Global Privacy Policy

Last updated: October 28, 2024

This Global Privacy Policy (“Policy”) describes how Better Outcomes Now (“BON” “We” “Us” “Our”) collects, uses and discloses personal information of visitors and users of Our website at https://www.betteroutcomesnow.com (“Site”) and from Our subscription users of Our web-based software application https://app.betteroutcomesnow.com (“App”).

It’s important that you understand how We collect and use your information. If you do not wish your information to be collected, used, stored, or disclosed as described in this Policy you should not use the Site or subscribe to use Our App. You should read this page carefully and in full. Below are the main highlights:

We require your consent to collect and use your personal information as described in this Policy.
With your given consent, We collect and use your personal information to provide and improve the Site and App, to communicate with you, to manage Our relationship with you, for your experience in using the Site and App, to monitor, administer, and protect the security and integrity of the Site and App, to develop, improve or enhance the Site and App, and to comply with Our legal and contractual obligations.
We do not knowingly collect any personal information from children under 18 years old.
We do not sell your personal information to any third parties in exchange for any money, goods or services or for any other valuable consideration, or for their own use to directly advertise their own products or services to you.
We may share some or all of your personal information with Our third-party services providers who assist Us with the performance, functionality, operations, availability, features and security of the Site and App, to comply with legal and regulatory requirements, to fulfill Our contractual obligations with Our App customers, and for other circumstances described in this Policy.
We will honor your legal rights and choices under applicable laws.
If you have any questions, you can contact Us by sending an email to privacy@betteroutcomesnow.com.

What is Personal Data at BON?

Personal Data refers to information that identifies a natural person or information that can reasonably be used to identify a natural person (“Personal Data”). This can include direct identifiers such as names, addresses, or identification numbers, as well as indirect identifiers that could be combined with one or more direct identifiers to specifically identify an individual. Under U.S. state-specific data privacy laws, Personal Data does not include:

Information derived from the use of the Site or App that is done in a business, commercial or employment context (“Business Data”), such as, but not limited to, on behalf of an employer or business, in the course of one’s profession or trade, business-to-business interactions, and any other activities that directly or indirectly relate to commercial interests, professional duties, or employment responsibilities;
Information constituting “personal health information” as defined by the Health Insurance Portability and Accountability Act of 1996 (HIPAA);
Information that is pseudonymized, deidentified or aggregated such that the information does not specifically identify you and is incapable of being restored or reasonably linked to specifically identify you; and,
Publicly available information.

Both the Site and App are designed and intended for use by behavioral health care practitioners and organizations and behavioral health care professionals affiliated with higher educational institutions and students under their supervision. Accordingly, the data We intend to collect is primarily Business Data. We acknowledge that some jurisdictions may deem certain business contact information as Personal Data and We will treat it as such in accordance with such applicable laws. In mixed-use scenarios where it may be unclear whether data qualifies as Business Data or Personal Data, We will err on the side of caution and treat it as Personal Data. Notwithstanding Our intention to collect primarily Business Data, in the event We collect your Personal Data, We will treat it in accordance with applicable privacy laws.

Within the United States, for Our App customers that are HIPAA covered entities or business associates, We handle the protected health information of their respective patients/clients in accordance with HIPAA and pursuant to Our business associate agreements with them.

If a foreign law where the Site and App are made available deems any Business Data as Personal Data, We will treat it as Personal Data in accordance with such foreign law. Additionally, in jurisdictions outside the United States, We will treat the health information of Our App customers’ respective patients/clients as sensitive Personal Data in accordance with the applicable foreign country’s laws, recognizing that many countries classify health information as a special category of data requiring heightened protection.

We are committed to the principle of data minimization and collect only the information necessary for the stated purposes in this Policy.

How We Collect Personal Data and Why

We collect Personal Data that is relevant and reasonably necessary for the purposes described in this Policy. We use, share, process, store, and hold Personal Data for the purposes described in this Policy and in accordance with the applicable laws.

Form Submission. When you contact Us using the form on the Site, We collect your first and last name and mailing address (if provided), phone number (if provided), email address, your selected products of interest, and any other information you choose to provide in your message. We collect and process this information to respond to your inquiry, to provide you with information in response to your message, to maintain a record of Our communications with you for quality assurance and follow-up purposes, to analyze the nature and frequency of inquiries submitted via the Site to improve the Site’s content, and to comply with Our legal obligations.

