Privacy Policy

Town Square Care, Inc. (“Town Square,” “we, “us,” or “our”) owns and operates www.jointownsquare.com, including without limitation all services, content, features and functionality available therein (“TS General Site”) including all services, content, features, and functionality available therein (the “Platform” and together with the TS General Site, the “Site”). At Town Square, we prioritize our customers' and visitors' (“user’, “you”, or “your”) privacy and are committed to protecting your personal information. We want you to understand how we collect, process, use, store, and disclose information while adhering to relevant laws. This Privacy Policy (the “Privacy Policy”) also describes the choices you can make about our use of your information. 

This Privacy Policy describes our practices in connection ‎with any information that we collect, including through websites operated by us from which you are ‎accessing this Privacy Policy, through the software applications made ‎available by us for use on or through computers and mobile devices (the “Apps”), and ‎through our social media pages that we control from which you are accessing this ‎Privacy Policy, as well as through HTML-formatted email messages that we may send to ‎you that link to this Privacy Policy (all of the foregoing, collectively, the “Services”).‎

We may update or modify this Privacy Policy at any time, by posting the updated version including the effective date of the updated version. Please review this Privacy Policy periodically for any updates or changes. This Privacy Policy is binding on all those who access our Site, whether acting as an individual or on behalf of an entity, including you and all persons, entities, or digital engines of any kind that harvest, crawl, index, scrape, spider, or mine digital content by an automated or manual process or otherwise. Please read this Privacy Policy carefully. Your continued use of the Site is considered your acceptance of these terms, and you agree to the terms of this Privacy Policy and the collection and use of information in accordance with this Privacy Policy. If you do not agree to be bound by this Privacy Policy or any subsequent modifications, you should not access our Site or disclose any Personal Information through our Site. This Privacy Policy is incorporated into our Terms of Use .

Personal Information

Personal Information We May Collect

“Personal Information” is information that identifies you as an individual or relates to ‎an identifiable person, including: Name, Email address, Health Information in connection with the quizzes, tests, and questionnaires we make available through the ‎Services (the “Questionnaires”). If you submit any Personal Information relating to ‎other people to us or to our service providers in connection with the Services, you ‎represent that you have the authority to do so and to permit us to use the information in ‎accordance with this Privacy Policy.

How We May Collect Personal Information

We and our service providers may collect Personal Information in a variety of ‎ways, including:‎

Through the Services: We may collect Personal Information directly from you through the ‎Services, e.g., when you answer a Questionnaire or register for an account.
Automatically: We may collect Personal Information when you access the Site
From Other Sources: We may receive your Personal Information from other sources with your ‎consent or as permitted by applicable law, such as from your insurance or healthcare provider, public databases, joint marketing partners and other third parties.

How We May Use and Disclose Your Personal Information

Town Square may have an arrangement with your insurance or healthcare provider and, under that arrangement, may be permitted to use and disclose your Personal ‎Information as directed by them, consistent with applicable law. Town Square also uses and discloses Personal Information to provide ‎the Services as described below.‎

We May Use Personal Information:‎

• To respond to your inquiries, fulfill your requests, and send you communications that you ‎request, such as the results of any Questionnaire that you have taken. To send administrative ‎information to you, for example, information regarding the Services and changes to our terms, ‎conditions and policies.‎
• To personalize your experience on the Services, for example, by presenting ‎Questionnaires and similar products to you.‎
• For our internal management and business purposes to the extent required or permitted under applicable law, such as data analysis, developing new ‎products and services, enhancing, improving or modifying the Services, audits, fraud monitoring and ‎prevention, identifying usage trends, and related purposes, which may include the use of artificial intelligence or machine learning.    
• To create de-identified and/or aggregated information to improve our services, enhance our ability to provide personalized and effective care, provide our customers with utilization insights, improve patient outcomes, and any other purpose permitted by law.
• As we believe to be necessary or appropriate, and only as permitted under the Health Insurance ‎Portability & Accountability Act and amendments thereto (HIPAA) or other applicable law: (a) to ‎comply with legal process; (b) to respond to requests from public and government authorities, ‎including public and government authorities outside your country of residence; (c) to protect our ‎operations or those of any of our affiliates, including in connection with investigating security ‎incidents; or (d) to protect our rights, privacy, safety or property, and/or that of our affiliates, you ‎or others.‎
• For such other purposes as you may consent or as may be authorized or required by applicable law.

