We are Living Solutions Counseling; a company focused on helping people feel emotionally healthy at work and at home. As a provider of mental health services that connects employees and their dependents with effective and convenient care for their mental and emotional well-being, we combine technology, research-backed therapeutic methods, and top support providers such as coaches and therapists (“Providers”) to offer personalized care. 

1. SCOPE 

General Scope. This Privacy Policy (“Policy”) describes how LSC uses, and discloses personal information collected via our Provider Portal (TEBRA), our mobile applications, sessions with LSC Providers, our events, and any other online or offline offering of ours that posts this Policy (collectively, the “Services”). If you do not agree with our privacy practices, please do not provide us with personal information, use our Services, or access our website. 

Definition of “LSC” within the United States. In the United States, we work to deliver and facilitate coaching and clinical services, for services delivered in the United States. 

Outside of the United States. Outside of the United States, LSC does not offer services  outside of the United States. 

Jurisdiction-Specific Disclosures. If you are located or reside in any of the following  jurisdictions, please see the Jurisdiction-Specific Disclosures linked directly below or  shown at the end of this Policy for additional information related to rights you may have  under the applicable privacy laws of your jurisdiction and disclosures required by the  privacy laws of particular jurisdictions. Note the remainder of this Privacy Policy applies to  all jurisdictions. 

• If you are in the United States and receive clinical services via our Services: See our  HIPAA Notice of Privacy Practices for how LSC and our Providers specifically use  and disclose Protected Health Information (“PHI”). 

• If you reside in California, please see our Supplemental Notice for California  Residents at Section 13. 

Additional Policies from Providers. Some Providers may have additional Privacy Policies  or Informed Consent documents that describe their data practices; see those documents  for more information on how your Provider may use your personal information during care. 

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us or  use our Services and the requirements of applicable law. We collect information that you  provide to us, information we obtain automatically when you use our Services, information  from other sources such as your Health Savings Plan, and/or Insurance company as  described below. 

CLIENTS 

Registering as a LSC Client. If you register as a LSC client, we may collect information  from you including your name, postal address, location, email address, phone number,  username, password, demographic information (such as your gender and date of birth, as  well as race, ethnicity, religious affiliations, sexual orientation and/or pronouns if you  choose to disclose such information), information about your mood, mental or physical  health, or emotional state, as well as other information you directly give us through the  Services. 

Using LSC Services. Depending on the LSC Services you use, you may be asked to  complete additional forms (e.g. intake form, initial assessment, Consent for Therapy)  which may ask for personal information such as your name, contact information,  information about your current or historical health or mental health and treatment, and  information on your lifestyle. 

Communicating with Us. If you communicate with us by email, phone, text, chat, or within  our Tebra, we will collect personal information from you, such as your name, contact  information, and information you provide within your communication to us. If you are a LSC client, you have the option of using our secure electronic communication portal as  described in Section 4 of this Policy. Note that calls to LSC’s Care Team may be recorded. 

Surveys. We may periodically send you optional surveys to collect your feedback on your  experience with LSC. Understanding outcomes is central to our mission of providing  effective, evidence-based care, and data can help inform LSC’s approach to treatment and  assessment of progress. 

ALL SERVICE USERS 

Information We Get from Interactive Features. We may collect personal information that  you submit or make available through our interactive features (e.g., messaging and chat  features, commenting functionalities, forums, blogs, and social media pages). Any  personal information you elect to make publicly available on our Services, such as posting  comments on our blog page, will be available to others. Any information you provide on the 

public sections of these features will be considered “public”, unless otherwise required by  applicable law, and is not subject to all of the privacy protections referenced herein. 

Information We Get from Others. We may get information about you from other sources,  such as your Benefit Sponsor, third-party care payors or other third parties who may be  involved with your care. For example, LSC may collect demographic information, such as  your name and telephone number, from a friend, colleague or relative who refers you to  LSC for Services. 

