Privacy Policy

BEHAVIORAL WEALTH INSTITUTE
PRIVACY POLICY

  1. Introduction

Behavioral Wealth Institute (“us,” “we,” or “BWI”) is committed to respecting the privacy rights of our customers, visitors, and other users of the BWI services (“Services”) provided via the BWI website (collectively, “Site”). We created this Site Privacy Policy (“Privacy Policy”) to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is only applicable to the Site, and not to any other websites that you may be able to access from the Site or any website of BWI’s partners, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy. Your use of the Site is governed by this Privacy Policy and the Terms of Use. If you are registering an account or using the Site on behalf of an individual or entity other than yourself, you represent that you are authorized by such individual or entity to accept this Privacy Policy on such individual’s or entity’s behalf.

  1. Traffic Data Collected
    We automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) types of web browsers used to access the Site; (5) referring source which may have sent you to the Site; and (6) other information associated with the interaction of your browser and the Site (collectively “Traffic Data”).
  2. Information Collected
    In order for you to access certain areas of the Site, we may require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information: (1) Contact Data (such as your e-mail address, phone number, and BWI password); and (2) Demographic Data (such as your gender, your date of birth, and your zip code). If you communicate with us by, for example, e-mail or letter, any information provided in such communication may be collected as Personal Information. BWI’s platform is reviewed, audited, and certified to be compliant with the Payment Card Industry Data Security Standard (PCI DSS). BWI shall continue to follow PCI DSS requirements.
  3. Interactive and Installed Tools
    We also collect other information, some of which may be Personal Information that you voluntarily provide to us when you choose to use some of the Site’s interactive tools and services (“Interactive Tools”), such as searching for Providers, searching for available appointments with them, and completing medical history forms (“Medical History Forms”) before appointments. We also collect information you provide voluntarily in free-form text boxes on the Site and through responses to surveys, questionnaires, and the like. Some of the free Interactive Tools and surveys on our Site ask you for health-related Personal Information. You may elect to use certain Services available through the Site that require you to download and install software on your computer (“Installed Tools”). The Installed Tools may collect and transmit information from your computer system solely relating to use of the Installed Tools and for the purpose of providing you the relevant Services, for example, by informing BWI when a user is logged on and available to receive updates or alert notices.
  4. Cookies

“Cookies” are small computer files that are transferred to your computer’s hard drive that contain information such as user ID, user preferences, lists of pages visited, and activities conducted while browsing the Site. At your option, expense, and responsibility, you may block cookies or delete cookies from your hard drive. However, by disabling cookies, you may not have access to the entire set of features of the Site. Generally, we use “cookies” to customize your experience on our Site and to store your password, so you do not have to re-enter it each time you visit the Site. In addition, our business partners may use cookies to provide us with anonymous data and information regarding the use of our Site. Specifically, some of our business partners use cookies to show BWI ads on other sites on the internet as a result of you using the Site. Such cookies do not contain any Personal Information. Other cookies used by our business partners may collect other non-personally identifying information, such as the computer’s IP address, type of operating system, type of internet browsing software, what web pages were viewed at what time, the geographic location of your internet service provider and demographic information, such as gender and age range. This information is used to provide BWI with more information about our users’ demographics and internet behaviors. You may find out more about the information collected and how to opt-out of receiving these cookies by visiting our partner’s respective website. We do not link the information stored in these cookies directly to any of your Personal Information you submit while on the Site, however.

