ALTHEA, PBC

Last Updated on October 31, 2024

Althea, PBC (“Althea”, “we”, “us” or “our”) respects the privacy of others. This Privacy Policy explains Althea’s privacy practices for the altheapbc.com website (together with its pages and features and all services provided through the website, the “Site”) by providing you and any person helping you visit, access, register with or use the Site (collectively, “you” or “your”) with an overview of the following:

• the type of personal information about you that Althea collects through the Site and the App;
• how that personal information is collected;
• how that personal information is used;
• how that personal information will be shared with others; 
• Althea’ security measures for protecting that personal information; and
• how to opt-out or unsubscribe and how to correct or delete your personal information .

As used herein, the term “personal information” means information that would allow someone to specifically identify you or contact you physically or online (e.g., your name, physical address, telephone number, email address, social security number); and the term “non-personal information” means any information other than personal information that Althea may collect from you.

This Privacy Policy applies to personal information collected through the Site and/or the App. Carefully read this Privacy Policy in its entirety.

When you create, register or log into an account through the Site, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the Site’s Terms of Service and the App’s Terms of Use.

Similarly, by visiting, accessing or using the Site, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the Site’s and the App’s Terms and your continuing visit, access or use of the Site reaffirms your acceptance and agreement in each instance.

If you do not agree to the terms herein, do not use our Site or our App and do not provide us with your personal information.

Contact Us

Please direct any questions you may have about this Privacy Policy, the Site to any one of the following:

• By mail: Althea, PBC, 1941 Pearl Street, #200, Boulder, CO 80302
• By email: info@altheapbc.com, with a subject line of “Privacy Policy.”

The foregoing contact information may change from time-to-time by supplementation, amendment, or modification of this Privacy Policy.

Changes to this Privacy Policy

We may supplement, amend, or otherwise modify this Privacy Policy at any time without notice to you. If we make any changes the revised Privacy Policy will posted on this or a similar page of the Site and the App and the “Last Updated” date at the top of this Privacy Policy will be revised and, in some cases, where appropriate we may notify you by adding a statement to the login screen or sending you an email notification.  All changes shall shall be deemed effective as of the stated “Last Updated” date. We encourage you to review our Privacy Policy whenever you use the Site to stay informed about our information practices and the ways you can help protect your privacy. It is your responsibility to carefully review this Privacy Policy each time you visit, access or use the Site .  Using our Site or App or continuing to provide personal information to us after a notice of changes has been sent to you or after the revised Privacy Policy has been published on our Site or App shall constitute consent to the changed terms and practices. If you disagree with any changes to this Privacy Policy, you will need to stop using the Site and the App and must deactivate your account(s). 

A Special Note About Minors

The Site is a general audience website intended for use by adults. Neither the Site nor the App is designed or intended to attract, and is not directed to, children under eighteen (18) years of age, let alone children under thirteen (13) years of age. Althea does not collect personal information through the Site from any person it actually knows to be under thirteen (13) years of age. If Althea obtains actual knowledge that it has collected personal information through the Site from a person under thirteen (13) years of age, then it will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under eighteen (18) years of age, then you (or your parent or legal guardian) may at any time request that Althea remove content or information about you that is posted on the Site . Please submit any such request (“Request for Removal of Minor Information”) to any one of the following:

• By mail: Althea, PBC, 1941 Pearl Street, #200, Boulder, CO 80302
• By email: info@altheapbc.com, with a subject line of “Removal of Minor Information.”

For each Request for Removal of Minor Information, please state “Removal of Minor Information” in the email or letter subject line, and clearly state the following in the body:

• the nature of your request;
• the identity of the content or information to be removed;
• whether such content or information if found on the Site ;
• the location on content or information on the Site(e.g., providing the URL for the specific web page the content or information is found on);
• that the request is related to the “Removal of Minor Information;”
• your name, street address, city, state, zip code and email address; and
• whether you prefer to receive a response to your request by mail or email.

If you send a Request for Removal of Minor Information by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking. Althea will not accept any Request for Removal of Minor Information via telephone or facsimile. Althea is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Site .

Also, please note that Althea is not required to erase or otherwise eliminate, or to enable erasure or elimination of, such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Althea to maintain the content or information; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when Althea anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Althea voluntary practices concerning the collection of personal information through the Site from certain minors, and is not intended to be an admission that Althea is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

Categories of Information Collected

Althea may collect personal and non-personal information about you through the Site.

