Privacy Policy

Reviving Mind Labs, Inc.

Reviving Mind Labs, Inc. (“Reviving Mind”) is devoted to safeguarding your private information and ensuring the highest level of confidentiality. This Privacy Policy describes the information we collect, how we use it, and the standards and procedures in place to safeguard your personal nonpublic information.

Reviving Mind, its personnel, and its affiliates strictly adhere to this Privacy Policy and the security practices and procedures described herein to ensure the confidentiality of customer information. It is Reviving Mind’s policy to comply with all federal and state laws and regulations relating to the privacy of our customers’ private information (PI) and private health information (PHI).

We receive several different types of information about you, including the information that is required when you sign up for the site, as well as the information you choose to share.

If you are coming to the site through an employer or insurer payor then there is additional information collected by these Parties. This information is typically collected to confirm your eligibility with the network benefit administrator and is not shared with your Provider (who will collect your contact information separately). Further, your Employer or the Employer of the subscriber of your benefits will not be provided this information (you likely already provided them similar information in your employee file unless you are a family member of an eligible employee).

Except as permitted by law or as otherwise described below, Reviving Mind does not disclose any PI/PHI about its customers, former customers, employees, or anyone. Reviving Mind does not sell lists or customer information.

Information Reviving Mind Collects for Customers

Reviving Mind collects, retains, and uses PI/PHI from customers to include the following:
● The information that is required when you sign up for the site, as well as the information you choose to share.
● Required information such as your name, email address, birthday, and gender. We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties.
● Usernames and User IDs, which are a way to identify you on Reviving Mind. A User ID is a string of numbers and a username generally is some variation of your name.
● “Public Information” which means the information you choose to make public, as well as information that is always publicly available.
● Information posted to a Group Therapy session or moderated session and information kept within a one on one session.
● “Contact Information” is personal information and or family/friend/relation that Reviving Mind stores confidentially for your Therapist to access in case of an emergency or mental health crisis.
● Information Reviving Mind receives on forms, including, but not limited to, identifying information such as address, telephone number, e-mail address related to customer projects;
● Banking information for billing purposes, such as account # and routing information for invoicing purposes

Information Reviving Mind Collects for Employees and Sub-Contractors

Federal law requires us to obtain, verify, and record personal information - such as your name, address and date of birth - in order to confirm your identity, social security number and banking information. Reviving Mind collects, retains, and uses PI from employees and subcontractors including the following:

● Information Reviving Mind receives on applications or other forms, including, but not limited to, identifying information such as address, telephone number, e-mail address, social security number, date of birth, mother’s maiden name, medical history;
● Federal Tax ID #;
● Medical records;
● Investment information;
● Background security checks

Information Reviving Mind May Share

Reviving Mind Labs, Inc. runs the site and maintains all Data. We keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies or during an emergency circumstance as judged by your Therapist working with local authorities). Generally, we only use your information within our company. However, sometimes we use third parties to process your information (for example as credit card payment providers). We require these third parties to comply strictly with its instructions and we require that they not use your personal information for their own business purposes.

How we use your Data

Reviving Mind uses non-identifying and aggregate information to better design our website and to use in research and trend analysis. For example, we may tell an advertiser that X number of individuals visited a certain area on our Web site, or that Y number of men and Z number of women filled out a site survey or form, but we would not disclose anything that could be used to identify those individuals. We only provide data to our partners, if any, after we have removed your name and any other personally identifying information from it, or have combined it with other people’s data in a way that it no longer personally identifies you.

Reviving Mind uses non-identifying (De-Identified or “Safe Harbor” form) and aggregate information about responses to the clinical outcome assessments (personal assessments), and the frequency of the utilization of the Reviving Mind service. These efforts enhance program evaluation.

The anonymous and aggregated data also may be published through various media platforms/academic journals. No personal identifying information is tied to the results, and Reviving Mind does not share anything that could be used to identify your account or your private information.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will contact you before we use your data for these new purposes to notify you of the policy change and to provide you with the ability to opt out of these new uses.Reviving Mind stores data only for as long as it is necessary to provide products and services to you and others, including those described above and for legal protections or as required by applicable laws and regulations.

Reviving Mind may enable access to public information that has been shared through our services.

Reviving Mind may allow service providers to access information so they can help us provide services. IP addresses are used to identify the location of users, the number of visits from different countries and also to block disruptive use; and to analyze and improve the services offered on our website, e.g. to provide you with the most user-friendly navigation experience.Certain information is needed to provide you with services, so we only delete this information after you delete your account. Some forms of processing (sending promotional information, commercial profiling, behavioral advertising, geo-location, etc.) may require the express consent of the User. Specific information may be shown on the pages of the Site in connection with services or processing of Data provided by the Site User.

