Privacy Policy

Fipple, Inc. ("Company", "us", and "we") is committed to protecting the privacy of sensitive information that is shared with us or that we discover.  We have prepared this Privacy Policy to describe our practices regarding the Personal Information (as defined below) we collect from users of the Fipple website (the “Site”) and the Fipple app (the “App”). For the purposes of this Policy, “Individual” refers to the person whose Data (as defined in Section 2 below) is shared with or collected by the Company. “You” or “Your” refers to the Individual or, If the reader of this Policy is not the Individual, then “You” or “Your” refers to the person (“Representative”) who is acting on behalf of an Individual for whom said Representative is (i) legally authorized to provide mental health services, or (ii) legally authorized to act, as a parent of a minor child; legal guardian, custodian or conservator; personal representative; power of attorney; or other person or entity legally authorized to share Data and to authorize the Company to collect such Information from third parties designated by the Representative, or through the Company’s website and/or through the use of the App.
  1. User Consent. By using our Site and/or the App, (i) You represent that You are legally authorized to access and share the Individual’s Data (as defined in Section 2 below), (ii) You agree to the terms of this Privacy Policy, and (iii) You expressly consent, on behalf of yourself and the Individual, to the Company’s collection, use and disclosure of the Data in accordance with this Privacy Policy. If the Individual is under the age of 13, we will not collect, maintain, use or disclose any Data unless you check the “I consent” box in the Terms of Use Agreement on the Site.
  2. Types of Data We Collect (the “Data”)
    • "Personal Information" means information:
      • (i) relating to the Individual’s past, present or future physical or mental health or condition, or the provision of or payment for physical or mental health care to the Individual; and/or
      • (ii) that identifies the Individual or for which there is a reasonable basis to believe it can be used to identify the Individual. Examples of common identifiers include, but are not limited to, name; date of birth; home address; work address; telephone numbers (land line and/or cell phone); e-mail address; a screen or user name, and any other substantially similar identifier that permits direct contact with a person online; a photograph, video, or audio file with the Individual’s image or voice; and geolocation information sufficient to identify street name and name of a city or town.
    • Information Provided to or Monitored by the Company.  We may collect information: directly from You, as well as from other persons or entities authorized to provide such Information to us; through Your use or the Individual’s use of the Company’s Site or the App; or through the Company’s ongoing monitoring of (i) electronic devices used by the Individual, including, but not limited to, laptop and desktop computers; tablets; mobile phones; and game consoles (“Devices”); and (ii) all internet activity by the Individual. This information may include, but not be limited to, websites and apps used or accessed by the Individual; information posted or viewed by the Individual on such websites or apps; the Individual’s location; text messages and e-mails (including images and video) sent and/or received by the Individual; and the Individual’s web browsing activity, contacts, and any information entered by the Individual into a Device. Further, we will connect to certain social media websites and other websites regularly for enhanced monitoring of the Individual’s on-line activities.
    • Information Collected via Technology. To make our Site more useful to You, our servers (which may be hosted by a third party service provider) may collect and store information from the Individual, the Representative, or other persons or entities authorized to provide such information to us, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer or other electronic device when the Internet is used, which may vary from session to session), domain name, and/or a date/time stamp for a visit to the Site. We may also use cookies, URL information, web beacons and similar technology to gather information regarding the date and time of an internet visit, web pages reviewed and the information searched and viewed.  "Cookies" are small pieces of information that a website sends to a computer's hard drive while viewing a website.  We may use both session Cookies (which expire once a web browser is closed) and persistent Cookies (which stay on a computer until deleted) to provide a more personal and interactive experience on our Site.  Persistent Cookies can be removed from a computer by following “help” directions from an Internet browser.