Categories of Information Collected Through the Site. The categories of personal and non-personal information collected from you through the Site might include your:

• Name (first, last and/or middle) and unique identifiers (e.g., username);
• Login information for the Site (e.g., username, password, security questions and answers);
• Home contact information (e.g., mailing address, email address, telephone number, fax number);
• Gender;
• Date of birth;
• Electronic signature;
• Photographic or video image to the extent provided by a user to a provider (as further subject to the HIPAA Privacy Policy);
• Results of any questionnaires, surveys, information requests, interviews, or other documentary, text, video, or audio interactions related to the provision of telehealth services (as further subject to the HIPAA Privacy Policy);
• Billing and payment information (e.g., payor or payee name, checking account number, credit card number, expiration date, verification code, accountholder name, cardholder name, billing address, mailing address, tax ID number, billing history);
• Computer, mobile device, and/or browser information (e.g., IP address, mobile device ID information, operating system, connection speed, bandwidth, browser type, referring/exist web pages, web page requests, cookie information, hardware attributes, software attributes);
• Third-party website, network, platform, server and/or application information (e.g., Facebook, Twitter, Instagram);
• Usage activity concerning your interactions with the Site and/or third-party websites, networks, platforms, servers or applications accessed through the Site (e.g., number of clicks on a page or feature, amount of time spent on a page or feature, identity of third-party websites, networks, platforms, servers and applications being access through the Site);
• Usage activity concerning services provided to or accessed by you on or through the Site (e.g. such as whether a live session has been scheduled by the user, whether a provider or user joins a scheduled session, when a session began and ended, and whether a session was canceled or rescheduled);
• Communications between users and providers and communications between users and Althea’s customer service team;
• Information about third parties that you refer to Althea (e.g., name, email and/or other contact information, relationship);
• Information set forth in the Site’s online account registration, subscriber profile, and/or subscriber directory forms completed by you; and/or
• Statements or content (e.g., comments, videos, photographs, images), and information about such statements or content, which you submit or publish on or through the Site, or which are accessed via your public or linked social media pages (e.g., Facebook, Twitter, Instagram).

Categories of Other Information Collected From Your Mobile Device. If you use your mobile device to visit, access or use the Site , then additional categories of personal and non-personal information collected from you through the Site might include:

• Your name associated with your mobile device;
• Your telephone number associated with your mobile device;
• Your geolocation;
• Your mobile device ID information;
• With your express consent, your contacts and/or contact information (e.g., names, telephone numbers, physical addresses, email addresses, photos) stored on your mobile device; and/or
• With your express consent, information about third-party software applications on your mobile device (including, without limitation, general software apps, downloadable software apps, social media apps).

You are solely responsible for the accuracy and content of the personal information you provide to Althea, and for keeping your personal information current and correct.

How Information Is Collected

Althea might collect personal and non-personal information from you when you visit, access or use the Site; when you register with or subscribe to the Site; when you register for or subscribe to the products and/or services of Althea online through the Site; when you “sign in,” “log in,” or the like to the Site; when you allow the Site to access, upload, download, import or export content found on or through, or to otherwise interact with, your computer or mobile device (or any other device you may use to visit, access or use the Site and/or the App) or online accounts with third-party websites, networks, platforms, servers or applications (e.g., your online social media accounts, your cloud drives and servers, your mobile device service provider); or whenever Althea asks you for such information, such as, for example, when you process a payment through the Site and/or the App, or when you answer an online survey or questionnaire.

In addition, if you or a third party sends Althea a comment, message or other communication (such as, by way of example only, email, letter, fax, phone call, or voice message) about you or your activities on or through the Site and/or the App, then Althea may collect any personal or non-personal information provided therein or therewith.