Email Communications. When you use an email address posted on Our Site to contact Us directly, We collect and process your email address, name (if provided) and the contents of your message to respond to your inquiry or request, to provide you with information about Our offerings or services, to maintain a record of Our communication for quality assurance and future reference, and to comply with Our legal obligations. If you consented to receive Our promotional emails, you may, at any time and regardless of where you reside, withdraw your consent by clicking the “unsubscribe” link located at the bottom of Our email. In some email messages We send to you, We may provide a “click-through URL” that links you to content on the Site. We track this click-through to help Us determine interest in particular topics and measure whether We are communicating with you effectively. If you prefer not to be tracked in this way, you should not click graphic or text links in email messages.

App User Account. When you set up your account in the App, We collect your name and other Business Data, such as, your job title, organization name, business phone number, business email address, business mailing address, user role and user access level for the App. We use this information to enable you to set up and manage your App account, to authenticate your identity and authorize appropriate access to features and data, to provide you with the services of the App, to communicate with you about the App and its related services, to manage Our relationship with you, to analyze usage patterns and improve the App’s functionality and user experience, to generate anonymized, aggregated data for internal analytical business purposes and service optimization, and to comply with Our legal obligations.

App Usage Data. We collect and process data related to your use of the App to improve the services of the App, enhance your user experience, and ensure proper functionality. App usage data may include login frequency and duration, features and functions accessed, actions performed within the App, data input patterns and volume, device information (e.g., type, operating system, browser), IP address and general location (not precise geolocation), time and date stamps of activities, and error logs and crash reports. We process this data to maintain and improve App performance and functionality, to analyze user behavior and optimize user interface and experience, to identify and resolve technical issues and bugs, to detect and prevent fraudulent or unauthorized use, to generate aggregated statistics about App usage, to assess the effectiveness of new features or updates, and to comply with legal and regulatory requirements related to system integrity and security. App usage data is generally processed in an aggregated or pseudonymized form. However, in some cases, it may be linked to your App user account for purposes such as providing personalized support or investigating security incidents.

App User Email Communications. As a subscriber to Our App, when you use an email address We provided to you to contact Us, We collect and process your email address, name, account identifier (if provided), and the content of your message to respond to your inquiries, requests or support needs related to your subscription, to assist you with technical issues or application functionality, to process account-related requests, to provide you with information about updates, maintenance or changes to the App, to address subscription-related matters, to gather feedback for improving the App and customer experience, to maintain a record of Our communication for quality assurance and account management, and to comply with Our contractual and legal obligations.

Cookies and Other Automated Data Collection Technologies.

App Cookies: We use security cookies on the App for the security of Our App. These cookies expire when you close your browser or after 120 minutes of inactivity.
Site Cookies: We use the below listed Google Analytics cookies to help Us understand the usage of the Site, to determine the effectiveness of Our marketing campaigns, and to enhance your browsing experience. These cookies do not collect any identifiable Personal Data about you. They store information anonymously and use a randomly generated unique ID number assigned to each visitor that is used to recognize and track visitors. These cookies either expire when you close your browser (session cookie) or after a set period.

ga: this cookie counts the number of Site visitors and identifies whether visitors are new or returning, including time spent on the Site, number of pages viewed, referring source (e.g., organic search, social media), IP address, device type, browser type and version, screen resolution, geographic location (country and city level, not precise), Site interaction events, and conversion tracking (e.g., signing up for Our newsletter or purchasing a subscription to Our App. The duration of this cookie is 2 years.

ga_*: this cookie is used to distinguish visitors of the Site and their interactions with the Site by tracking their sessions and interactions over time and lasts for 2 years.

gid: this cookie uses a visitor’s unique ID to track interactions on the Site within a single session and may collect a user IP address and the timestamp of the user’s first visit to the Site. The duration of this cookie is 1 day.

We do not use Google Analytics data to personally identify individual users or combine that data with any identifiable Personal Data. The data is collected and used in accordance with this Policy and is also governed by Google’s privacy policy. Details about Google’s privacy practices can be viewed here: https://www.google.com/policies/privacy.