Upon request we provide site visitors with access to a description of information that we maintain about them. www.revivingmind.com uses industry-standard encryption technologies when transferring and receiving consumer data exchanged with our site. If you feel that this site is not following its stated information policy, you may contact us at the address below or via our contact us page.

For content that is covered by intellectual property rights, like photos and videos you specifically grant www.revivingmind.com a non-exclusive, transferable, sub-licensable, royalty- free, worldwide license to use any IP content that you post on or in connection with www.revivingmind.com (IP License). This IP License ends when you delete your IP content or your account unless your content has been shared with others, and they have not deleted it. This Paragraph does NOT apply to photos, images or other videos shared ONLY with your Therapist in your private “Room” on the Platform.

When you delete IP content, it is deleted as permanently as technically reasonable. You understand that removed content may persist in backup copies for a reasonable period (but will not be available to others).

Disclosure of Personal Information

We do not share nonpublic personal information about our customers (present, former and potential) with anyone, except as required by law, or as follows:

● To any person when you authorize such disclosure;
● To computer services consultants and technicians or other security consultants, inorder to ensure the confidentiality and security of customer & employee records;
● To financial service providers or consultants to carry out requested services,and/or to protect against or prevent actual or potential fraud, unauthorizedtransactions, claims, or other liability;
● To independent auditors or consultants to carry out institutional riskcontrol;
● To government or regulatory agencies, including self-regulatory organizationsand to comply with a legal summons, court order, subpoena or a similar legalprocess, audit or investigation; and,
● To swap data repositories

Protection: How We Protect Personal Information

We restrict access to information about you to those employees who need to know that information as part of their job responsibilities. We also educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our Code of Conduct. We take appropriate disciplinary measures to enforce employee privacy responsibilities. We have developed precautions that comply with federal regulations to ensure the security and confidentiality of customer records and information, to guard against any anticipated threats or hazards to the security or integrity of such records, and to protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to our customers or our employees.

Reviving Mind maintains strict information security procedures, including physical, electronic and procedural safeguards, to protect the confidentiality of your information. We conduct semi-annual Risk Privacy Assessments and remediate to update our technology to improve the protection of information storage.

We protect nonpublic personal information by

● Restricting access to customer information to only those personnel for whom the information is necessary;
● Entering into written confidentiality/non-disclosure agreements with third party service providers for certain disclosures;
● Maintaining physical, electronic, and procedural safeguards that comply with the relevant laws and regulations; and
● Conducting a Security Training and Awareness training program to communicate and educate employees about information security policies and procedures to make them aware of their roles and responsibilities in safeguarding information resources.
● Reviving Mind uses firewall barriers and digital certifications to maintain the security of your online session and information.
● We do not collect any non-public personal information about visitors on our website, unless information is provided to us voluntarily or derived from website navigation and usage of the Reviving Mind website and online platforms.
● We may gather and analyze information regarding usage of our website, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using cookies. Reviving Mind uses cookies and similar technologies to track usage of the website and to address security issues. We may also use cookies to store your preferences relating to use of our website. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet, phablet, cell phone or other electronic device (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website to track traffic flows.

Cookies record information about your preferences and allow us to tailor Reviving Mind to your interests. During the course or any visit to the Site, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things such as finding out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking for the cookie left there on the previous visit. Information supplied by cookies can help us to analyze the profile of our visitors so we can provide you with a better user experience.

Protecting the Privacy of your fellow Reviving Mind Users

During the use of www.revivingmind.com/services, you will not send or otherwise post unauthorized commercial communications (such as spam) on www.revivingmind.com. You will not collect users’ content or information, or otherwise access www.revivingmind.com, using automated means (such as harvesting bots, robots, spiders, or scrapers) without our permission.

You will not upload viruses or other malicious code.
You will not solicit login information or access an account belonging to someone else.
You will not bully, intimidate, or harass any other User.You will not post content that: is hateful, threatening, or pornographic; incites violence; or contains nudity or graphic or gratuitous violence.
You will not provide any false personal information on www.revivingmind.com or create an account for anyone other than yourself without permission.
You will not create more than one personal profile.

YOU WILL NOT PUBLISH, RECORD, SHARE, OR DISCLOSE ANY INFORMATION LEARNED OF ABOUT OTHER USERS DURING ANY GROUP THERAPY SESSIONS OFFERED ON WWW.REVIVINGMIND.COM AND UNDERSTAND THAT ANY OF THE AFOREMENTIONED ACTIONS MAY RESULT IN A PERMANENT BAN OF YOUR ACCOUNT.