Your Personal Information may be transferred or disclosed:‎

• To our third party service providers who assist us to provide the Services (such as website ‎hosting, data analysis, care delivery support, information technology and related infrastructure provision, email ‎delivery, auditing and other services), and with whom we have a contract that includes ‎appropriate privacy obligations.‎
• To third parties, such as your insurance or healthcare provider, consistent with your ‎instructions. For example, you may opt in to allow us to share your responses to and results of ‎any Questionnaires.‎
• As de-identified and aggregated information to third parties to improve our services, enhance our ability to provide personalized and effective care, provide our customers with utilization insights, improve patient outcomes, and any other purpose permitted by law.
• As we believe to be necessary or appropriate, and only as permitted under HIPAA or other ‎applicable law: (a) to comply with legal process; (b) to respond to requests from public and ‎government authorities, including public and government authorities outside your country of ‎residence; (c) to protect our operations or those of any of our affiliates, including in connection ‎with investigating security incidents; or (d) to protect our rights, privacy, safety or property, and/or ‎that of our affiliates, you or others.‎
• To such third parties and for such purposes to which you consent or which may be authorized or required by law.‎

Other Information

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or ‎does not directly relate to an individual, such as:‎

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• General demographic information
• Aggregated information

If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose ‎Personal Information as detailed in this Policy.‎

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ‎ways, including:‎

• Through your browser or device: Certain information is collected by most browsers or ‎automatically through your device, such as your Media Access Control (MAC) address, ‎computer type (Windows or Macintosh), screen resolution, operating system name and version, ‎device manufacturer and model, language, Internet browser type and version and the name ‎and version of the Services (such as the App) you are using. We use this information to ensure ‎that the Services function properly.‎
• Through your use of the Apps: When you download and use the Apps, we and our service ‎providers may track and collect usage data, such as the date and time the App on your device ‎accesses our servers and what information and files have been downloaded to the App based ‎on your device number.‎
• Using cookies, pixel tags and other similar technologies: Pixel tags (also known as web beacons and ‎clear GIFs) may be used in connection with some Services to, among other things, track the ‎actions of users of the Services (including email recipients), and compile statistics about usage ‎of the Services and response rates.‎
• Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service ‎may also collect information regarding the use of other websites, apps and online resources. ‎You can learn about Google’s practices by going to https://www.google.com/policies/privacy, ‎and opt out of them by downloading the Google Analytics opt-out browser add-on, available at ‎https://tools.google.com/dlpage/gaoptout.‎
• IP Address: Your IP address is a number that is automatically assigned to the computer that you ‎are using by your Internet Service Provider (ISP). An IP address may be identified and logged ‎automatically in our server log files whenever a user accesses the Services, along with the time ‎of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for ‎purposes such as calculating usage levels, diagnosing server problems and administering the ‎Services. We may also derive your approximate location from your IP address.
• Physical ‎Location: We may collect the physical location of your device by, for example, using satellite, ‎cell phone tower or WiFi signals. We may use your device’s physical location to provide you ‎with personalized location-based services and content. You may be permitted to allow or deny such use, but, if you do, we may not be able to provide you with the applicable personalized services and content.
• From you: Information such as your preferred means of communication is collected when you ‎voluntarily provide it.‎

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are ‎required to do otherwise under applicable law. In some instances, we may ‎combine Other Information with Personal Information. If we do, we will treat the ‎combined information as Personal Information as long as it is combined.‎  