You can control and delete cookies in your browser settings. However, please note that disabling essential cookies may affect the functionality of the Site and your user experience. You can learn more about cookies, including how to manage and disable them, here: https://www.aboutcookies.org/.

Event Logs. Our Site and App automatically collect and record data about actions or occurrences occurring on the each of them. This data may include user interactions (e.g., App login attempts, App password changes, page views, and form submissions); system events (e.g., server errors, crashes or restarts), security events (e.g., App login failures, App access); application events (e.g., queries); timestamps; and, performance metrics (e.g., response times and error rates). We use and process this data to monitor the performance, privacy and security of the Site and App, troubleshoot issues and identify root causes, optimize the Site and App configuration, improve user experience, and to comply with legal or regulatory requirements.
Web Logs. We automatically record certain data and store it in log files when you interact with the Site or App. This data typically includes your IP address, requested URLs, HTTP status codes, user agent information (browser type and version, operating system), date and time stamps of visits, referring pages, and basic performance data (e.g., response times, errors). We process this data to monitor and improve Our services, detect and prevent unauthorized access, and comply with legal requirements. Unlike cookies, web log data is collected and stored on Our services and not on your device.

Note to Patients/Clients of Our App Customers

If you are a patient/client of one of Our App customers, We may collect your name provided by your treating health care provider to whom you have authorized to share it with Us and to act on your behalf to consent to and opt out of Our collection, use, processing, storage and sharing of your Personal Data, including your health information. If you have any questions or wish to exercise any of your available rights concerning Our collection, use, processing, sharing or storage of your Personal Data, including your health information, please contact your treating health care provider directly.

Note on App Subscription Payments

When you purchase an App subscription plan, Our third-party payment processor (i.e., Stripe) collects and processes your business billing details on Our behalf. We do not collect or store your payment card or bank account details. This financial information is provided directly to Stripe whose collection and use is governed by Stripe’s privacy policy. Details about Stripe’s data privacy, security, retention and access practices are available at https://stripe.com/legal/privacy-center.

Do Not Track Requests

Some browsers may transmit “Do Not Track” (DNT) signals to websites you visit. Because there is not common agreement about how to interpret DNT signals, the Site currently does not take action in response to them.

Categories of Third Parties With Whom We May Disclose Personal Data and Why

We may share your Personal Data to the below categories of third parties for the below described purposes.

Third-Party Service Providers. We engage others to perform some functions on Our behalf, such as conducting customer relationship management, processing payments, analyzing data, providing marketing support, and providing hosting, administration, infrastructure and cybersecurity support. These providers have access to Personal Data necessary to exclusively perform their functions and not for other purposes.

Professional Advisors. We may share Personal Data with Our insurers or other professional advisors (such as, attorneys, accountants, consultants and auditors) who have a need to know the Personal Data to provide their professional services to Us and not for other purposes.

Business Transfer. We may share Personal Data in the event of a company merger, restructuring, reorganization, dissolution or other sale or transfer of some or all of Our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us is among the assets to be transferred.

With Your Consent. For purposes not addressed in this Policy, We will only disclose your Personal Data with your express consent.

Statistical Data. We may also share pseudonymized, de-identified or aggregated data that does not specifically identify you and is not reasonably capable of being restored or linked to specifically identify you for Our analytical purposes to assist Us understand Our users’ interests, preferences and usage patterns related to the content, performance, operations, features, and functionality of the Site and App.

Specific Third Parties With Whom We Share Personal Data and Why

We use the below specified third-party service providers (“Providers”) to assist Us with the Site’s and App’s collection, processing, security, storing, and transmitting of Personal Data, including Business Data. By virtue of their services, Our Providers will have access to certain parts of your Personal Data and Business Data in the course of providing their services to Us in order to deliver the Site and App services to you.