Finally, Althea might use various tracking, data aggregation and/or data analysis technologies, including, for example, the following:

• Cookies, which are small data files (e.g., text files) stored on the browser or device you use to view a website or message. They may help store user preferences and activity, and may allow a website to recognize a particular browser or device. There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. Cookies may record information you access on one page of a website to simplify subsequent interaction with that website, or to help streamline your transactions on related pages of that website. Most major browsers are set up so that they will initially accept cookies, but you might be able to adjust your browser’s or device’s preferences to issue you an alert when a cookie is downloaded, or to block, reject, disable, delete or manage the use of some or all cookies on your browser or device.
• Flash cookies, which are cookies written using Adobe Flash, and which may be permanently stored on your device. Like regular cookies, Flash cookies may help store user preferences and activity, and may allow a website to recognize a particular browser or device. Flash cookies are not managed by the same browser settings that are used for regular cookies.
• Web beacons, which are pieces of code embedded in a website or email to monitor your activity on the website or your opening of the email, and which can pass along information such as the IP address of the computer or device you use to view the website or open the email, the URL page on which the web beacon is located, the type of browser that was used to access the website, and previously set cookie values. Web beacons are sometimes used to collect advertising data, such as counting page views, promotion views or advertising responses. Disabling your computer’s, device’s or browser’s cookies may prevent some web beacons from tracking or recording certain information about your activities.
• Scripts, which are pieces of code embedded in a website to define how the website behaves in response to certain key or click requests sent by the user. Scripts are sometimes used to collect information about the user’s interactions with the website, such as the links the user clicks on. Scripts are often times temporarily downloaded to the user’s computer or device from the website server, active only while the user is connected to the Site and/or the App, and deactivated or deleted when the user disconnects from the website.
• Analytic tools and services, which are sometimes offered by third parties, and which track, measure and/or generate information about a website’s or program’s traffic, sales, audience and similar information, and which may be used for various reasons, such as, for example, statistical research, marketing research, and content ratings research, and conversion tracking. Examples of the analytic tools and services which Althea might use include Google Analytics. Althea may also use other third-party analytic tools and services.
• We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users. 
• When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.
• Third Party Web Beacons and Third Party Buttons. We may also implement third-party content or advertising on the Service that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third-party content on the Service. Additionally, we may implement third-party buttons (such as Facebook “like” or “share” buttons) that may allow third parties to collect information about you through such third parties’ browser cookies, even when you do not interact with the button. Information collected through web beacons and buttons is collected directly by these third parties, and Althea does not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.

Please be advised that if you choose to block, reject, disable, delete or change the management settings for any or all of the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies, then certain areas of the Site might not function properly.

By visiting, accessing or using the Site and/or the App, you acknowledge and agree in each instance that you are giving Althea permission to monitor or otherwise track your activities on the Site and/or the App, and that Althea may use the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies.

Use of Information Collected

Althea may use the personal and/or non-personal information it collects from you through the Site in a variety of ways, such as, for example, to:

• Fulfill your requests;
• Process your payments;
• Match users with services providers and facilitate provision of the services;
• Facilitate your movement through the Site and/or the App;
• Facilitate your use of the Site, the App and/or our products and/or services;
• Send you communications like, for example, administrative emails, answers to your questions and updates about the Site and/or the App;
• Complete an activity you requested, such as register for an account or obtain more information;
• Create your account and let you log in to your account and use the Site and/or the App;
• Manage your account, facilitate your interactions with telehealth providers and provide you with customer support;
• Provide you with information about Althea and/or Althea’s businesses, products and services by letter, email, text, telephone or other forms of communication;
• Provide you with information about third-party businesses, products and services by letter, email, text, telephone or other forms of communication;
• Reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act;
• Improve the Site, the App and/or their respective content, features and/or services;
• Improve the products, services, marketing and/or promotional efforts of Althea;
• Create new products, services, marketing and/or promotions for Althea;
• Market the businesses, products and/or services of Althea;
• Help personalize user experiences with the Site, the App and/or their respective products and/or services;
• Analyze traffic to and through the Site and/or the App;
• Analyze user behavior and activity on or through the Site and/or the App;
• Conduct research and measurement activities for purposes of product and service research and development, advertising claim substantiation, market research, and other activities related to Althea, the Site, the App and/or Althea’s products and/or services;
• Monitor the activities of you and others on or through the Site and/or the App;
• Protect or enforce Althea’s rights and properties; 
• Protect or enforce the rights and properties of others (which may include you); and/or
• Any other purpose with your consent.

Althea reserves the right to use your personal and non-personal information when:

• Required by applicable law, court order or other governmental authority (including, without limitation and by way of example only, in response to a subpoena or other legal process); or
• To comply with applicable state and federal laws, including, but not limited to laws related to protecting user, provider and/or public health and safety; or
• Althea believes in good faith that such use is otherwise necessary or advisable (including, without limitation and by way of example only, to investigate, prevent, or take legal action against someone who may be causing injury to, interfering with, or threatening the rights, obligations or properties of Althea, a user of the Site which may include you, a user of the App which may include you, or anyone else who may be harmed by such activities or to further Althea’ legitimate business interests).

