Privacy Policy

Welcome to Thrive

Thrive™ combines powerful self-help techniques, best practices from the world of cognitive behavior therapy, and technology to assist you in creating a customized plan that helps put you in control of your life. Thrive is operated by Waypoint Health Innovations, LLC, a Wisconsin limited liability company. In this Privacy Policy, “Waypoint”, “we”, “us”, or “our” means Waypoint Health Innovations, LLC.

We are committed to respecting your privacy. Because facts about a person’s health, health interests and health care are private and sensitive, we know that you may have concerns about sharing information with us.

Your use of Thrive is subject to the terms of this Privacy Policy. We urge all Thrive users to read this Privacy Policy to learn more about the policies and practices that we have developed to safeguard your information, and to better understand our relationships with third parties who may have access to this information.

Thrive is intended for the exclusive use of registered users who are residents of the United States of America. The type of information Thrive collects, the manner in which it is collected, and the specified uses of the collected information may not be legal in certain countries outside of the United States. Because of these various laws, regulations, and medical practices, information designated to be used in one country may not be approved for use outside of that country.

Therefore, the collection of information by Thrive may not be appropriate for residents of other countries. THRIVE IS DESIGNED TO COMPLY WITH THE LAWS AND REGULATIONS OF THE UNITED STATES ONLY. Nothing on Thrive should be considered a solicitation or promotion of any product or an indication for any product that is not permitted by the laws or regulations of the country where the user of the product resides.

1. Your Healthcare Provider

This Privacy Policy uses the term “Healthcare Provider”. In this Privacy Policy, your “Healthcare Provider” means the organization that recommended, provided, or provisioned Thrive to or for you. We allow your Healthcare Provider to see some information about your activity in Thrive so that your Healthcare Provider may better serve you or manage their relationship with you. For more information about what information we allow your Healthcare Provider to see, see the “Disclosure of Your Personal Information and Individually Identifiable Health Information” section below.

2. Information we collect

Although we collect information related to you and your health, you should never depend upon Waypoint, your Healthcare Provider, or any other party reading or analyzing such information to contact you or take any other action based on such information. If at any time you need medical attention, contact your physician or call 911.

If you choose to use Thrive, we collect the following information from you or about you.

Personal Information

Thrive stores your Personal Information. In this Privacy Policy, “Personal Information” means the following information:

• Email address: we use your email address as a user ID for logging into the site, to send you emails related to your use of Thrive, and to allow your Healthcare Provider to locate your account in Thrive.
• First name: we use your first name to address you on Thrive and in Thrive-related emails (for example, “Hello, John”).
• Case number: The case number is a number that your Healthcare Provider has given you to obtain access to Thrive. Your Healthcare Provider may use the case number to identify you in its own records. In the context of its own records, your Healthcare Provider may refer to the case number by a different term, such as “customer number” or “patient number”. We use the case number to identify you as a valid user of Thrive and to help your Healthcare Provider locate your account in Thrive.

If your Personal Information changes (such as email address), you can log into your account and change the appropriate information.

Assessment Scores

Assessments are questionnaires that are intended to measure the severity of symptoms of a disorder, the rate of symptom improvement, the extent to which a disorder is impacting the respondent’s life, or other similar measures. Since Thrive does not make diagnoses or other clinical evaluations, the assessments in Thrive are used solely to allow you to compare your assessment scores to the scores of other people.

Thrive gathers answers to each assessment question and uses those answers to create an overall score for that assessment. The overall score for an assessment is referred to as an “Assessment Score” in this Privacy Policy. Thrive stores your Assessment Scores, but does not store your answer to individual assessment questions, with the exception of assessments that contain only one question.

Usage Information

“Usage Information” is information about your interaction with Thrive and your inputs into Thrive, with the exception of Personal Information and Assessment Scores. Usage Information includes, but is not limited to, the pages that you visit, when you visit them, the items that you click on, and text that you input into Thrive. Thrive stores your Usage Information.

