WebPT, Inc., and its subsidiaries and affiliates (“WebPT”, “we”, “us”, or “our”) value your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain through our websites posting this Policy, such as https://app.webpt.com, https://www.webpt.com https://therabill.com, https://get.webpt.com, https://why.weboutcomes.com, https://www.clinicient.com/, https://www.keethealth.com/, and https://www.webpt.com/ascend/ (collectively, the “Site”); the products and services available through our Site (collectively, the Site, and the services available through the Site are the “Services”). The Services and the Site are provided for business use and are not intended for use by individuals in their personal, family, or household purposes.

In providing our Services, the information we collect may include your or your patients’ protected health information (“PHI”), as that term is defined under the Health Insurance Portability and Accountability Act (“HIPAA”). Our processing of PHI is subject to WebPT’s Business Associate Agreement.

1. What Information We Collect:
   1. Demographic Data. On some pages, you can make a request to contact us or inquire about the Services through a web form, communicate with us by email, or enter a live chat. The types of information collected on these pages may include your name, company name, ZIP code, email address, and phone number.
   2. Usage Data. We also automatically collect information about you through your use of our Services, including, without limitation: Internet protocol (“IP”) address, browser type, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services, device identification information, and your activities within our Services (e.g., links you click, searches you run, purchase history, etc.). We may combine information we collect automatically with information we collect directly from you or from third parties.
   3. Chat Data. When you start a live chat, WebPT will collect a log about your interaction with WebPT’s chat agents.
   4. Ascend or Other Event Information. When you register for Ascend or another WebPT event, we collect information such as name, address, phone number, and email address. We use this information to communicate with you and in some cases facilitate your registration. Additionally, we may share your registration data with service providers of Ascend in order to provide event information and improve your experience at Ascend or future WebPT events.
   5. Account and User Information. We collect personal data when you sign-up for a WebPT account, create or modify user information, set preferences, or provide any other related information to access or utilize our Services.
   6. Advertising. The personal data we collect from other sources for the purposes of tailored advertising includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. We may collect this from third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs, and custom profiles for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility, and verifying contact information. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you.
   7. Other Data. We also may collect other data not specifically listed above, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
2. How We Use Your Personal Information. We use the information that we gather about you, including personal information, for the following purposes:
   1. Providing and Improving Our Services. To provide and maintain our Services; to improve our Services; to develop new features, products, or services; to perform technical operations, such as updating software; and for other customer service and support purposes.
   2. Anonymous Data. We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you.
   3. Research and Analytics. To analyze how our users interact with our Services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
   4. Protecting Rights and Interests. To protect the safety, rights, property, or security of WebPT, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity, which WebPT, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our Terms of Service.
   5. Testimonials, Comments, and Reviews. We post WebPT member testimonials, comments, reviews, and other user-generated content on our Services that may contain personal information. If you provide us with a testimonial, comment, or review, we will obtain your consent prior to posting your name along with your testimonial, comment, or review. If you later decide that you would not like your name shown, please contact us at legal@webpt.com.
   6. Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request from law enforcement or a governmental authority.
3. How We Disclose Information. We may disclose the information that we collect about you, including personal information, with the following entities or ways:
   1. Affiliates. We may disclose your information to any current or future affiliates or subsidiaries for research and other purposes.
   2. Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions, such as web hosting or data hosting, on our behalf.
   3. Marketing and Communications. To communicate with you about your account and use of our Services; to send you product, service, or event updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Our communications with you may include communications via email. Please see the “Your Choices” section of the Policy for more information about how to change your communications preferences.
   4. Blogs or Forums. Our Site offers publicly accessible blogs and/or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, please contact us per Section 13 of this Privacy Policy. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
   5. Business Transfers. We may disclose information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
   6. Protecting Rights and Interests. We may disclose information to protect the safety, rights, property, or security of WebPT, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that WebPT, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our any agreement governing your use of the Services.
   7. Professional Advisors. In individual instances, we may share your personal data with professional advisors – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your personal data
   8. We may share data with WebPT partners to contact you based on your request to receive such communications, help us perform statistical analysis, provide sales support, or provide customer support. Partners are prohibited from using your personal data except for these purposes, and they are required to maintain the confidentiality of your data.
   9. We also may partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications.
   10. Legal Compliance. We may disclose information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request from law enforcement or a government official.
   11. Aggregated and De-Identified Information. In addition to the disclosures noted above, we may also share aggregate or de-identified information with third parties for research or other purposes. For example, we may share de-identified information with an outcomes working group to help identify outcome trends related to certain treatments.
   12. Mobile Information. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
4. Service Emails and Other Communications.
   1. Our Services allow users to communicate with others through our in-product messaging services. Communications that are sent by or on behalf of a user are indicated as being “From” that user. Communications that are sent by us are indicated as being from us or one of our account or support specialists assigned to assist you. Either type of communication may be a “real time” communication or communication triggered automatically upon the occurrence of certain events or dates.
   2. Email communications from users and our administrative announcements are often transactional or relationship messages, such as workout reminders and message notifications, or other service notifications. If you or your healthcare provider are using these Services, you may not be able to opt-out of receiving certain messages, although our Services may provide a means to modify the frequency of receiving them. In cases in which we believe user emails are not primarily transactional or relationship messages, there will be the option to opt-out of receiving further emails.