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating ‎any site or service to which the Services link. The inclusion of a link on the Services ‎does not imply endorsement of the linked site or service by us or by our affiliates. In ‎addition, we are not responsible for the information collection, use, disclosure or ‎security policies or practices of other organizations, such as Facebook, Apple, Google, ‎Microsoft, RIM or any other app developer, app provider, social media platform provider, ‎operating system provider, wireless service provider or device manufacturer, including ‎with respect to any Personal Information you disclose to other organizations through or ‎in connection with the Services.‎

Security and Retention

We seek to use administrative, physical, and technical safeguards that are reasonable ‎and appropriate for the protection of the Personal Information in our custody or control. ‎Unfortunately, no data transmission or storage system can be guaranteed to be 100% ‎secure. If you have reason to believe that your interaction with us is no longer secure ‎‎(for example, if you feel that the security of your account has been compromised), ‎please immediately notify us in accordance with the “Contacting Us” section below. We ‎will retain your Personal Information in a file specific to you at our offices in 85th 5th Ave., 8th floor, New York, NY 10011 and the data centers of our service ‎providers. We will retain your Personal Information for the period necessary to fulfill the ‎purposes outlined in this Privacy Policy unless a longer retention period is required or ‎permitted by law.‎ As our operations are conducted from the US, all Personal Information that we collect is ‎used and stored in the US, is subject to US laws, and may be subject to disclosure to US ‎governments, courts or law enforcement or regulatory agencies pursuant to those laws.‎

Individual Rights

The following six rights are collectively referred to as the “Individual Rights.”‎

• The right to access – You have the right to request copies of your personal data that Town Square possesses in most cases. We may charge you a small fee for this service;
• The right to rectification – You have the right to request that Town Square correct any information you believe is inaccurate. You also have the right to request that Town Square complete information you believe is incomplete;
• The right to erasure — You have the right to request that Town Square erase your personal data, under certain conditions;
• The right to restrict processing – You have the right to request that Town Square restrict the processing of your personal data, under certain conditions;
• The right to object to processing – You have the right to object to Town Square’s processing of your personal data, under certain conditions; and
• The right to data portability – You have the right to request that Town Square transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise any of your Individual Rights regarding Personal ‎Information that you have previously provided to us, you may do so by logging into your ‎account within the Services or by contacting us in accordance with the “Contacting Us” ‎section below. In your request, please make clear what Individual Right you are ‎exercising. For your protection, we may only implement requests with respect to the ‎Personal Information associated with the particular email address that you use to send ‎us your request, and we may need to verify your identity before implementing your ‎request. We will try to comply with your request as soon as reasonably practicable and ‎in compliance with applicable law. Where appropriate, we will transmit the amended ‎information to third parties having access to your Personal Information. We may be ‎prevented from complying with a request to exercise an Individual Right. In such ‎circumstances, we will respond to your request to exercise your Individual Right with a ‎response stating that we cannot comply with such a request and, if legally allowed, why.‎‎

Policy on Children’s Information

Our Site is not created for anyone under the age of 18 (“Children” or “Child”). By using the Site, you represent that you are at least 18 years old. If you do not meet this age requirement, then you must not access or use our Site.

We do not knowingly collect Personal Information from anyone under the age of 14, and we do not target the Site to Children. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information, please contact us at [email protected]. If we become aware that we have collected Personal Information from Children without verification of parental consent, we take reasonable steps to remove that information from our servers.

For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions

California Residents

If you are a resident of California the following information and rights are provided to ‎you as required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA), and all implementing regulations, as may be further amended from time to time (collectively, the “CCPA”). Any terms ‎defined in the CCPA have the same meaning when used in this notice. Personal ‎information under CCPA does not include:‎

• Publicly available information from government records.‎
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:‎
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.‎
• Financial Information covered by the Gramm-Leach-Bliley Act, and implementing regulations.‎

In the preceding twelve (12) months, we have disclosed the following categories ‎of Personal Information for a business purpose:‎