Privacy Enforcement

Personnel using Reviving Mind’s information resources in opposition to this policy may be subject to limitations on the use of these resources, suspension of privileges (including internet access), as well as disciplinary and/or legal action, including termination of employment. Employees, contractors, consultants, interns, and all personnel affiliated via third parties sign the Privacy Policy agreement to comply and be governed by this policy and the Reviving Mind Information Security Policies upon hire and again annually. All Employees have background checks performed. All Therapists acting as contractors go through rigorous vetting processes meeting or exceeding national credentialing standards.

Copyrights: Reviving Mind and Protecting Other People’s Intellectual Property Rights

We respect other people’s rights and expect you to do the same. You will not post content or take any action on www.revivingmind.com that infringes or violates someone else’s rights or otherwise violates the law. We can remove any content or information you post on www.revivingmind.com if we believe that it violates this Privacy Policy or the Terms of Use on this Site. You will not use our copyrights or any confusingly similar marks, without our written permission. If you collect information from Reviving Mind Users, you will: obtain their consent, make it clear you (and not www.revivingmind.com) are the one collecting their information, and post a privacy policy explaining what information you collect and how you will use it. You will not post anyone’s identification documents or sensitive financial information on www.revivingmind.com. You will not tag Reviving Mind fellow Users or send email invitations to non-users without their consent.

Portable Electronic Devices

The Reviving Mind Platform is available on a multitude of portable electronic devices. We provide our connection to mobile services for free, but please be aware that your carrier’s normal rates and fees, such as text messaging fees, may still apply. You provide all rights necessary to enable Reviving Mind Users to sync (including through an application) their contact lists with any basic information and contact information that is visible to them on www.revivingmind.com, as well as your name and profile picture.

California Consumer Privacy Act (CCPA) Use and Disclosure of Personal Data

Reviving Mind recognizes that California has articulated specific privacy rights of Reviving Mind Users in that State. California Users should understand that Reviving Mind does not sell User data to third parties. Further, Reviving Mind is a medical records retention company. As such, almost all User data is kept in encrypted storage as a medical record, including all User created transcripts. State Law requires Reviving Mind to retain such records for at least seven years. The CCPA does not generally apply to medical information governed by the California Confidentiality of Medical Information Act (CMIA) or protected health information collected by a covered entity or business associate governed by the privacy, security, and breach notification rules of the Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009.

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request, once a year, if Reviving Mind have shared their personal information (non-medical record data only) with other companies for direct marketing purposes during the preceding calendar year. This is California’s “Shine-the-Light Law.”  To request a copy of the information disclosure provided by Reviving Mind, please contact us on www.revivingmind.com at the “contact us” link on the website. Please allow reasonable time for a response.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted on our site. Reviving Mind does not have Users below the age of 13 and does not typically allow Users to publicly post information. However, if you feel you publicly posted information on the Site and you are between the ages of 13 and 17, please contact us on www.revivingmind.com at the “contact us” link on the website. Please allow reasonable time for a response. Please be aware that such a request does not ensure complete or comprehensive removal of the data/content you have posted and that there may be circumstances in which the law does not require or even allow removal of data, specifically medical data, even if requested.

California Right to Know: You may request access to the specific pieces of personal data we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal data we have collected about you, the sources of such collection, the categories of personal data we share for a business or commercial purpose, and the categories of third parties with whom we share your personal data. You may make these requests by contacting us on www.revivingmind.com at the “contact us” link on the website. Please allow reasonable time for a response.

California Designated Agent. You may designate an agent to make a request on your behalf. That agent must have access to your account for us to verify the request. California Non-Discrimination. Reviving Mind will never discriminate against you, including by denying or providing a different level of service should you choose to exercise your rights under the CCPA.

Privacy in International Use and the GDPR

The Reviving Mind Platform advises both its Client/Users and practicing Platform Providers to be aware of and respect and comply with the local laws of any international based Client. Reviving Mind is cognizant and respects the formal promulgation of the existing European Union (EU) data privacy regulations. The General Data Protection Regulation 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It also addresses the export of personal data outside the EU and EEA and is commonly referred to as “GDPR.” Reviving Mind has always respected our Client’s Privacy (see our Privacy Policy) and we were already a HIPAA certified platform following stringent data privacy rules.

The basic tenants of the promulgated GDPR regulations include, but are not limited to the following:

Disclosure when you sell, transfer or third party marketing of User’s data: As outlined in this Terms of Use, Reviving Mind does not sell or transfer Client data and any marketing efforts are focused solely on internal information updates to our registered Clients.

Access to collected data: At Reviving Mind, you already have the ability to access your shared data (Your personal information, your emergency contact information and all your interactions with your Providers) and use it as you wish.