We may combine the information that we collect with data obtained from third parties or  through our products and Services. Additionally, you may also be able to access your LSC account by signing on through various third-party services, such as Google. Signing on  through such third-party services is voluntary. If you choose to sign on through a third-party  service, LSC may collect certain information from your account including your public  profile, user name, email address, birthday, stated location, city, contact lists, and other  interactions on that platform (such as interests and likes). The information we may have  access to will vary by platform and is controlled by your privacy settings and account  settings on that platform. Your use of services on third-party platforms are governed by the  privacy statement and other terms of use for that third-party platform, until such  information is disclosed to us, and then such information is also subject to this Policy.  Please note that you should obtain necessary consents before providing us with personal  information regarding another individual. 

Providers Information Automatically Collected. We automatically log information about  you and your computer, phone, tablet, or other devices you use to access the Services. In  particular, when visiting the Services, we log your computer or device identification,  operating system type, browser type, browser language, the website you visited before  browsing to our website, pages you viewed, how long you spent on a page, access times,  and information about your use of and actions on the Services. How much of this  information we collect depends on the type and settings of the device you use to access  the Services. 

Cookies. We, as well as third parties that provide content, advertising, or other  functionality on the Services, may log information using cookies, pixel tags, web server  logs, web beacons, and other technologies (“Technologies”) to automatically collect  information through your use of our Services. This information is collected to make the  Services more useful to you and to tailor the experience with us to meet your special  interests and needs. Note that advertising technologies are not used on sites where clients  login to access our services and/or search for care, they are only used on LSC’s website.

• Cookies. Cookies are small data files stored on your hard drive by a website. We  may use both session cookies (which expire once you close your web browser) and  persistent cookies (which stay on your computer until you delete them) to provide  you with a more personal and interactive experience on the Services. 

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of  code embedded in the Services that collects information about engagement on the  Services. The use of a pixel tag allows us to record, for example, that a user has  visited a particular webpage or clicked on a particular advertisement. We may also  include web beacons in e-mails to understand whether messages have been  opened, acted on, or forwarded. 

Our uses of these Technologies fall into the following general categories: 

• Operationally Necessary. This includes Technologies that allow you access to the  Services, applications, and tools that are required to identify irregular website  behavior, prevent fraudulent activity, and improve security or that allow you to make  use of our functionality. 

• Performance-Related. We may use Technologies to assess the performance of the  Services, including as part of our analytics practices to help us understand how  individuals use the Services (see Analytics below). 

• Functionality-Related. We may use Technologies that allow us to offer you  enhanced functionality when accessing or using the Services. This may include  identifying you when you sign into the Services or keeping track of your specified  preferences, interests, or past items viewed. 

• Advertising or Targeting-Related. We may use first-party or third-party  Technologies to deliver content, including ads relevant to your interests, on LSC  website. 

Note that advertising technologies are not used on sites where clients login to access our  services and/or search for care, they are only used on LSC’s website. 

Analytics. We may use Technologies and other third-party tools to process analytics  information on the Services. Some of our analytics partners include: 

• Google Analytics. For more information, please visit Google Analytics’ Privacy  Policy. To learn more about how to opt-out of Google Analytics’ use of your  information, please click here.

Social Media Platforms. The Services may contain buttons to social media platforms such  as Twitter, Facebook and LinkedIn (that might include widgets such as the “share this”  button or other interactive mini programs). These features may collect your IP address,  which page you are visiting on the Services, and may set a cookie to enable the feature to  function properly. Your interactions with these platforms are governed by the privacy policy  of the company providing the widget.  

3. USE OF PERSONAL INFORMATION 

How we use the information we collect depends in part on which Services you use, how  you use them, and any preferences you have communicated to us. Below are the purposes  for which we use the information we collect about you. 

To provide and secure the Services and personalize your experience: We use  information about you to provide the Services to you, including to: 

• Help establish and verify the identity and eligibility of users; 

• Conduct outreach to potential clients if they are referred to LSC by a friend,  colleague, or relative. 

