Better Therapeutics Privacy Policy

Last Updated June 6, 2019

Through its mobile application (the “App”), Better Therapeutics, Inc. (“Better Therapeutics,” “we,” “us,” or “our”) provides a behavioral therapy program for cardiometabolic diseases (the “Program”). Better Therapeutics provides information about the Program through its website (the “Site”). The App, Program, and Site are 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 Service, how we use and share that data, and your choices concerning our data practices.

Before using the Service or submitting any Personal Data to Better Therapeutics, please review this Privacy Policy carefully and contact us at privacy@bettertherapeutics.io if you have any questions. By using the Service, 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 Service.

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 Service, provide Personal Data through the Site, 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 Service, 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 Service, and other information you share with us through the Service, 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 Service: When you download, visit, use and interact with the Service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, 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 Service (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 Service, 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). 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 uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

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 http://www.networkadvertising.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 Service available to you;
  • To respond to your inquiries, comments, feedback or questions;
  • To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies;
  • To analyze how you interact with our Service;
  • To maintain and improve the content and functionality of the Service;
  • To develop new products and services;
  • To prevent fraud, criminal activity, or misuses of our Service, 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 Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, 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 Service. You can also make your Personal Data available to family, friends or other caregivers. We will not sell or rent your Protected Health Information to anyone.
  • 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: 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 Service, 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@bettertherapeutics.io if you need to change or correct your Personal Data.

6. CHILDREN

Our Service is not directed to children who are under the age of 13. Better Therapeutics does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Better Therapeutics through the Service, please contact us at privacy@bettertherapeutics.io and we will endeavor to delete that information from our databases.

7. LINKS TO OTHER SITES

The Services 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.

8. SECURITY

You use the Service 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 secure. Therefore, you should take special care in deciding what information you send to us via the Service 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 Service, 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 Services, you may be unable to use those features. You can also contact us at privacy@bettertherapeutics.io to ask us to update or correct your Personal Data.

10. CHANGES TO YOUR PRIVACY POLICY

The Service, 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 Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

11. CONTACT US

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