One of Althea’s objectives is to accelerate the rate of acceptance of psychedelic medicine. We believe that in order to do this, the world of psychedelic medicine needs better data to surface safe, effective practices for scale. For this reason, gathering collective insights from across our user base is of the highest priority. We believe that by analyzing our aggregate data, we can help impact the rate of acceptance of this revolutionary approach to healing. 

• Collective Insights Improve Health Outcomes. Althea uses aggregate information to develop collective insights to help further the collective understanding and knowledge of psychedelic medicines, protocols, efficacy, and approaches. This insight is available within our Site and App to help practitioners better understand how their approaches compare to the cross-practice benchmarks we develop using this information. This in turn helps to identify areas for improvement and helps our practitioner customers to improve their health outcomes.
• How We Handle Data For Use In Collective Insights We collect your individual-level information into what is called aggregate information. All personal data has been removed in aggregated information. We use and share this aggregated information with selected third parties in order to conduct our own research, develop research reports, educate our users, and improve our services. ‍ 
• Access To Your Data. We will never sell or lease the personal data of our users. In addition, de-identified, aggregated, and anonymized data will only be used for research purposes and will never be used for marketing purposes.

Sharing of Information Collected

We Never Sell Personal Information. We will never sell, rent or otherwise provide your Personal Information to any third party for marketing purposes.

Althea does not authorize third parties to collect your personal information when you use the Site , except as described in this Privacy Policy. To the fullest extent permitted by law, Althea is not responsible for, and you hereby release Althea from any and all liability which may arise from, such third parties’ unauthorized collection, use and sharing of your personal information.

Sharing Information with Third Parties. We only share your Personal Information with third parties as described in this Privacy Policy, to carry out your instructions, as may be compelled by law, or as necessary to protect our rights or property. For example, Althea reserves the right to share your personal information with Althea’ employees, agents, administrators, accountants, financial advisors and legal advisors; with Althea’s employed or contracted lactation consultants, mental health providers and other providers; and with those third parties who help manage, administer distribute and/or operate the Site and/or the App, and/or third party service providers that provide their respective products, services and/or features for the Site (e.g., web hosting companies, website administrators, mobile app distribution platforms, video conferencing providers, support services companies, credit card or other payment processing companies), as needed in order for them to perform such services. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. 

Research Partners. With your explicit consent, we may share your Personal Information with our research partners in connection with our research activities. Our mission includes contributing to ongoing research and insights on the efficacy of psychedelic-assisted therapy. In order to successfully carry out our mission, we support research through a combination of analyzing our aggregate data, and direct market research activities. 

• Ability To Opt-in/Out Of Research. Our research may include analyzing aggregate information, conducting research surveys, and working with selected third-parties to support their research goals. You can opt out of any or all of these at any time. You can regularly revoke, reassess, and change the settings regarding how your information is stored, used, and shared at any time in your account settings or by contacting info@altheapbc.com directly. ‍ 
• How We Protect Your Identity In Our Research. Our research makes use of aggregate information. Aggregate information is data that has been amalgamated from multiple participants and is not linked to any specific individual. When your data is compiled into aggregated information, all personally identifiable information is removed and combined with other participants’ data so that no individual can reasonably be identified. People who have chosen to participate in studies that involve the treatment of specific conditions may be asked to provide additional consent forms for researchers to reference their de-identified, individual-level information for ongoing research. As with everything, this is your choice. 
• Choose To (Or Not To) Participate In Third Party Research. The de-identified and aggregated data gathered may also contribute to the research of selected third-party institutions working with Althea. These third-parties may also field research studies via our network to you. It will always be your choice to take part in these studies via an explicit opt-in.

Community. Our Site and App offer publicly accessible community services such as blogs and forums. You should be aware that any information or content you provide in these areas may be made public and read, collected, and used by others who access them. Your posts may remain even after you cancel your account. 