• Open, maintain, administer, and manage profiles and accounts for registered users; 

• Recommend Providers and Services that may be a good fit for you, including using  artificial intelligence to assist in the identification of potential providers and/or  treatment suggestions for you, based on your responses to intake questions and  other information collected about you; 

• Provide notifications and reminders that are relevant for you, including using  automation tools (such as to notify you of an action that your provider has  recommended, or to remind you of upcoming appointments); 

• Provide you with customized products, Services, content, offers, or materials; 

• Provide, deliver, operate and maintain the Services and other products and services  that you request, including those from our selected partners; 

• Respond to comments and questions and provide customer service or technical  support; 

• Process applications to become a LSC Provider; 

• Allow you to register for events;

• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal  activity, and prosecute those responsible for that activity; 

• Ensure internal quality control and safety; 

• Debug or identify and repair errors with the Services; 

• Audit interactions, transactions and other compliance activities; 

• Enable our providers to complete manual, administrative, and/or routine tasks more  effectively, with the help of automated conversation notes and summaries, for  provider review, and other tools powered by artificial intelligence; 

• Communicate with you about your account, including confirmations, notices,  notifications, updates, security alerts, and support and administrative messages. If  you are communicating with LSC about your care, these communications may  contain medical information. 

Understand and improve our Services, provided the agreement we have with your  employer permits use of personal information for this purpose, such as to: 

• Measure and understand engagement with the Services; 

• Research and develop products, Services, marketing, or internal processes; • Short-term, transient use, such as contextual customization of ads; • Improve, repair, upgrade, or enhance the Services. 

To protect our legitimate business interests and legal rights, such as to: • Enforce our agreements and policies; 

• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal  activity, and prosecute those responsible for that activity; 

• Ensure internal quality control and safety; 

• Protect your safety or vital interests, or the safety or vital interests of others; and • Comply with our legal obligations. 

With your consent: We may use information about you in other ways or for other purposes,  where you have given us consent to do so for a specific purpose not listed above. 

De-identified and Aggregated Information: We may use personal information and other  information about you to create de-identified and/or aggregated information, such as de-

identified demographic information, location information, information about the device  from which you access the Services, or other data sets we may create. In some cases, we  use aggregated, de-identified clinical data to provide our customers with insight into how  their employees are using our Services, without identifying you personally. We will use de identified information as part of our machine learning and artificial intelligence initiatives to  improve our services. Non-personally identifiable information may be stored indefinitely. 

4. DISCLOSURES OF PERSONAL INFORMATION 

We only disclose your information to third parties as described below. 

Your Providers. If you seek care, treatment or other services from a Provider available  through the Services, your Provider will have access to the personal information that you  have provided through your completed intake form and initial assessment in order to  provide you with their services. If you switch Providers, we may disclose your personal  information to your new Provider to facilitate a consistent care experience. 

Service Providers. We disclose your personal information to our third-party service  providers, such as IT and related services, payment processors, customer service  providers, and other vendors that support our provision of the Services. These service  providers will be subject to contractual obligations to implement appropriate technical and  organizational security measures to safeguard the personal data, and to process the  personal data only as instructed. 

Disclosures to Protect Us and Others: We may access, preserve, and disclose any  information we store associated with you to external parties if we, in good faith, believe  doing so is required or appropriate: to comply with law enforcement or national security  requests and legal process, such as a court order or subpoena; when required by health  oversight agencies for legally authorized health oversight activities; to protect your, our or  others’ rights, property, or safety, including to protect the security or integrity of the  Services and any facilities or equipment used to make the Services available; to enforce  our policies or contracts; to collect amounts owed to us or any LSC Provider; or to assist  with an investigation or prosecution of suspected or actual illegal activity or in an  emergency. 

What Happens in the Event of a Change of Control: We may buy or sell/divest/transfer  our company (including any shares in the company), or any combination of its products,  services, assets and/or businesses. We may also sell, assign, or otherwise transfer such  information in the course of corporate divestitures, mergers, acquisitions, bankruptcies,  dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all 

or a portion of LSC. Your information such as names and email addresses, and other  information related to the Services may be among the items transferred in these types of  transactions. 