• Identifiers: Name, residential address, Internet Protocol (IP) address, ‎email address, or other similar identifiers
• Customer records information: Name, address, telephone number, ‎medical information, health insurance information‎
• Characteristics of protected classifications under California or federal law: ‎Race, gender identity, age‎
• Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement‎
• Geolocation data: physical location or movement‎
• Professional or employment-related information‎
• Education information‎

We may also collect the following Sensitive Personal Information:

• Social security, driver’s license, state identification card, or passport number‎
• Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account‎
• Precise geolocation‎
• Racial or ethnic origin, religious or philosophical beliefs, or union membership‎
• Health information‎
• Information concerning a consumer’s sex life or sexual orientation‎

This information is collected as noted in the Sections above entitled How We May Collect Personal Information and How We May Collection Other Information. The business purposes for which we collect and disclose this information are:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards‎
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business‎
• Helping to ensure security and integrity‎
• Debugging to identify and repair errors that impair existing intended functionality‎
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business
• Providing advertising and marketing services, except for cross-context behavioral advertising, to consumers
• Undertaking internal research for technological development and demonstration‎
• Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance the services‎

In the past 12 months, we have disclosed your Personal Information for a business purpose to the following ‎categories of third parties:‎

• Service Providers: Cloud hosting, email delivery, medical record ‎management, telehealth video platform, care delivery support, service desk management, platform ‎usage analytics, business analytics, SMS delivery, log aggregation, ‎geolocation‎

In addition to the above, we may disclose any or all categories of Personal Information to any third-party (including government entities and/or law enforcement entities) as necessary to

• comply with federal, state, or local laws, cooperate with law enforcement agencies, or to comply with a court order or subpoena to provide information
• cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law‎
• comply with certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury‎
• exercise or defend legal claims‎

“Sale” or “Sharing” of Personal Information

The categories of sources that we collect Personal Information and Sensitive Personal Information and our business and commercial purposes for using this information are set forth above. We do not "sell" or "share" your Personal Information. You may remove or adjust your cookie preferences on your device or browser as they permit, and you may contact us to exercise your rights at any time (see “Contacting Us” below).

Your Rights and Choices ‎

The CCPA provides consumers (California residents) with specific rights regarding ‎their Personal Information, including:

• Access – The right to request access to certain information about our collection and use of your Personal Information over the past 12 months;
• Data Portability – The right to request a copy of the specific Personal Information that we have collected about you or to transmit such Personal Information to another entity;
• Deletion – The right to request deletion of Personal Information that we have collected and retained (subject to certain exceptions);
• Correct – The right to correct Personal Information that we have collected to ensure that it is complete, accurate, and as current as possible;
• Opt-out – The right to opt-out of selling and sharing the information we collect (see above).

You may submit a verifiable consumer request to us to exercise any of these rights by contacting us as indicated below. We will process such requests in accordance with applicable laws.

Response Timing and Format

We will respond to a verifiable consumer request within 10 days of its receipt. We will generally process these requests within 45 days of its receipt. If ‎we require more time (up to an additional 45 days), we will inform you of the reason and extension ‎period in writing. If you have an account with us, we will deliver our written response to ‎that account. If you do not have an account with us, we will deliver our written response ‎by mail or electronically, at your option. Any disclosures we provide will only cover the ‎‎12-month period preceding the verifiable consumer request’s receipt. The response we ‎provide will also explain the reasons we cannot comply with a request, if applicable.‎

Verification

Only you or a person registered with the California Secretary of State that you ‎authorize to act on your behalf, may make a verifiable consumer request related to ‎your Personal Information. For privacy protection, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. ‎Unless permitted by the CCPA, we will not:‎

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through
• Granting discounts or other benefits, or imposing penalties.‎
• Provide you a different level or quality of goods or services.‎
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.‎

Updates to This Privacy Policy

We may change this Privacy Policy. The “Last Updated” legend at the top of this page ‎indicates when this Privacy Policy was last revised. Any changes will become ‎effective when we post the revised Privacy Policy on the Services. Your use of the ‎Services following these changes means that you accept the revised Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at [email protected]. ‎Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.‎