Compliance with Legal Process. We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder. We may be required to disclose your Personal Information and/or information with respect to your use of our Site and/or App in response to lawful requests by governmental or regulatory agency or by court order, subpoena or other legal process or requirement, including to meet national security or law enforcement requirements, or if we reasonably believe that such disclosure is necessary (i) to investigate, prevent or take action with respect to suspected or actual illegal activities or to assist government enforcement agencies, (ii) to protect the safety of any person from death or serious bodily injury, (iii) to prevent fraud or abuse of our Site and/or App or infringement of our intellectual property rights in our Site and/or App, (iv) to enforce our terms of use or your agreements with us, or (v) to investigate and defend ourselves against any third party claims or allegations. You should also be aware that our mental health counselors may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment. 

Business Transfers. We may sell, transfer or otherwise share your information to a third party in connection with a merger, acquisition, reorganization or sale of assets of Althea or in the event of bankruptcy of Althea and you agree that any such third party will have the right to continue to use your Personal Information and other information that you provide to us or which we obtain through your use of the service. 

For other business reasons: We may share your information to enforce any applicable terms and conditions applicable to our Site and/or App, and to ensure the safety and security of the Site and/or App and our users.

With affiliates within our corporate group: We may share your information with any subsidiaries or parent companies within our corporate group.

For advertising: Due to the use of cookies and web beacons, information regarding your activity on our websites, excluding activity when you are logged in and have started therapy, may be disclosed to our advertising partners to optimize marketing. We do not share with any advertising platform private information like member names, email addresses, phone numbers, diagnosis, sessions data, journal entries, messages, worksheets, or any other type of communication you have with your telehealth professional. If you want to opt out of these cookies and web beacons, reach out to us at info@altheapbc.com

Aggregated or Anonymized Data. We may also share aggregated or anonymized information that does not directly identify you with the third parties described above. 

With Your Consent. We will share your personal information with third parties when we have your consent to do so. 

Non-Personal Information. Althea does not limit the ways in which it may use or share non-personal information because non-personal information does not identify you. For example, Althea may freely share non-personal information with its affiliates, suppliers and representatives, as well as with other individuals, businesses, and government entities. We may de-identify your information and disclose such de-identified information for any business or other purpose not prohibited by applicable law.

Google Analytics and Advertising

We use Google Analytics to recognize you and link the devices you use when you visit our Site on your browser or mobile device, log in to your account on our Site or App, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Site and App and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located atwww.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Site and/or App. You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources athttp://www.networkadvertising.org/choices.

Data Retention

Althea may retain your personal information and non-personal information for as long as it believes necessary; as long as necessary to comply with its legal obligations, resolve disputes and/or enforce its agreements; and/or as long as needed to provide you with the Site and/or the App. Althea may dispose of or delete any such personal information or non-personal information at any time, except as set forth in any other agreement or document executed by Althea or as required by law.

Transactions

Generally. In connection with any transaction that you conduct through the Site (e.g., the payment of any subscription fees, the purchase or sale of any services on or through the Site and/or the App), you may be asked to supply certain information relevant to the transaction, including, without limitation, your credit card number and expiration date, your billing address, your phone number and/or your email address. By submitting such information, you grant Althea without charge the irrevocable, unencumbered, universe-wide and perpetual right to provide such information to third parties for the sole purpose of facilitating the transaction.

Third Party Links

The Site, the App, and/or any communications sent through or as a function of the Site may contain links to third-party websites, networks, platforms, servers and/or applications. To the fullest extent permitted by law, Althea is not responsible for, and you hereby release Althea from any and all liability which may arise from, such third party websites, networks, platforms, servers and applications (including, without limitation, the privacy policies and practices of such third-party websites, networks, platforms, servers, and applications).

You may have the opportunity to access the Site using your online user accounts with certain third-party websites, networks, platforms, servers or applications, which may be subject to separate privacy policies pertaining to those third-party websites, networks, platforms, servers or applications. Althea may also collect information from those third-party websites, networks, platforms, servers or applications (such as, for example, your name, gender, date of birth and personal interests, when you “like” or click links provided by or through those third-party websites, networks, platforms, servers, or applications and other information available through your online account or page with those third-party websites, networks, platforms, servers or applications). 