Clear Consent: At Reviving Mind our Terms of Use are clear on what consent we seek with regards to your data and prior to your engagement with your Provider, you review and agree to a further “informed consent” process.Security: At Reviving Mind we have encrypted our data from day one and has always been stored all Private Health Information with full HIPAA compliance and in an anonymized form as required by the GDPR.

Notice/Audit: At Reviving Mind, we will provide our Clients notice of any data breach and we employ a full time security Officer, as well as engaging a third party security firm to periodically audit both or code and technology security as well as our HIPAA policies and procedures around data security.

Finally, dependent of your EU country or origin, the GDPR considers what was previously termed the right “to forget” or request deletion of your data once you cease using a application or site. This tenant of the GDPR may conflict with applicable medical records retention laws. In the United States, this requires at least seven years of retention, which is common around the world and is sometime up to ten years or more in certain countries. So, unlike some data platforms, Reviving Mind cannot erase private health data directly upon a Client’s request, as it may be considered essential for other medical file retention purposes. Applicable individual country medical retention laws are generally considered an acceptable exception to the GDPR regulations regarding the right to deletion of certain data.

Privacy Disputes

You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Statement or www.revivingmind.com exclusively in a state or federal court located Delaware. The laws of the State of Delaware will govern this Statement, as well as any claim that might arise between you and us, without regard to conflict of law provisions.If anyone brings a claim against us related to your actions, content or information on www.revivingmind.com, you will indemnify and hold us harmless from and against all damages, losses, and expenses of any kind (including reasonable legal fees and costs) related to such claim.

Social Networks and Reviving Mind

These services allow the web site to access the data on your profile in the social networks, and to interact through your post. These services are not activated automatically but require express authorization by the User. Reviving Mind Users can share information and Data supplied to this Site with the social networks with which the User is registered, accepting their privacy policy. Facebook social buttons/widgets (Facebook) Facebook Social button is a service run by Facebook Inc., a company that complies with the “Safe Harbor” Privacy Policy Framework initiative, guaranteeing the handling of Personal Data.Twitter is managed by Twitter, a company that complies with the “Safe Harbor” Privacy Policy Framework initiative, guaranteeing the handling of Personal Information.

Final Words from Reviving Mind
We try to keep www.revivingmind.com safe, but you use it at your own risk. Further, your participation in any Group Therapy Session is strictly covered by this Privacy Policy and our Terms and Conditions. We are providing www.revivingmind.com “As Is” without any express or implied warranties. We do not guarantee that www.revivingmind.com will be safe or secure. www.revivingmind.com is not responsible for the actions, content, information, or data of third parties, and you release us, our directors, officers, employees, and agents from any claims and damages, known and unknown, arising out of or in any way connected with any claim you have against any such third parties.

We strive to create a global community with consistent standards for everyone, but we also strive to respect local laws. You consent to having your personal data transferred to and processed in the United States. If you are in a country embargoed by the United States or are on the U.S. Treasury Department’s list of Specially Designated Nationals, you will not engage in commercial activities on www.revivingmind.com (such as advertising or payments). By content we mean anything you post on www.revivingmind.com that would not be included in the definition of information. By data we mean content and information that third parties can retrieve from www.revivingmind.comor provide to www.revivingmind.com through Platform. By post we mean post on www.revivingmind.com or otherwise make available to us (such as by using an application). By use we mean use, copy, publicly perform or display, distribute, modify, translate, and/or create derivative works.

www.revivingmind.com openly volunteers its practices of collecting information, its targeting capabilities, and its use of cookies. If you have any questions pertaining to this privacy policy and its contents, please direct your correspondence to www.revivingmind.com at the “contact us” link on the website.

Understand, that we treat your use of our platform with the utmost respect to your privacy. We keep all information not disclosed above private between the Therapist and the User, keeping only non-decimated “file” copies for reference in case of legal dispute of by court order as we are required to under Federal Laws for period up to seven years or by the applicable State Regulation. File retention protects both the User and the Therapists safety. Reviving Mind is not responsible for data lost/exposed/used due to the nature of the Internet and digital environments, including illegal actions of hackers and criminals, technical malfunctions of servers and database etc. These are the accepted risks of our Users and users of the Internet in general. You are agreeing to this standard in using our site.

Reviving Mind reserves the right to amend this Privacy Statement at any time without notice, and only the current Privacy Statement may be deemed effective. Regardless of later updates or changes to our privacy notice, we will never use the information you submit under our current privacy notice in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.

CONTACT US
Reviving Mind Labs, Inc.
Data Protection Officer
651 N Broad St, Suite 206 Middletown, DE 19709
Email:  hello@revivingmind.com

Last Updated: May 19, 2020
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