Privacy Policy for Greenfeld and Smith Ventures, LLC Mobile Applications

This privacy policy governs your use of the software application nOCD (“Application”) for mobile devices that was created by Greenfeld and Smith Ventures, LLC. The Application is a mobile app where users with clinical Obsessive Compulsive Disorder (“OCD”) can 1) Access customizable on-the-go coaching during episodes, 2) Take progress benchmarking self-assessments, 3) Organize and execute specific “Exposure Response Prevention” exercises, and 4) Store, view, and share data collected by the app.

User Provided Information

The Application obtains the information you provide when you download and register the Application. Registration with us is optional. However, please keep in mind that you may not be able to use some of the features offered by the Application unless you register with us.

When you register with us and use the Application, you generally provide (a) your name, email address, phone number, age, IP address, current location, user name, password and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you contact us for help; (d) credit card information for purchase and use of the Application, (e) information you enter into our system when using the Application, such as contact information and project management. The User will also provide episode themes, triggers, types, location, intensity, time spent using the Application, time spent on each exposure, accountability and information collected when a User completes a clinical survey regarding their OCD.

We may also use the information you provided us to contact you from time to time to provide you with important information, required notices and marketing promotions. Automatically Collected Information

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application. The Application does collect precise information about the location of your mobile device, with the user’s active consent during each location gathering event. You will be asked upon the first launching of the Application if you would like to enable precise geo-location sharing information for the purposes of a more customized experience. You may be asked to share your precise geo-location information with us so we can customize your experience. This includes instances when we work with a third party (such as your doctor), plan exercises to be completed at a specific location, and access other treatment related data collection. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application. Additionally, the Application will keep a record of other metrics gathered during use. This includes: Metametrics about the time spent and usage of the actual Application, frequency of episodes and “homework,” the subject of a user’s obsessions, compulsions, and triggers, accountability in completion of “homework” sessions, the user’s anxiety during both “homework” sessions and during episodes, and the nature of the OCD episode, if that nature is an obsession, a compulsion, or the user is unsure.

How You Can Access or Correct Information

Access to certain personal information that is collected from our Application and that we maintain may be available to you. For example, if you created a password-protected account within our Application, you can access that account to review the information you provided. You may also send an e-mail to info@nOCDhelp.com requesting access to or correction of your personal information. Please include your registration information such as first name, last name and e-mail address in the request. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.

Third Party Access To Information Obtained By The Application

A summarized report of the User’s data can be sent to a Third Party if the User wishes, including therapists, doctors, family members, or otherwise. This data is only shared with the active consent of the User, who has to manually type in and submit the information over email to the Third Party the User chooses. Additionally, if the recipient of the email manually connects their account with our therapist website, information will be sent directly to that therapist’s profile through a secure, HIPAA compliant connection.

Only aggregated, anonymized data is periodically transmitted to external services to help us improve the Application and our service. We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose User Provided and Automatically Collected Information:

  • as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure with third parties is necessary in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Application, or violations of our policies, the law or our Terms of Use, to verify or enforce compliance with the policies governing our Service
  • with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
  • if Greenfeld and Smith Ventures, LLC is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

HIPPA Compliance

The Application has secure access to Protected Health Information (“PHI”) via unique user authentication. All data received is encrypted when stored and when in transit. Greenfeld and Smith Ventures, LLC will implement regular safety updates to protect the user from any breaches. The Application has a system to audit the data and ensure that it hasn’t been accessed or modified in any unauthorized way. The data on the Application can be wiped out entirely by deleting the app. You will be asked if you wish to keep your data, and you can select “No.” The Application is equipped with a mobile wipe out option that allows PHI to be wiped if the device is lost. (If your device is lost, go on to our website at www.treatmyocd.com, or email the Company at info@nOCDhelp.com to send us a message, and we’ll delete the account). Moreover, the Application has a data backup in case of a device loss, failure, or other disaster. The Application uses the HIPAA-compliant hosting provider, Amazon Web Services, which has signed a Business Associate Agreement. Greenfeld and Smith Ventures, LLC has ensured HIPPA compliance by:

  • putting safeguards in place to protect patient health info
  • reasonably limiting use and sharing to the minimum necessary to accomplish the intended purpose having agreements in place (BAA) with service provider that perform covered functions (Amazon) creating procedures to limit who can access patient health info, and training programs about how to protect patient health info

What Are My Opt-Out Rights?

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at info@nOCDhelp.com

How To Contact Us/Opting Out

If you have any questions or concerns about the online Privacy Policy for this Service or its implementation, or if you would like to opt out from our sharing of your personal information with your third party, you may contact our Privacy Policy Coordinator at info@nOCDhelp.com and request that we opt you out of such sharing. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account. If you have signed up to receive text messages from us and no longer wish to receive such messages, you may follow the instructions to stop the delivery of such messages, which may include by replying “Stop” to the received text message.

Data Retention Policy, Managing Your Information

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. After a User stops using the Application, we will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the Application sooner, please contact us at info@nOCDhelp.com and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

Children

If you are under the age eightteen, you must ask your parent or guardian for permission to use this Application. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info@nOCDhelp.com. We will delete such information from our files within a reasonable time. If a parent or guardian consents to the collection of the child’s information, the parents will have access to the child’s personal information to review and/or have the information deleted. We will maintain the confidentiality, security, and integrity of information collected from children, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security. The child will not be required to disclose more information than is reasonably necessary to participate in an activity. The child’s personal information collected will be retained only as long as needed to fulfill the purpose for which it was collected and will be deleted using reasonable measures to protect against its unauthorized access or use.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy.

Your Consent

By using this Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information.

International Transfer

This Application is governed by and operated in accordance with United States law. If you are located outside of the United States, you use this Application at your own risk. Greenfeld and Smith Ventures, LLC operates globally so it is necessary to transfer your information internationally. In particular, your information will be transferred to and processed in the United States where our central database operates. By using this Application, you acknowledge that the data protection and other laws of other countries, such as the United States, may provide a less comprehensive or protective standard of protection than those in your country, and consent to your information being collected, processed and transferred as set forth in this Privacy Policy and United States law.

Updates & Contact us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at info@nOCDhelp.com. From time to time, we may update this Privacy Policy. We will notify you about material changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our Application. We encourage you to periodically check back and review this policy so that you always will know what information we collect, how we use it, and with whom we share it.