Amazon Web Services (AWS): a U.S. based cloud infrastructure and hosting provider. The categories of data processed by and shared with AWS may include account information, profile data, user-generated content, usage data and device data. Details about AWS’s data privacy, security, retention and access to Personal Data are available at: https://aws.amazon.com/compliance/data-privacy-faq/

Aptible: a U.S. based software infrastructure development, maintenance and cybersecurity provider. The categories of data processed by and shared with Aptible may include account information, profile data, user-generated content, usage data, device data and compliance-related data. Details about Aptible’s data privacy, security, retention and access to Personal Data are available at: https://www.aptible.com/legal/privacy

Datadog: a U.S. based cloud monitoring and cybersecurity provider. The categories of data processed by and shared with Datadog may include log data, performance data, user session data, and information related to potential security incidents or anomalies. Details about Datadog’s data privacy, security, retention and access to Personal Data are available at: https://www.datadoghq.com/security/?tab=security

Other Circumstances Where We May Disclose Personal Data

We may disclose your Personal Data when necessary under the following circumstances:

Legal Compliance: to comply with applicable federal, state, local and foreign laws governing the collection, use, processing, sharing, and storage of your Personal Data to which We are subject to.

Regulatory and Law Enforcement Cooperation: to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, and/or summons by any federal, state, local or foreign authorities and/or to cooperate with law enforcement agencies concerning conduct or activity that We or a third party has a reasonable and good faith belief may or does violate applicable law.

Legal Rights Protection: to establish, enforce, exercise, and/or defend Our legal rights in any court, administrative, enforcement, or other proceeding;

Vital Interests Protection: to take immediate steps to the protect an interest that is essential for the life or physical safety of you or of any other individual, and where Our processing is not manifestly based on another legal basis.

Security and Fraud Prevention: to prevent, detect, protect against, or respond to security incidents, fraud, harassment, malicious or deceptive activity, and illegal activity so as to preserve the integrity and security of the Site, App and Our systems and, when applicable, to investigate, report or prosecute those responsible for such events;

Contractual Obligations: to assist another data controller, data processor or third-party service provider with whom We have a contractual relationship with to perform their obligations under applicable laws.

Location of Processing and Storage

Our operations are based in the State of Florida in the United States, and We store Personal Data in servers located in the United States. Within the United States, We select third-party processors that have agreed to adhere to relevant U.S. laws and regulations, including HIPAA as it applies to personal health information, and obtain data processing and related agreements when required by applicable foreign law. We implement technical and organizational measures to protect Personal Data, including encryption, access controls, audits, and risk assessments. While We make reasonable efforts to engage third-party processors that maintain adequate data security practices, We do not have direct control over any of their operations and cannot guarantee any of their practices.

For users outside the United States, please note that your information will be collected, processed, and stored in the United States. We strive to comply with applicable international data protection regulations, including the EU General Data Protection Regulation (GDPR), where the Site and App are made available.

We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws or regulations.

By using the Site and/or subscribing to Our App, you expressly agree to the following:

Your Personal Data being processed and stored in the United States;
If applicable, you are responsible for obtaining the consent of your patients/clients to have their Personal Data, including their health information, processed and stored in the United States;
If applicable, you are responsible for informing your authorized users (if any) that their Personal Data will be processed and stored in the United States and that they consent to this;
If applicable, if any of your patients/clients or authorized users do not wish to have their information processed and stored in the United States, you will not submit or cause the submission of any such individuals’ information to the App; and
You understand that you may have certain rights regarding your Personal Data under applicable laws (as described further below in this Policy), and you can contact Us to exercise these rights.

Security and Retention

We make reasonable efforts to provide a level of security appropriate to the risk associated with processing Personal Data under Our control. We maintain administrative, physical, and technical security measures to protect Personal Data from being accessed, used, destroyed, altered, lost or deleted in an unauthorized manner. This includes using secure socket layer technology (SSL), firewalls, encryption, and periodically auditing Our security measures and conducting data risk assessments. Our security measures include updates of security protocols and software, access controls and authentication measures for data access, and monitoring systems for detecting and responding to potential security incidents. However, no method of data transmission or storage system can be guaranteed to be 100% secure, and We cannot guarantee absolute security. In the event of a data breach that affects your Personal Data, We will notify you in accordance with applicable laws.

