Better Therapeutics Privacy Policy

Last Updated September 8, 2023

Through its website, mobile application products, services, events and any interactive features, applications or other services (the “Platform”), Better Therapeutics, Inc. (“Better Therapeutics,” “we,” “us,” or “our”) provides cognitive behavioral therapy treatment program(s). Better Therapeutics provides information about the cognitive behavioral therapy treatment program(s) through its Platform and is collectively referred to in this Privacy Policy as the “Service.” This Privacy Policy explains what Personal Data (defined below) we collect in connection with our operation of the Platform, how we use and share that data, and your choices concerning our data practices.

Before using the Platform or submitting any Personal Data to Better Therapeutics, please review this Privacy Policy carefully and contact us at privacy@bettertx.com if you have any questions. By using the Platform, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Platform.

1. PERSONAL DATA WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

Personal Data Processed on Behalf of Customers: We collect and analyze Personal Data on behalf of and subject to the instructions of our health care provider and health plan customers (“Customers”) as specified in our Terms of Service and other agreements with our Customers. Some of this Personal Data may be subject to health information privacy laws and regulations, such as rules issued under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH) (the “HIPAA Rules”), that govern providers’ use and disclosure of certain individually identifiable health-related Personal Data (“Protected Health Information”). When we receive Protected Health Information, we may do so as a “Business Associate” of a Customer under an agreement that, among other things, prohibits us from using or disclosing the Protected Health Information in ways that are not permissible by the Customer itself, and requires us to implement certain measures to safeguard the confidentiality, integrity, and availability of the Protected Health Information. When we act as a Business Associate, we may be subject to certain laws and regulations, including certain HIPAA rules (https://www.hhs.gov/hipaa/for-individuals/faq/index.html), that govern our use and disclosure of Protected Health Information and that may be more restrictive than otherwise provided in this Privacy Policy.

Personal Data You Provide: We collect Personal Data when you set up your account, use the Platform, provide Personal Data through the Platform, or communicate with us. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include your name, email, password, date of birth, sex, height, weight, ethnicity, and zip code. In order to provide the Platform, we will also collect information related to your medical diagnosis, any prescribed medications you take, information related to your eating and exercise habits, lab test results, blood pressure readings, information contained in any medical records you elect to upload to the Platform, and other information you share with us through the Platform, including information shared with your health coach and information shared in the App. With your permission, we may also collect your location information in order to identify doctors in your area.

Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Facebook, Pinterest, Instagram, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us through your settings with the Social Media Page, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Personal Data We Receive Automatically From Your Use of the Platform: When you download, visit, use and interact with the Platform, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Platform, peak hours of visits, which page(s) are visited, the length of App sessions, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Platform (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

  • Log data: Information that your browser automatically sends whenever you visit the Site (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
  • Cookies: Please see the “Cookies” section below to learn more about how we use cookies.
  • Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Information: We collect information about how you use our Platform, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it) and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). By using the Platform, you consent to our use of cookies and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Platform. For more details on cookies please visit All About Cookies.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). ”). Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Online Tracking and Do Not Track Signals: We and our third-party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may collect Personal Data through cookies. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at https://thenai.org/ and follow the opt-out instructions there. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

2. HOW WE USE PERSONAL DATA

We may use Personal Data for the following purposes:

  • To make the Platform available to you;
  • To respond to your inquiries, comments, feedback or questions;
  • To send administrative information to you, for example, information regarding the Platform, and changes to our terms, conditions, and policies;
  • To analyze how you interact with our Platform;
  • To maintain and improve the content and functionality of the Platform;
  • To develop new products and services;
  • To prevent fraud, criminal activity, or misuses of our Platform, and to ensure the security of our IT systems, architecture and networks; and
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.

Aggregated Information. We may aggregate Personal Data and use the aggregated information to perform research, publish works of scholarship, analyze the effectiveness of our Platform, to improve and add features to our Platform, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Platforms and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Platform, through cookies, and through other means described in this Privacy Policy.

Consent. We may use your Personal Data for other purposes with your explicit consent.

3. SHARING AND DISCLOSURE OF PERSONAL DATA

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

  • At Your Direction: We may share your Protected Health Information and other Personal Data with the Customers through whom you signed up for the Platform. You can also make your Personal Data available to family, friends or other caregivers. We will not sell or rent your Personal Data or Protected Health Information to anyone, except if done in connection with a merger, acquisition, reorganization or sale of all or substantially all of our assets (as noted below regarding Business Transfers).
  • As Permitted by Law: We may disclose Personal Data, including Protected Health Information, if we believe it is necessary to investigate potential violations of our Terms of Use, or to enforce those Terms of Use. We will also share, use and disclose PHI as permitted by HIPAA, including sharing your PHI with your health care provider for treatment, payment, or operational purposes.
  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, connected device manufacturers, email communication software, payment processors, customer relationship management and customer support services, biomarker testing laboratories, and web analytics services (for more details on the third parties that place cookies through the Site, please see the “Cookies” section above). Pursuant to our instructions, these parties will access, process or store Personal Data while performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the Security standards we apply to your Personal Data.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: We may share your Personal Data and if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Platform, or the public, or (v) protect against legal liability.

4. DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is the longer.

5. UPDATE YOUR INFORMATION

Please log in to your account or contact us at privacy@bettertx.com if you need to change or correct your Personal Data.

6. CHILDREN'S PRIVACY

We are committed to complying with the Children’s Online Privacy Protection Act (COPPA). Our Platform is not directed to children who are under the age of 18. Better Therapeutics does not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to Better Therapeutics through the Platform, please contact us at privacy@bettertx.com and we will endeavor to delete that information from our databases. If we receive personal information that we discover was provided by a child under the age of 18, we will promptly destroy such information. Schools and parents should supervise their children’s online activities and consider the use of other means to provide a child-friendly online environment. Additional information is available on the Direct Marketing Association’s home page at http://www.the-dma.org. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.

7. LINKS TO OTHER SITES

The Platform may contain links to other websites not operated or controlled by Better Therapeutics, including social media services (“Third-Party Sites”). The information that you share with Third-Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third-Party Sites directly for information on their privacy practices and policies. If you decide to access any of the Third-Party Sites listed on or linked to from the Platform, you should understand that you do so at your own risk.

8. SECURITY

You use the Platform at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be completely secure. Therefore, you should take special care in deciding what information you send to us via the Platform or e-mail. Please keep this in mind when disclosing any Personal Data to Better Therapeutics via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Platform, or third-party websites.

9. YOUR CHOICES

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Platform, you may be unable to use those features. You can also contact us at privacy@bettertx.com to ask us to update or correct your Personal Data.

Better Therapeutics takes appropriate steps to avoid unauthorized changes to personal information you submit to the Platform. For so long as we elect to continue to provide the Platform, and provided that you comply with all agreements concerning use of these sites, we will make all reasonable efforts to provide you with online access to your registration data and other personal information so that you may view, update or correct it.

You may opt out of receiving marketing and market research communications at any time by using the unsubscribe links provided or by contacting us at privacy@bettertx.com. You may also change your preferences regarding the communications you receive from us here.

10. CONTACTS, RIGHTS

In certain circumstances, subject to certain exceptions and applicable law, you may have the following rights in relation to personal information about you:

  • the right to know: (i) the specific pieces of personal information collected; (ii) the categories of personal information; (iii) the categories of sources of the personal information; (iv) the business or commercial purpose for collecting the personal information; (v) the categories of personal information disclosed for a business purpose; and (vi) the categories of third parties with whom the personal information is shared;
  • the right to have personal information corrected, for example if it is incomplete or incorrect;
  • the right to opt out of receiving marketing communications at any time;
  • the right to request that personal information is deleted;
  • the right to restrict or object to the processing of personal information;
  • the right to receive a copy of personal information which you have provided to the firm, in a structured, commonly used and machine-readable format (known as “data portability”);
  • where you have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw your consent;
  • the right not to be discriminated against if you exercise any rights conferred on you by the California Consumer Privacy Act of 2018; and
  • the right to complain to a Data Protection Authority (see further below).

If you have an online account, you may access, update, and correct your personal information – including your marketing choices – using the account management facilities. You may also opt out of receiving marketing and market research communications at any time by contacting us at privacy@bettertx.com.

11. YOUR CALIFORNIA PRIVACY RIGHTS

As described above, Better Therapeutics collects certain types of Personal Data about you during your relationship with us. Under California law, if you are a resident of California, you have the right to request certain information that we collect about you, including:

  1. The categories of personal information we have collected from you;
  2. The categories of sources from which we collected the personal information;
  3. The business purpose we have for collecting or selling that personal information;
  4. The categories of third parties with whom we share such personal information; and
  5. The specific pieces of personal information we have collected about you.

In addition, if we sold or disclosed your personal information for a business purpose, you may request that we provide you with:

  1. The categories of personal information that we sold about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the information was sold; or if we have not sold consumers’ personal information; and
  2. The categories of personal information that we have disclosed about you for a business purpose, and the categories of third parties to whom the personal information was disclosed, by category or categories of personal information for each category of third parties to whom the information was disclosed; or if we have not disclosed consumers’ personal information for a business purpose.

As a California resident, you also have the right, at any time, to tell us not to sell personal information – this is called the “right to opt-out” of the sale of personal information. You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

To exercise the access, data portability, Do Not Sell, and deletion rights described in this section, please submit a verifiable consumer request to us by calling or emailing us with your request at the contact information below. Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You must include your full name, email address, and attest to the fact that you are a California resident by including a California postal address in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in California in order to obtain the information, and you are only entitled to make this request twice a year. We will respond to your request within 45 days or let you know if we need additional time.

Please provide a description of the right(s) you want to exercise and the information to which your request relates to:

  • Toll-Free Number for California Privacy Requests: (888) 277-9731
  • Email Address: privacy@bettertx.com

We may be unable to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

12. CHANGES TO YOUR PRIVACY POLICY

The Platform, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Platform and/or providing us with Personal Data, in each case, after we have posted an updated Privacy Policy or have otherwise notified you by other means, you consent to the revised Privacy Policy and practices described in it.

13. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at privacy@bettertx.com