5. Cookies and Tracking Analytics. We use cookies, local shared objects, log files, clear GIFs, embedded scripts, and other tracking mechanisms to track information about your use of our Services. We may combine this information with other personal information we collect from you.
   1. Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies enable a faster log-in process, and some allow us to track your activities on our Services. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to disable cookies or change your cookies settings.
   2. Clear GIFs, Pixel Tags, and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags) in connection with our Services to, for example, track the activities of visitors to our Site, help us manage content, and compile statistics about usage of our Sites. We may also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
   3. Local Storage Objects. We may use Local Storage Objects (“LSOs”), including Flash LSOs, to store your preferences and to personalize your visit. LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions.
   4. Do Not Track Disclosure. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
   5. Third-Party Analytics. We also use automated devices and applications, such as Google Analytics to evaluate usage of Services. We use these tools to gather information about users to help us improve our Services, performance, and user experiences. We may disclose information, including personal information, to certain third-party services in order to obtain such services. These analytics providers may use cookies and other technologies to perform their services and may combine the information that they collect about you on our Services with other information that they have collected on our Services. This Policy does not cover such third parties’ use of the data. To opt out of being tracked by Google Analytics across all websites, you can download the Google Analytics Opt-out Browser Add-on.
6. Third-Party Collection. Our Services may contain links to third-party websites and applications or integrate with websites and services provided by third parties. Any access to and use of such linked websites, applications, or third-party services is not governed by this Policy but instead by the privacy statements of those third parties. We are not responsible for the information practices of such third parties and we encourage you to read their privacy statements.
7. Data Security. The security of personal information is important and WebPT has implemented safeguards to protect the personal information it collects. To prevent unauthorized access and maintain data accuracy, we employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no method of transmission over the Internet, or method of digital storage, is 100% secure. Therefore, we cannot guarantee absolute security. Further, you should take steps to protect your device and/or account by, for example, logging off when you have finished with a session and choosing a robust password that no one else knows or could easily guess.
8. Your Choices
   1. Correcting or Deleting Personal Information. You may correct or request deletion of your personal information by logging into your account and updating your information. Please note that we may retain certain information about you as required by law or as permitted by law for legitimate business purposes (e.g., in accordance with our record retention policies or to enforce any agreements related to the Services).
   2. Opting out of Email Communications. We may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email or emailing us at legal@webpt.com. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving marketing emails from us, we may still send you non-promotional emails (e.g., about your account with us).
9. Interest-Based Advertising
   1. Opting Out. We use third parties such as network advertisers to display advertisements on our Services, to assist us in displaying advertisements on third-party websites, and to evaluate the success of our advertising campaigns. You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).
   2. Opt Out Effect. Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Services or other services. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextual advertising). Also, if your browsers are configured to reject cookies when you visit an opt-out page, or you subsequently erase your cookies, use a different computer, or change web browsers, your NAI or DAA opt- out may no longer be effective.
10. Children’s Privacy. Our online, publicly available Services, including public websites, are not targeted to children. Children under the age of 18 are not permitted to use WebPT software or services. We do not knowingly collect information online from children under 18. If we discover that we have collected personal information from a child under 18, we will take steps to delete such information.
11. United States Only. Access to our Services is administered in the United States (“US”) and is intended for users in the US. You may not use our Services in any jurisdiction where offering, accessing, or using our Services would be illegal or unlawful. If you are located outside of the US, please note that the information you submit to us will be transferred to the US. If you are located in a country other than the US, you should note that, at present, the laws of the US and certain other countries have not been approved by the European Commission or privacy authorities in certain other countries as providing “adequate protection” for personal information within the meaning of the General Data Protection Regulation or applicable laws of other countries.
12. Policy Changes. This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
13. Contact Us. If you have any further questions or concerns about this Policy or our privacy practices, please send us an email at legal@webpt.com.
14. Additional Disclosures for California Residents. The California Consumer Privacy Act (“CCPA”) (as amended by the California Privacy Rights Act) requires businesses to disclose whether they sell or share Personal Data. As a business covered by the CCPA, we do not sell personal data. We may share personal data (in the form of identifiers and internet activity information) with third party advertisers for purposes of targeting advertisements on non-WebPT websites, applications, and services. In addition, we may allow third parties to collect personal data from our Sites or Services if those third parties are authorized service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you use the Sites or Services to interact with third parties or direct us to disclose your personal data to third parties.
    1. Data categories. California law requires that we detail the categories of personal data that we disclose for certain “business purposes”, such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in Section 3 (“How We Disclose Information”) of this Privacy Policy. We disclose the following categories of personal data for our business purposes:
       1. Identifiers;
       2. Commercial information;
       3. Internet activity information;
       4. Financial information;
       5. Professional and employment-related information;
       6. Education information;
       7. Geolocation data;
       8. Audio and visual data;
       9. In limited circumstances where allowed by law, information that may be protected characteristics under California or United States law; and
       10. Inferences drawn from any of the above information categories.
    2. Exercise of Rights.
       1. California law grants state residents certain rights, including the rights to know and access specific types of personal data, to learn how we process personal data, to request deletion of personal data, to request correction of personal data, to opt-out of sharing your personal data for third party advertising purposes, and not to be denied goods or services for exercising these rights.
       2. If you are a California resident, you can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your personal information.
       3. To exercise your rights, please contact us by:

Sending your request to legal@webpt.com,

Writing to us by mail at WebPT, Inc., 111 West Monroe Street, Suite 200, Phoenix, AZ 85003, Attn: Legal Department, or

Calling us at (866)221-1870

Your personal data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a WebPT customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.