DIRECT HEALTHCARE PLLC – Privacy Policy

Introduction

Welcome to DIRECT HEALTHCARE PLLC. We understand that privacy policies can be

overwhelming. That’s why we’ve created this document to be as straightforward and

accessible as possible. If you have any questions while reading through our policy, please

don’t hesitate to reach out to us at toby@direct.healthcare.

In this document, “data” refers to personal information that is linked to an individual or

household, such as names, phone numbers, device IDs, and health-related information. By

using our platform, you agree to this Privacy Policy and understand that we may share certain

information with service providers as necessary.

Document Updates

We may periodically update this Privacy Policy. Significant changes will be notified through

our website or during your next visit to our platform. We encourage you to review this

document regularly to stay informed about how we protect your information.

Navigating This Document

This policy is organized into specific sections for your convenience:

1. Data Collection and Processing

2. Data Sharing

3. Data Retention, Erasure, and Exporting

4. Security Measures

5. Use of Cookies and Web Beacons

6. Additional Information for Arizona Residents

SECTION 1: Data Collection and Processing

Do we collect, store, or process your data? Yes, DIRECT HEALTHCARE PLLC collects and

processes information essential for providing and improving our healthcare services. This may

include sending you informational messages or promotional offers, which you can opt out of

at any time. Here’s a detailed breakdown:

• Visitor Data: When you use our website or platform, we collect information such as

the pages you visit, the time spent on our platform, device and browser information,

and IP address. If you consent, this information may be shared with third parties for

advertising purposes.

• Onboarding Data: Information collected from initial assessments or questionnaires

helps us tailor our services to your needs.• Account Data: Includes details you provide when creating an account, such as

demographic information and contact details.

• User ID: Each user is assigned a unique ID to enhance platform functionality and

service personalization.

• Transaction Data: We record details about your transactions and interactions with

our platform to improve service delivery and user experience.

• Member Engagement Data: Includes logging and activity data within our platform,

except for private therapy details.

• Therapy Data: This encompasses the health and treatment information shared with

your healthcare provider to facilitate your care.

How long do we retain your data and how can you request data erasure? Your data is

retained as necessary for the purpose it was collected and in compliance with legal and

regulatory standards. To request data erasure, please contact us at +14806145808.

SECTION 2: Data Sharing

What are the purposes for sharing my data? At DIRECT HEALTHCARE PLLC, we respect your

privacy while ensuring your data is used appropriately:

1. Legal Compliance: We may share your data to comply with legal obligations, such as

responding to court orders or subpoenas. We adhere to the confidentiality standards

of the healthcare profession, prioritizing your privacy.

2. Internal Use: Occasionally, specific employees within DIRECT HEALTHCARE PLLC

might access your data to provide support services, under strict confidentiality

obligations.

3. Service Providers: We collaborate with external service providers to enhance our

healthcare services:

• Data Hosting: Like AWS for secure data storage and management.

• Technology Solutions: Integration of tools to enhance platform functionality,

including live session technologies.

• Customer Support: Utilizing secure systems for efficient patient support and

communication.

• Payment Processing: Secure processing of payments through services like

Stripe, adhering to financial data protection standards.

• Analytics and Reporting: Employing tools to analyze service usage and

improve patient experiences.4. Therapist Collaboration: Sharing relevant data with healthcare professionals for

enhanced patient care, always maintaining confidentiality.

5. Organizational Partnerships: If you receive services through an employer or an EAP,

anonymized group data may be shared, respecting individual privacy.

6. Business Transitions: In events like mergers or acquisitions, patient data may be part

of the transferred assets under confidentiality agreements.

7. Public Information: Any data you publicly share on our platform could be accessible

to others. Exercise caution when disclosing personal information.

8. Advertising and Analytics: With your consent, we may share anonymized data for

advertising, helping us reach individuals seeking healthcare services without

compromising personal therapy details.

How do we use your data to comply with the law? We cooperate with legal and

governmental requests, adhering to the standards of the healthcare industry. This includes

sharing data when legally required while upholding professional confidentiality. Your therapist

might disclose certain information under legal obligations or professional duties, particularly

in situations concerning public safety or court orders.

Do we sell your data? DIRECT HEALTHCARE PLLC does not sell your personal data. Our

commitment is to your healthcare, not to monetizing your information.

Are we using your data for advertising? Our advertising efforts aim to reach individuals who

may benefit from our services. If you opt-in, we utilize non-sensitive, anonymized data for

targeted advertising, ensuring no personal healthcare information is disclosed.

Contact Information: For any queries regarding our data sharing practices, please contact us

at:

DIRECT HEALTHCARE PLLC

10117 N. 92nd Street – Suite #101

Scottsdale, Arizona, 85258

Phone: +14806145808

Email: toby@direct.healthcare

SECTION 3: Data Retention, Erasure, and Exporting

How long do we retain your data and how can you request data erasure?

DIRECT HEALTHCARE PLLC is dedicated to retaining your personal information only as long as

necessary to provide you with high-quality healthcare services, and as required by applicable

legal standards.

Data Retention Policy:

• If you have not started therapy: Your data is kept for three years after your last

interaction with us, after which it is securely deleted.• If you have started therapy: We retain your data for ten years following your last

treatment session, to comply with healthcare regulations and to support any

continued care needs.

• Request for data erasure: If you have not started therapy and request data erasure,

your information is removed within 24 hours. If you have received therapy, your clinical

health records and related communications may be retained for ten years for

compliance reasons. Other personal identifiable information is erased within 24 hours

of your request.

Requesting Data Erasure and Access:

If you wish to have your personal data erased or wish to access the data we hold about you,

please contact us directly:

• Phone: +14806145808

• Email: toby@direct.healthcare

We will process your requests in accordance with our privacy obligations. Please note, to

protect your privacy and security, we will take steps to verify your identity before processing

any data erasure request or granting access to personal information.