Individually Identifiable Health Information

In the context of this Privacy Policy, “Individually Identifiable Health Information” is a set of information that contains your Personal Information and either your Assessment Scores or Usage Information. Thrive generally does not store your Personal Information with your Assessment Scores or Usage Information. However, in very limited circumstances Thrive will join your Personal Information with your Assessment Scores and/or your Usage Information to create Individually Identifiable Health Information.

Since Individually Identifiable Health Information combines information related to your identity and information related to your health, we are very careful about how we use and share your Individually Identifiable Health Information. See the “Disclosure of Your Personal Information and Individually Identifiable Health Information” section below.

Internet Protocol (IP) Address

We record the Internet Protocol (IP) address of your computer when you visit Thrive. The IP address does not identify you personally, but it allows us to maintain communications with you as you move about Thrive.

Cookies

We also collect information about your use of Thrive through cookies and similar technologies. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and preferences and recognize you as a return visitor to Thrive. Cookie technology allows us to collect “clickstream” data, which is not personally identifying information, but which reflects your activities on Thrive. A cookie does not collect or keep your name or other personally identifying information, but when you revisit Thrive the cookie allows us to bring you the content and features likely to be of greatest interest to you based on your previous activities on Thrive.

3. Disclosure of your Personal Information and Individually Identifiable Health Information

We pledge that other than as disclosed in this Privacy Policy, we will not disclose your Personal Information or Individually Identifiable Health Information to a third party without your express permission.

Your Healthcare Provider: We may disclose your Personal Information and Individually Identifiable Health Information to your Healthcare Provider. Your Healthcare Provider is required to keep such information confidential in compliance with all legal requirements.

Waypoint may share the following information with your Healthcare Provider:

• Your email address, case number, and first name
• Your first login date, last login date, total number of logins, and derivations of such information (for example, the number of days since your last login)
• Your Assessment Scores, as shown in the Assessments section of Thrive under My Account, and in summary reports that convey the same information. Your Healthcare Provider may not see the answers to individual assessment questions (with the exception of assessments that contain only one question).
• Your progress through the site, including which pages you have accessed and the last date each page was accessed, as shown in the Progress section of Thrive under My Account, and in summary reports that convey the same information.

Waypoint will not share the following information with your Healthcare Provider:

• Answers to individual assessment questions (with the exception of assessments that contain only one question)
• Any text you input into Thrive (for example, your personalized negative thoughts), with the exception of your Personal Information
• Selections you make in the negative thought list and the pleasant activity list
• The specific answers you provide regarding your homework, including but not limited to the number of times a negative thought occurred, your distress rating for a negative thought, the number of times you communicated assertively, and the number of times you performed a particular activity. However, your Healthcare Provider may see whether or not you indicated that you completed such homework

Although we may share your Individually Identifiable Health Information with your Healthcare Provider, you should never depend upon your Healthcare Provider reading or analyzing such information or contacting you or taking any other action based on such information. If at any time you need medical attention, contact your physician or call 911.

Suppliers and Contractors: We use third parties to provide services to operate Thrive. These third parties may have access to and use Personal Information and Individually Identifiable Health Information to provide services on our behalf. If we allow a supplier or contractor to have access to your Personal Information and Individually Identifiable Health Information, they will only be permitted to take it or use it for purposes that are consistent with this Privacy Policy. All vendors and contractors are required to responsibly use your Personal Information and Individually Identifiable Health Information in an authorized manner and to comply with all legal requirements. Other than as described in this Privacy Policy, Waypoint will not disclose your Personal Information or Individually Identifiable Health Information to any supplier, contractor, or other third party for any purpose other than to operate Thrive.

Law Enforcement or Threats: In certain limited circumstances, we may be called upon to release your Personal Information or Individually Identifiable Health Information in response to a court order, subpoena, search warrant, law, regulation or other judicial or legal process or proceeding. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information or Individually Identifiable Health Information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior that is illegal or harmful to other users of Thrive.

Changes in Our Corporate Structure: If all or part of our company is sold, merged or otherwise transferred to another entity, your Personal Information or Individually Identifiable Health Information may be transferred as part of that transaction. Waypoint will take steps to assure that, without your consent, any Personal Information or Individually Identifiable Health Information that is transferred will not be used or shared in a manner inconsistent with this Privacy Policy under which it was collected.

