHI 

Your authorization is required, with a few exceptions, for disclosure of psychotherapy notes, use or disclosure of PHI for marketing, and for the sale of PHI. We will also obtain your written authorization before using or disclosing your PHI for purposes other than those provided for in this Notice (or as otherwise permitted or required by law). You may revoke an authorization in writing at any time. Upon receipt of the written revocation, we will stop using or disclosing your PHI, except to the extent that we have already taken action in reliance on the authorization.

1. Right to Access PHI

You have the right to look at or get copies of your health information, with limited exceptions. You must request in writing. You may obtain a form to request access by using the contact information listed at the end of this Notice. You may also request access by sending us a letter to the address at the end of this Notice. 

2. Disclosure Accounting. 

With the exception of certain disclosures, you have the right to receive an accounting of disclosures of your health information in accordance with applicable laws and regulations

3. Right to Request a Restriction

You have the right to request additional restrictions on our use or disclosure of your PHI by submitting a written request to us. Your written request must include (1) what information you want to limit, (2) whether you want to limit our use, disclosure or both, and (3) to whom you want the limits to apply. We are not required to agree to your request except in the case where the disclosure is to a health plan for purposes of carrying out payment or health care operations, and the information pertains solely to a health care item or service for which you, or a person on your behalf (other than the health plan), has paid our practice in full.

4. Amendment to PHI

You have the right to request that we amend your health information. Your request must be in writing, and it must explain why the information should be amended. We may deny your request under certain circumstances. If we agree to your request, we will amend your record(s) and notify you of such. If we deny your request for an amendment, we will provide you with a written explanation of why we denied it and explain your rights.

5. Alternative Communication. You have the right to request that we communicate with you about your health information by alternative means or at alternative locations. You must make your request in writing. Your request must specify the alternative means or location, and provide a satisfactory explanation of how payments will be handled under the alternative means or location you request. We will accommodate all reasonable requests. However, if we are unable to contact you using the ways or locations you have requested, we may contact you using the information we have.
   

6. Right to Notification of a Breach. You will receive notifications of breaches of your unsecured protected health information as required by law.

You have the right to obtain a paper copy of this Notice, upon request, even if you have previously requested its receipt electronically by e-mail.

If you are concerned that we may have violated your privacy rights, or if you disagree with a decision, we made about access to your health information or in response to a request you made to amend or restrict the use or disclosure of your health information or to have us communicate with you by alternative means or at alternative locations, you may complain to us using the contact information listed at the end of this Notice.

Our address: 6430 N. Silversmith Pl., Tucson, AZ 85750

Telephone:+1.520.977.0715

Email: [email protected]