Legal Limitations:

In certain situations, legal and regulatory requirements may necessitate retaining specific

data, even if a deletion request has been made. This includes but is not limited to:

• Information required to be maintained by healthcare laws.

• Data involved in legal holds or ongoing legal proceedings.

• Documentation necessary for compliance with state and federal regulations.

Requesting a Copy of Your Data:

To request a copy of the personal information we hold about you, contact us using the details

provided above. You will be provided with a summary that includes information such as

contact details, medical records, and treatment history, subject to our verification process.

Exemptions:

Please note that requests for erasure may be denied if retaining the information is necessary

for us or our service providers to:

• Complete the transaction for which the personal information was collected, fulfill the

terms of a written warranty or product recall conducted in accordance with federal

law, provide a good or service requested by you, or reasonably anticipated within the

context of our ongoing business relationship with you, or otherwise perform a contract

between you and us.• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal

activity; or prosecute those responsible for such activities.

• Comply with a legal obligation.

• Make other internal and lawful uses of the information that are compatible with the

context in which you provided it.

Should your request for data erasure be denied, we will inform you of the reasons for this

decision.

Contact Information for Data Requests:

For any further questions or to initiate a data request, please contact us at:

DIRECT HEALTHCARE PLLC

10117 N. 92nd Street – Suite #101

Scottsdale, Arizona, 85258

Phone: +14806145808

Email: toby@direct.healthcare

SECTION 4: Security and Anonymity

How do we keep your data secure?

At DIRECT HEALTHCARE PLLC, we prioritize the security of your personal and health

information. We implement industry-standard best practices and cutting-edge technologies

to safeguard your data against unauthorized access and disclosure. Our commitment to your

security includes:

• Encryption: We use strong encryption methods for all data transmissions, ensuring

that all communications between you and your healthcare provider are secured.

• Secure Infrastructure: Our servers and IT infrastructure adhere to high security

standards, ensuring that your data is protected at all times.

• Best Practices for Browsing Encryption: We follow modern security practices for

web browsing and data encryption to keep your information safe.

• Data Protection: Our databases are designed with security in mind, ensuring that

your information remains protected even in the unlikely event of a security breach.

• Continuous Monitoring: We have robust systems and procedures for monitoring and

alerting, supported by a dedicated security team, ensuring round-the-clock

protection.

Protecting Yourself Online:• Phishing Awareness: Be cautious of unsolicited communications asking for sensitive

information. DIRECT HEALTHCARE PLLC will never ask for your login or credit card

details via unsecured methods.

• External Links: Be aware that links on our platform may lead to external sites with

their own privacy practices, over which we have no control.

Anonymity in Healthcare Services:

While total anonymity online is challenging, we strive to limit the personal information

required from you. You will not be asked for detailed personal identifiers unless necessary for

your care or for emergency situations.

Visibility of Your Healthcare Interactions:

Only you and your healthcare provider can view your personal health interactions and

communications. Any review by additional healthcare personnel, such as for quality

assurance purposes, is done with your consent and in compliance with professional

standards.

Data from Children:

DIRECT HEALTHCARE PLLC does not knowingly collect information from children under the

age of thirteen. If we discover that we have inadvertently collected such information, we will

take immediate steps to delete it.

Contact Information for Security Concerns:

If you have any questions about the security of your data, or if you believe your privacy has

been compromised, please contact us at:

DIRECT HEALTHCARE PLLC

10117 N. 92nd Street – Suite #101

Scottsdale, Arizona, 85258

Phone: +14806145808

Email: toby@direct.healthcare

Your privacy and security are of utmost importance to us, and we are committed to protecting

the information you entrust to DIRECT HEALTHCARE PLLC.

SECTION 5: Cookies and Web Beacons

What is a cookie or web beacon?

At DIRECT HEALTHCARE PLLC, we use “cookies” and “web beacons” to improve your

experience on our platform. A “cookie” is a small file stored on your device, designed to hold a

modest amount of data specific to you and our website. It helps to enhance platform

performance and personalize your experience.A “web beacon,” also known as a “pixel,” is a small, often invisible, graphic included on our

website or in emails, allowing us to monitor user activity and gather information about how

our services are used.

What are we using cookies and web beacons for?

We deploy cookies and web beacons for several purposes:

• Enhancing Platform Performance: Cookies help streamline your experience,

enabling features such as automatic login and personal settings.

• Monitoring and Analytics: To understand how our services are being used, which

helps us identify areas for improvement.

• Compliance: Ensuring our platform meets legal requirements and standards.

• Advertising: With your consent, we utilize cookies for targeted advertising, making the

ads you see more relevant to your interests.

How can you opt out of cookies, web beacons, and other tracking technologies?

You have control over your data. If you wish to opt out of tracking technologies like cookies

and web beacons:

• Visit the settings in your web browser to manage, disable, or delete your cookies.

• For web beacons used in emails, you can prevent them by disabling images in your

email client, though this might affect your ability to view other images.

Stopping Direct Marketing Communications:

If you no longer wish to receive direct marketing emails from us, you have the option to opt

out:

• Click the unsubscribe link located at the bottom of our email communications, and

you will be removed from future mailings.

Contact for Privacy Concerns:

If you have any questions regarding our use of cookies, web beacons, or your privacy

preferences, please contact us at:

DIRECT HEALTHCARE PLLC

10117 N. 92nd Street – Suite #101

Scottsdale, Arizona, 85258

Phone: +14806145808

Email: toby@direct.healthcare

Your privacy is our priority, and we are committed to ensuring your experience with DIRECT

HEALTHCARE PLLC is secure and personalized to your needs.