5. SECURITY OF PERSONAL INFORMATION 

We are committed to protecting your privacy and data. We have taken steps to implement  safeguards and security measures to help prevent your personal information from being  lost, used or accessed in an unauthorized way, altered or disclosed. However, no method  of transmission over the Internet or method of electronic storage is 100% secure.  Therefore, we cannot guarantee its security. If you have any questions about the security of  the Services, you can contact us as described below. 

Any text, email or other transmission you send unencrypted through the Internet cannot be  completely protected against unauthorized interception. In particular, we want to make you  aware that personal email may be unsecure. You are not required to authorize the use of  your personal email for purposes of communicating with LSC; a decision not to consent or  to opt out of receiving these emails will not restrict your ability to access care from your  Provider. You can choose to receive email from LSC using our secure electronic  communication system instead of your personal email. Our secure electronic  communication system will require you to log into a separate portal to access the email  that is being sent. 

6. DATA RETENTION 

We retain personal information pursuant to statutory requirements, for as long as needed  to provide the Services or fulfill the purpose for which it was collected, and to comply with  our legal and compliance obligations (including auditing), resolve potential or actual  disputes, conduct research and development for the Services (provided the agreement we  have with your employer permits use of personal information for this purpose), or enforce  our agreements. 

7. INTERNATIONAL DATA TRANSFER 

By using the Services, your personal information will be stored within the United States,  where privacy rules differ and may be less stringent than those of the country in which you  reside. 

8. THIRD-PARTY WEBSITES/APPLICATIONS 

The Services may contain links to other websites/applications and other  websites/applications may reference or link to our Services. These third-party 

services/applications are not controlled by us. We encourage our users to read the privacy  notices and policies of each website and application with which they interact. 

9. CHILDREN 

LSC’s teletherapy services are not directed to children under 13 (or other age as required by  local law), and we do not knowingly collect or maintain the personal information shared by  children under 13. 

If you believe that LSC has inappropriately received information about a child under the age  of 13, please contact us as described below. If we become aware that a child has provided  us with personal information in violation of applicable law, we will delete any personal  information we have collected, unless we have a legal obligation to keep it, and terminate  the child’s account if applicable. 

10. YOUR PRIVACY CHOICES AND RIGHTS 

Your Privacy Choices. You have a number of choices you can make regarding your  personal information, including as follows: 

Email Communications. If you receive an unwanted email from us, you can use the  unsubscribe link found at the bottom of the email to opt out of receiving future emails.  Note that you will continue to receive transaction-related emails regarding products or  Services you have requested. We may also send you certain non-promotional  communications regarding us and the Services, and you will not be able to opt out of those  communications (e.g., communications regarding the Services or updates to our Terms or  this Privacy Policy). 

Text Messages. You may opt out of receiving text messages from us at any time by  following the instructions in the text message/replying “STOP” to a text message you have  received from us, by updating your communications preferences within your LSC profile, or  by contacting us as described below. 

Mobile Devices. We may send you push notifications through our mobile application. You  may opt out from receiving these push notifications by changing the settings on your  mobile device. 

Your Privacy Rights. In accordance with applicable law, you may have the right to: 

Access Personal Information about you, including: (i) confirming whether we are  processing your personal information; (ii) obtaining access to or receiving a copy of your  personal information; and (iii) receiving an electronic copy of personal information that you 

have provided to us, or (iv) asking us to send that information to another company (the  “right of data portability”); 

Request Correction of your personal information where it is inaccurate or incomplete. In  some cases, we may provide self-service tools that enable you to update your personal  information; 

Request Deletion of your personal information; 

Request Restriction of or Object to our processing of your personal information; and  Withdraw your Consent to our processing of your personal information. 

You may submit requests regarding your personal information by emailing  support@livingsolutionscounseling.com. If you have such rights and your request complies  with applicable legal requirements, we will give effect to your rights and respond within any  mandatory timeframes as required by law. 

11. CHANGES TO THIS PRIVACY POLICY 

We may change this Policy and our privacy practices, so please check this page  occasionally. If we make any changes, we will change the Last Updated date above and/or  notify you or seek your consent as required by applicable law.