  3. Use of the Data
    1. General Use.  In general, the Data described in Section 2 is used to provide the Company’s services, and / or to improve our delivery of those services, which are intended to contribute to protecting the safety of the Individual.  We may use all or any part of the Data in any or all of the following ways:
      • To identify and understand the Individual’s Device usage and on-line communication activities, in order to allow us to effectively detect and monitor potential indicators of certain behaviors that might indicate depression, suicide, drug use, violence, bullying, or other destructive behaviors and situations (collectively, “Behaviors”);
      • To identify whether the Individual is in specific internet locations (or categories of internet locations), or using internet resources, which may be of concern based on information provided by You;
      • To notify parties designated by You in the event that we detect actual or potential Behaviors;
      • Upon Your request, to share with You any Data that we have collected;
      • Provide improved administration of our Site;
      • Improve the quality of experience when You interact with our Site; and
      • Respond to Your inquiries, or to solicit Your feedback.
    2. Creation of Anonymous Data.  We may create “Anonymous Data” records from the information that You provide or that we collect, by excluding the portion of the Personal Information that makes the information personally identifiable to the Individual.  We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our services and improve Site and App navigation.  We may combine Anonymous Data related to multiple users of the Site and the App, and reserve the right to use Anonymous Data for any purpose (including, but not limited to, analytical and marketing purposes), and to disclose Anonymous Data to third parties in our sole discretion.
  4. Disclosure of Data.  We only disclose the Data, including the Personal Information (as defined in Section 2 above), in the manner described In Section 3, and as described below.
    1. Third Party Service Providers.  We may share the Data with third party service providers to: support the services that we offer through our Site and our App; to conduct quality assurance testing; to provide technical support; and/or to provide other services to our Company necessary to our operations.  These third party service providers are required not to use any of the Data for any purpose other than to provide the services requested by us.
    2. Affiliates and Acquisitions.  We may share some or all of the Data with our corporate affiliates, such as joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy.
    3. Other Disclosures.  Regardless of any choices You make regarding the maintenance, use and disclosure of the Data, and in addition to the disclosures described above, we may disclose all or any part of the Data if we believe in good faith that such disclosure is necessary (i) to comply with our legal obligations related to imminent harm to the Individual or to others; (ii) to comply with other relevant laws or to respond to subpoenas or warrants properly issued and served on us; (iii) to protect or defend our rights or property, or other users of our services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use. If You disagree with the collection or use of Your “Data” as described in this Policy, please contact us at dataprivacy@fipple.com.
  5. Third Party Websites. When You link to any other website or location from our Site, You will leave our Site and go to another website and another entity may collect Data from You.  We have no control over, do not review, and cannot be responsible for, these third party websites or their content.  Please be aware that the terms of this Privacy Policy do not apply to these third party websites or content, or to any collection of data after You click on links to such third party websites. Please review the privacy policies of the third party websites for information on how they may collect, use and maintain the Data.
  6. Security of Your Data. We are committed to protecting the security of the Data.  We use a variety of industry-standard security technologies and procedures to help protect Your Data from unauthorized access, use, or disclosure. While we use reasonable commercial efforts to protect the Data, no technology, data transmission or system can be guaranteed to be 100% secure.
  7. Changes to This Privacy Policy. This Privacy Policy is subject to change in order to comply with applicable law and to reflect our business practices regarding the way we use Your Data. Accordingly, we may modify this Privacy Policy from time to time as reflected by the effective date listed above.  Our Site and the App will include the most current form of the Privacy Policy. Your continued use of our Site or App following any such update shall represent Your acknowledgement of such changes and agreement to be bound by the updated Privacy Policy.
  8. Revocation of Consent. Except as set forth in Section 4.c of this Policy, you may revoke Your consent to the Company’s collection, use, disclosure or retention of the Data, and require the Company to delete the Data, at any time by providing written notice to the Company at the physical or e-mail address set forth at the beginning of this Policy. Any such revocation will only be effective with respect to Company actions taken after the Company receives the revocation, and the revocation will not create any liability on the part of the Company under any federal or state law or regulation for any activities or actions taken prior to the receipt of the revocation.
  9. Contact Information. We welcome Your comments or questions regarding this Privacy Policy.  Please e-mail us at dataprivacy@fipple.com.

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