4. Disclosure of Non-Individually Identifiable Health Information

“Non-Individually Identifiable Heath Information” is any set of information that includes your Assessment Scores and your Usage Information but does not include your Personal Information. For example, a set of information that includes data about which Thrive modules you use, how often you use them, how far you progressed in each module, and your Assessment Scores, but does not contain your email address, first name, or case number, is Non-Individually Identifiable Health Information. If someone has Non-Individually Identifiable Health Information but not Individually Identifiable Health Information, there is no reasonably possible method for that person to determine that the information refers to you.

We may share your Non-Individually Identifiable Health Information with third parties. When we do that, it will usually, but not always, be combined with the Non-Individually Identifiable Health Information of many other Thrive users. Since there is no reasonably possible method for such third party to determine to whom such information refers, we may not restrict how such third party uses such information or shares that information with others.

5. How we use your information Use of Personal Information and Individually Identifiable Health Information

Waypoint and your Healthcare Provider may use your Personal Information and Individually Identifiable Health Information for business, clinical, and operational purposes.

The purposes for which we may use your Personal Information and Individually Identifiable Health Information include, but are not limited to, the following:

• To analyze usage patterns to better design Thrive
• To determine which web page to direct you to or to otherwise personalize your experience on Thrive
• To determine the effectiveness of Thrive
• To determine when to send an email or other form of communication to you
• To determine what information to provide to you in such email or other communication
• To administer our business relationship with your Healthcare Provider
• To help your Healthcare Provider determine when to contact you or otherwise serve you better
• To help third parties support or operate Thrive.

The purposes for which your Healthcare Provider may use your Personal Information and Individually Identifiable Health Information include, but are not limited to, the following:

• To make decisions about contacting you
• To make decisions about managing your health care
• To make decisions about providing other services to you

Use of IP Address

In addition to using the IP address of your computer to maintain communications with you as you log into Thrive, we also use the IP address to track failed logins and password changes.

Use of Cookies

We may use the data that we obtain through the use of cookies to determine if you have logged in properly to Thrive and to track other activity on Thrive. We do not allow other sites or third parties to use our cookies for purposes other than to support or operate Thrive. We use the information collected through the use of cookies to track your progress through Thrive and for our business purposes, including operation of Thrive and research and product analysis.

6. Automated emails

Thrive will send you emails related to the management of your Thrive account. For example, you may receive emails from Thrive when you create your account or request a new password. Thrive will also send you emails that provide information, encouragement, and reminders related to Thrive. Thrive will never send you an email containing your Assessment Scores. By using Thrive you acknowledge that email is not a completely secure method of information transmission or storage, you agree to use all reasonable measures to prevent other people from accessing your email, and you assume all risk of another person intercepting or reading emails that Thrive has sent to you.

Waypoint will not share your email address with any third party for marketing or advertising purposes, nor will Waypoint use your email address for any purposes other than those directly related to your use of Thrive.

7. How we store and protect your information

Waypoint has adopted administrative, physical and technical security measures to protect your Personal Information and Individually Identifiable Health Information, and has contracted with third parties for the operation of Thrive that follow similar measures. However no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we and our suppliers and contractors use commercially reasonable and appropriate means to protect your Personal Information and Individually Identifiable Health Information, we cannot guarantee its absolute security.

Your Personal Information and password are stored in an encrypted manner. We use Secure Socket Layer ("SSL") to encrypt our website pages that collect Personal Information and Individually Identifiable Health Information from you (notice that the address bar starts with https: which indicates your connection is taking place via a secure server). We limit systems access to Personal Information and Individually Identifiable Health Information only to personnel who reasonably have a need to know this information to provide our services. We use firewalls to protect our networks.

Waypoint will not be responsible for any liability arising from you sharing your personal information, assessment scores, or usage information with others.

8. Changes to the Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please check this Privacy Policy periodically for changes. At the top of this Privacy Policy we indicate the date it was previously updated. The continued use of Thrive following the effective date of posted changes to this Privacy Policy will mean that you accept those changes.