  1. Web Beacons
    In limited circumstances, we also may use “Web Beacons” to collect anonymous, non-personal information about your use of our Site and the sites of selected sponsors and advertisers, and your use of emails, special promotions, or newsletters we send to you. “Web Beacons” are tiny graphic image files embedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user’s browser. The information collected by web beacons allows us to statistically monitor how many people are using the Site and selected sponsors’ and advertisers’ sites, or opening our emails, and for what purposes.
  2. Website Analytics
    We may use third-party website analytics services in connection with the Site. These website analytics services do not collect Personal Information that you do not voluntarily enter into the Site. These services do not track your browsing habits across websites that do not use their services. We are using the information collected from these services to find usability problems to make the Site easier to use. The recordings will never identify you or your account. We only record anonymous user information, and we stop such recording before you sign in or create an account.
  3. Storage
    We store all Traffic Data and review postings indefinitely, even after “deletion,” and may archive such information elsewhere. We store all Personal Information until you request that we modify or delete it, in which case we may still wind up retaining some of that information for the reasons described in Section 20 below.
  4. Information Provided on Behalf of Children
    BWI does not collect information from children under the age of 13 in accordance with the Children’s Online Privacy Protection Act (“COPPA”) as discussed below. If you are a parent or legal guardian of a minor child, you may, in compliance with the Terms of Use, use the Site or Services on behalf of such minor child. Any information that you provide while using the Site or Service on behalf of your minor child will be treated as Personal Information as otherwise provided herein.
  5. Children’s Online Privacy Protection Act
    COPPA severely restricts what information can be collected from children under the age of 13. For this reason, children under the age of 13 in the United States are prohibited from using the Site. The Site is not directed at children, and BWI does not knowingly collect any information from individuals under the age of 13. If we learn that we have received any information from an individual under the age of 13, we will use that information only to respond directly to that child (or a parent or legal guardian) to inform him or her that he or she cannot use the Services and subsequently we will delete that information from our own servers.
  6. BWI’s Use of Your Information
    We may use your Personal Information to recommend certain resources or mental health providers. BWI may view emails that you send to mental health practitioners from our site. This information will never be shared with outside parties. We may use your Contact Data to send you information about BWI or our products or Services, to contact you when necessary, including to remind you of membership expiration dates and to encourage you to take a pre or post-survey. We may use your Demographic Data, your Traffic Data, your Insurance Data, or your Medical Data to customize and tailor your experience on the Site, in emails, and in other communications, displaying content that we think you might be interested in and according to your preferences. You agree to give us permission to contact you at 6-month intervals to ensure that services are being provided to your liking, to enquire about your membership status, and to ask you to take a post-treatment survey. We may also use your de-identified Personal Information to run (or authorize third parties to run) statistical research on individual or aggregate health or medical trends. Such research would only use your Personal Information in an anonymous manner that cannot be tied directly back to you.
  7. Sharing of Information
    We share certain categories of information we collect from you in the ways described in this Privacy Policy, including as described below:
    • We share Traffic Data with our business partners who assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Site and/or by making certain Interactive Tools available to our users. Those business partners shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to BWI and to provide your requested medical care and services.
    • We may transfer information about you to another company in connection with a merger, sale, or acquisition by or of BWI. In this event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy. BWI does not share, sell, rent, or trade your Personal Information with any third parties for their promotional purposes.
  8. User Choice
    You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Site; however, you will not be able to access and use those portions of the Site that require your Personal Information, this includes contracting with a Behavioral Wealth Institute clinician.
  9. Confidentiality and Security
    Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless we believe in good faith that disclosure of your Personal Information or any other information we collect about you is necessary to: (1) comply with a court order or other legal process; (2) protect the rights, property or safety of BWI or another party; (3) enforce our Terms of Use; or (4) respond to claims that any posting or other content violates the rights of third-parties.
  10. Mental Health Clinicians
    Mental Health Clinicians, their employees, and their agents should be particularly aware of their obligations of patient confidentiality, including without limitation their obligations under the Health Insurance Portability and Accountability Act (“HIPAA”), both in communicating with BWI and in responding to a review of their services posted on our Site. BWI does not have, and will not accept, any obligations of confidentiality concerning any communications other than those expressly stated in this Privacy Policy and BWI’s Terms of Use.
  11. Public Information
    Any information that you may reveal in a review posting or other online discussion or forum is intentionally open to the public and is not in any way private. You should think carefully before disclosing any personally identifiable information in any public forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.
  12. Security
    The security of your Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, when you enter sensitive information on our Site, we encrypt that information using secure socket layer technology (SSL).
    Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Personal Information. If we become aware that your Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.
  13. Lost or Stolen Information
    You must promptly notify us if your Contact Data is lost, stolen, or used without permission. In such an event, we will remove that Contact Data from your account and update our records accordingly.
  14. Updates and Changes to the Privacy Policy
    We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy so please review it frequently. If we do, then we will notify you here, as well as by posting a notice on our Site and, where appropriate, a link to the modified policy so that you can review it. In all cases, use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.
  15. Controlling Your Personal Information
    As a registered user of the Site, you can modify some of the Personal Information you have included in your profile or change your username by logging in and accessing your account. Upon your request, BWI will use commercially reasonable efforts to delete your account and the Personal Information in your profile; however, it may be impossible to remove your account without some residual information being retained by BWI. BWI has no obligation to delete any data or information you provide on a Medical History Form following the termination of your account or the account of any medical professional to whom your Medical History Form was submitted through the Site. Registered users who wish to close their account should contact email here
  16. Links to Other Websites
    The Site contains links to third-party websites to which BWI has no affiliation. BWI does not share your personal information with those websites and is not responsible for their privacy practices. Some websites may have the look and feel of our Site. Please be aware that you may be on a different site and that this Privacy Policy only covers our Site. Should you decide to visit one of these third-party websites, we suggest that you read its privacy policy.
  17. Contacts
    If you have any comments, concerns, or questions about this Privacy Policy, please contact us at:
    Behavioral Wealth Institute
    (703) 595-4803
    Alexandria, VA 22314