Althea does not control these third-party websites, networks, platforms, servers and/or applications and our provision of links to or use of these third party websites, networks, platforms, servers and/or applications does not constitute an endorsement and you should proceed with caution.  This Privacy Policy does not apply to such third party websites, networks, platforms, servers and/or applications, which are subject to their own privacy policies, waivers and terms of use.  It is your responsibility to carefully read, accept and comply with the relevant terms of use, waivers, and privacy policies associated with third-party websites, networks, platforms, servers and applications, which may be significantly different from ours.

Security

Althea implements security measures to help protect the personal information it collects through the Site and the App. For example, Althea encrypts the transmission of information through the Site by using secure socket layer (SSL) technology.

When sensitive Personal Information (such as a credit card information) is collected on our store, it is protected by our third-party credit card processor. 

As part of providing you the Site and/or App, we may need to provide you with certain communications (via in app message, text and email), such as service announcements and administrative messages. These communications are considered part of the Site and/or App and may occur via emails, text messages or in app messages. You acknowledge that you are aware that email and text messages are not secure methods of communication and that your communication with us is not encrypted, and that you agree to the risks including the risk that the information contained within emails or texts could be read by a third party.

Although we use industry standard security measures, the Internet is not a 100% secure environment and we cannot, and do not, ensure or warrant the security of any information you transmit or store using the Site and/or App. There is no guarantee that your information may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards and we are not responsible for third party circumvention of your privacy settings or our security measures. You are responsible for maintaining the secrecy of your unique password and account information and for controlling access to your account.

To help maintain the security of your personal information, Althea asks that you please notify it immediately of any unauthorized visit, access or use of the Site and/or the App, or the loss or unauthorized use of your user access information for the Site (e.g., username or password).

Opting Out and Unsubscribing

You may, of course, decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of the Site and/or App. 

To Unsubscribe From Our Communications:  You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails, or to any one of the following:

• By mail: Althea, PBC, 1941 Pearl Street, #200, Boulder, CO 80302, with a subject line of “Unsubscribe.”
• By email: info@altheapbc.com with a subject line of “Unsubscribe.”

Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request, and you may receive promotional communications from us that you have opted out from during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Site as long as you remain a member of Althea.

How You Can Opt Out of Web Tracking:  There are several ways to opt out of web tracking:  

Most browsers allow you to block third-party cookies or prevent cross-domain tracking. This will limit the cookies that can be set by third-party scripts. This will not completely eliminate tracking by some third-party services though as they may use first-party cookies. 

Most browsers also allow you to ask not to be tracked (it sends the “Do Not Track” request header). If you have enabled this feature, we will not track the pages you visit in a way that enables us to connect them to your personal information. Your page views may still be collected anonymously though. Many of the third-party services we use for collecting anonymous data also respect the Do Not Track setting. 

How You Can Opt Out of Cookies:  Most browsers allow you to adjust your browser settings to (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Blocking or deleting cookies may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Deleting cookies does not delete Local Storage Objects (LSOs) such as HTML5.

How You Can Opt Out of Interest-based Advertising: To learn about interest-based advertising and how you may be able to opt out of some of this advertising, you may wish to visit the Network Advertising Initiative’s (NAI) online resources athttp://www.networkadvertising.org/choices and/or the DAA’s resources at www.aboutads.info/choices.

How You Can Opt Out of Cross-device Linking: Please note that opting out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt out on each browser or device you use.

How You Can Opt Out of Mobile Advertising: You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt out of interest based ads” (Android). You may also be able to opt out of some—but not all—interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Some of these opt outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again.

Retention, Review, and Change of Information Collected

You may request at any time that Althea provide you with an opportunity to review and change your personal information collected through the Site or to no longer use your personal information to provide you with any products or services. Please submit any such request (“Request Concerning Personal Information”) to any one of the following:

• By mail: Althea, PBC, 1941 Pearl Street, #200, Boulder, CO 80302, with a subject line of “Your Personal Information.”
• By email: info@altheapbc.com with a subject line of “Your Personal Information.”

For each Request Concerning Personal Information, please state “Your Personal Information” in the email or letter subject line, and clearly state the following in the body:

• the nature of your request;
• that the request is related to “Your Personal Information;”
• your name, street address, city, state, zip code and email address; and
• whether you prefer to receive a response to your request by mail or email.

If you send a Request Concerning Personal Information by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking. Althea will not accept a Request Concerning Personal Information via telephone or facsimile. Althea is not responsible for any Request Concerning Personal Information that is incomplete, incorrectly labeled, or incorrectly sent.

Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may not be able to modify or delete your information in all circumstances.

Protected Health Information

Some of the information you submit or that is created through your use of the Service may constitute “protected health information” (“PHI”) as defined by the Health Insurance Portability and Accountability Act (“HIPAA”). PHI does not include information that has been de-identified in accordance with HIPAA. Even though Althea is not a “covered entity” as defined by HIPAA, providers that provide services through the Site and the App may be a “covered entity” and therefore the providers and/or Althea may be subject to certain requirements under HIPAA. As a result, Althea has adopted a HIPAA Notice of Privacy Practices (the “Notice of Privacy Practices”) to describe how Althea and its providers use and disclose your PHI.

Jurisdictional Issues

The Site and App may only be used within certain jurisdictions within the United States as set forth in the Althea Terms of Service. Accordingly, this Privacy Policy, and our collection, use, and disclosure of your personal information, is governed by U.S. law, and by using the Site and/or App, you acknowledge that the Site and/or App will be governed by U.S. law. Using the Site and/or App from outside the United States is prohibited under our Terms of Service and may subject you to termination under such Terms of Service. In no event will Althea or any of its officers, directors, employees, consultants, subsidiaries, agents, and affiliated entities or any of Althea’s providers, be liable for any losses or damages arising from your use of the Site and/or App outside of the United States, and you waive any claims that may arise under the laws of your location outside the United States. 

Notwithstanding the foregoing, we do not represent or warrant that the Site and/or App is appropriate or available for use in any particular jurisdiction. If you choose to use the Site and/or App from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Site and/or App. By providing any information, including PHI, on or to the Site and/or App, you consent to such transfer, storage, and processing.

Your California Privacy Rights

These California Privacy Rights Disclosures (the “CA Disclosures”) provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”). Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in this Privacy Policy or as otherwise defined in the CCPA. The CCPA provides that you may not be discriminated against for exercising these rights.

Personal Information

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. 

For the purposes of these CA Disclosures, personal information does not include:  

• Publicly available information from government records. 
• Deidentified, aggregated or anonymized data (not capable of being associated with or linked to you).
• Information relating to our job applicants, employees, contractors and other personnel, which is not governed by these CA Disclosures.
• Information excluded from the CCPA’s scope, such as: (i) Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; (ii) Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. 

California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

1. The Right to Know:  You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:

• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information we have collected about you;
• The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
• The business or commercial purposes for collecting or, if applicable, selling personal information about you. 

2. The Right to Request Deletion: You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.

3. The Right to Opt Out of Personal Information Sales: You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.   If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.  

4. The Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of the rights described above.   However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner. 

Collection and Use of Personal Information

We collect various categories of personal information in connection with our services. Please review this Privacy Policy to learn more about the personal information we collect, how we collect personal information and how we use personal information. The personal information we collected in the last twelve months is as described above under the heading “Categories of Information Collected”.

Sale of Personal Information

We do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and for other business purposes. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see the section of this Privacy Policy with the heading “Opting-out and Unsubscribing” for more information including how you may be able to exercise your rights to opt-out of cookies, analytics and personalized advertising. 

How to Exercise Your California Privacy Rights 

To Exercise Your Right to Know or Right to Deletion:  You may request that we: 

• disclose to you the following information covering the 12 months preceding your request:
• the categories and specific pieces of personal information we collected about you and the categories of personal information we sold;
• the categories of sources from which we collected such personal information;
• the business or commercial purpose for collecting or selling personal information about you; and
• the categories of third parties to whom we sold or otherwise disclosed personal information. 
• delete personal information we collected from you; or
• opt-out of any future sale of personal information about you.

To exercise your right to know and/or right to deletion, please submit a request by emailing info@altheapbc.com with the subject line “California Rights Request”.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity. 

To Exercise Your Right to Opt Out of Personal Information Sales:   As noted above, we do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see the section of this Privacy Policy with the heading “Opting-out and Unsubscribing” for more information including how you may be able to exercise your rights to opt-out of cookies, analytics and personalized advertising. 

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of this Privacy Policy. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our website, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Severability

If any term or condition of this Privacy Policy is deemed invalid or unenforceable by a court of law with binding authority, then the remaining terms and conditions shall not be affected, and the court shall reform the invalidated or unenforceable term or condition to the maximum extent permitted under the law and consistent with the intent of this Privacy Policy.