Privacy Policy

PEAR THERAPEUTICS, INC

This service is provided by Pear Therapeutics, Inc

Through its Clinician facing website www.reset.md (the “Website” or “Site”) and its mobile application for Patients (the “App”), Pear Therapeutics, Inc (“Pear Therapeutics”, “we” or “us”) provides digital prescription therapies designed to improve patient outcomes. These prescription therapies include data collection, storage, analysis and reporting tools, functions and related services, which are collectively referred to in this Privacy Policy as the Service.

This Privacy Policy covers how Pear Therapeutics, collects, receives, uses, retains, and discloses
Personally Identifiable Information (“PII”) of Clinicians (also “you”, “your” or “user”) through the Site.
PII includes information about you that is personally identifying such as your name, email address, and phone number and which is not otherwise publicly available. Only the legal definition of PII that applies to your location will apply to you under this Privacy Policy.

Clinical Partners are hospitals, clinics, practices or other medical groups or healthcare systems that have contracted with Pear Therapeutics to permit use of the Service by their respective Clinicians and Patients; Clinicians are practitioners, patient advocates, coaches or other individuals who (as employees of or contractors to a Clinical Partner) provide healthcare or related services to Patients; and Patients are individual patients of the Clinical Partner who receive medical treatments or other healthcare services from one or more Clinicians, or individuals who are properly authorized representatives of any such patient.

Through their provision of health care services to Patients, Clinicians and Clinical Partners will have access to and be responsible for Patient PII and Patient Protected Health Information as defined by Health Insurance Portability and Accountability Act (HIPAA) Privacy Rules or other applicable laws. Clinicians and Clinical Partners are responsible for the privacy and security of such information and for obtaining consent from Patients for the use and disclosure of such information to, from and through the App and the Service.

Agreement

By using the Site or the Service, and/or by providing PII to Pear Therapeutics, you accept and hereby expressly consent to our collection, use, retention, and disclosure of your PII in accordance with the terms of this Privacy Policy. If you choose not to provide the requested information you will not be able to access the Site or Service.

This Privacy Policy may change from time to time, so please check back periodically to check the most recent modification date to ensure that you are aware of any changes in our processing of your Personal Data. Your continued use of the Site or the Service after any changes signifies your express, explicit, voluntary and unambiguous consent to any such changes. If you do not agree to such changes, you must immediately stop using the Site. This Privacy Policy was last modified on January 18, 2017.

Information Collection and Use; Choice and Consent

Registration

You must register with the Site and the Service and set up an account in order to use the Service. We may receive PII about you from your Clinical Partner in order to identify you as an authorized user of the Service. When you register, we collect your name and email address. It is always your choice whether or not to provide us with such information. Pear Therapeutics uses PII to:

  1. Provide the Service
  2. Communicate with you
  3. Communicate with your Patients and Clinical Partners as applicable
  4. Create user profiles
  5. Create de-identified analytical information
  6. Reply to your request for information or comments

Analytics

When you use the Site or the Service, we use tracking technology to collect de-identified information relating to your browser or device type, the time and date you use the Service, operating system, identification of Site page views, use of particular Service features, geographic location and other statistical information relating to your use of the Site or the Service but which does not identify you. This information is referred to in this Privacy Policy as “Analytics.” We use Analytics to develop, improve, extend and test the Service (and underlying technology platforms); to market and promote Pear Therapeutics and the Service; and we disclose, distribute and transmit Analytics to Clinical Partners for their use.

Withdrawing Consent

You may withdraw your consent to further use of your PII by emailing a request to us at security@peartherapeutics.com. We will respond to your request in accordance with the law that applies to you. Your PII which we processed prior to your request may not be deleted from our Site system records but will be blocked from further processing without your permission. A request to withdraw consent may not apply to information collected by tracking technologies or used internally to recognize you and/or facilitate your visits to the Site, or information we may keep to comply with legal requirements.

You may access, change, modify or delete your information as described below.

Protection of Your Information

Pear Therapeutics uses secure server software (SSL), firewalls, and end-to-end encryption to protect your PII from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

We will retain PII for as long as necessary to provide our services, but no later than 6 years following termination of Services. We will retain and use PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Information Sharing and Disclosure

Your PII will be shared with your Clinical Partner. We disclose your PII as well as de-identified information to third party vendors who help us operate the Site. These third parties are contractually obligated to maintain the confidentiality of your PII consistent with the terms of this Privacy Policy and to comply with the applicable data protection laws.

We will disclose your information in response to valid legal process, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements. We also may disclose your information in response to a law enforcement agency’s request or other request for information from the U.S. or other government entities, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or to verify or enforce compliance with the policies governing our products and/or services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. In addition, we may, upon notice to you and/or your Clinical Partner, transfer your information to an entity or individual that acquires, buys, or merges with Pear Therapeutics, or our other business units.

We share Analytics with Clinical Partners for their internal use and with other third parties to market and promote Pear Therapeutics and the Service.

Links to Other Sites; Third Party Apps; Transactions with Third Parties

The Site may contain links to other sites that are not owned or controlled by Pear Therapeutics. Please be aware that we are not responsible for the privacy practices of these other sites. We encourage you to review the privacy policies and statements of other sites to understand their information practices. Our Privacy Policy applies only to information collected by our Site and Services.

You may be able to obtain an App, access the Service and/or communicate with the Service from, and you may be able to link or communicate from the Service to, applications, devices, distribution platforms and websites owned and operated by Clinical Partners and/or by Apple, Google or other third party distribution platform operators (“Channel Partners”). These other applications, devices, platforms and websites belong to third parties and are not operated or controlled by Pear Therapeutics. Our Privacy Policy does not apply to any information collected, received, used, processed, transferred or disclosed by such third parties. Additional or different terms and conditions (including without limitation, privacy and security practices) apply when you access and use third party applications, devices, platforms and websites, which are not the responsibility of Pear Therapeutics.

Pear Therapeutics is not responsible for and will not be a party to any transactions between you and a third party provider of products, information or services. Pear Therapeutics does not monitor such transactions or ensure the confidentiality of your PII, including credit card information, for any third party transaction. Any separate charges or obligations you incur in your dealings with these third parties linked to Pear Therapeutics’ Site are solely your responsibility.

Children

Our Service is intended for individuals who are over age 18. If you believe a child who is under age 13 has provided information to the Service please contact us using the information provided below.

Your California Privacy Rights; California Do Not Track Disclosures

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by Pear Therapeutics or its subsidiaries to a third party for the third party’s direct marketing purposes. Since we do not make such disclosures, we are exempt from these reporting requirements.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities, over time and across different websites. We do not honor “Do Not Track” signals.

Accessing Your Information

You may access, review, change, update or delete your PII by contacting us at security@peartherapeutics.com. You can help us maintain the accuracy of your information by notifying us of any changes to your information by email to security@peartherapeutics.com.

Contact Us About Complaints, Questions or Notices relating to this Privacy Policy

Pear Therapeutics commits to resolving complaints about your privacy and our collection or use of your PII. If you believe your privacy rights have been violated or you disagree with any action Pear Therapeutics has taken with regard to your PII, you may file a complaint with Pear Therapeutics by emailing us at security@peartherapeutics.com.

If you have questions or suggestions, please email us at support_reset@peartherapeutics.com. You may also contact us at:

Pear Therapeutics, Inc. Attn: Privacy Officer 745 Atlantic Ave Boston, MA 02111