We retain Personal Data for as long as is reasonably necessary to fulfill Our business purposes for which We collected it, as described in this Policy, and to comply with Our legal or compliance obligations. The specific retention period may vary depending on the type of data, the purpose for which it was collected, and legal requirements. We take commercially reasonable steps to permanently and securely delete Personal Data when (1) We have a legal obligation to do so, (2) We no longer have a business, commercial, or legal purpose to retain it, or (3) if you ask Us to delete it, except if We determine that doing so would impair or violate any of Our legal or contractual obligations. We may also decide to delete some or all of a Site user’s Personal Data if We believe it is incomplete, false, inaccurate, or that Our continued storage is contrary to Our legal or compliance obligations.

Children Under 13

The Site is not directed to or intended for use by children under 13 years old. We do not knowingly collect personal data from children under 13. If We learn that We have collected personal data from a child under 13 without the consent of the child’s parent or legal guardian, We will take steps to stop collecting and entirely delete the child’s Personal Data. If you believe We have collected Personal Data of your child who is under 13, please let Us know by email to privacy@betteroutcomesnow.com. For more information about Children’s’ Online Privacy Protection Rule (“COPPA”), please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule

Third-Party Links Disclaimer

The Site may contain links, media or other content from third parties. These links are external resources, and the third parties have their own privacy policies that govern your visit to, access of and/or use of them. If you click on a third-party link, you will be redirected to that third-party’s website. We do not own or control any third-party websites or platforms. We do not guarantee or warrant the adequacy of protection or the collection, use and data handling practices of any third-party websites or platforms. You should read the third-party’s policies about their privacy and security practices to learn what information they collect about you, why they collect it, how they use it, how they protect it, where they store it, who they share with it and why, and their transfer practices as their terms that will apply to you as between you and the third-party and not Us or this Policy.

Your Privacy Right and Choices

You may have certain rights relating to your Personal Data and/or Business Data depending on the data privacy laws of where you reside or of your citizenship, in each case as determined by the law of your state or country. Below We address:

Privacy rights of residents of states in the United States with data privacy laws currently in effect and those coming into effect in the latter part of 2024 and in 2025 that We know of as of the date of this Policy, and
Privacy rights of residents/citizens of foreign countries with data privacy laws currently in effect as of the date of this Policy where the Site and App is made available.

In each case, We will honor your privacy rights and choices as required by applicable laws.

United States – State Specific Consumer Privacy Rights

Colorado

Your Privacy Rights

As a Colorado resident, you may have the below listed rights under the Colorado Privacy Act (“CPA”) that you may exercise once a year. However, these rights are not absolute and in certain cases We may deny your request or claim legal exemptions as permitted by the CPA and/or other applicable laws.

Right to know and access: you may request if We hold and process your Personal Data and receive a securely transmitted copy of it from Us that you can access, read and electronically transmit.
Right to correct: you may request that We correct any inaccurate or incomplete identifiable Personal Data about you that We hold.

Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to withdraw: you may withdraw your previously given consent to collection, use, disclosure or any other form of processing of your Personal Data. Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.
Right to opt out of selling: We do not sell Personal Data and you have the right to receive confirmation of this from Us.
Right to opt out of targeted advertising: you may opt out of Our processing your Personal Data for targeted advertising purposes.

Right to opt in for sensitive Personal Data: The Site does not collect any sensitive Personal Data. Notwithstanding, if We collect sensitive Personal Data from or about you via the Site, We will not process that data without your express consent.
Right to opt out of profiling: you may opt out of the automated processing of your Personal Data that We hold and use to evaluate, analyze or predict personal aspects that directly identifies you or could reasonably be linked to identify you, but only to the extent Our decision results in producing legal or similarly significant effects about you.
Right to appeal: you may appeal Our denial of any right you exercised. Within 45 days of Our receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s). We have a right to extend the 45-day period by an additional 60 days by notifying you within 45 days of receiving your appeal and telling you why We need additional time.
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.

Request Submission Process

You may submit a written request to privacy@betteroutcomesnow.com. When submitting your request, please include your full name, contact information, the nature of your request and any additional details that may help Us locate your Personal Data (e.g., website visitor, App subscriber, approximate timeframe when you used the Site).

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. If Our verification process is successful, We will respond within 45 days of receiving your verifiable request. To the extent required, We reserve the right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and telling you why We require additional time.

If We cannot verify your identity We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and the reason(s).

If We have a good faith, reasonable basis to believe your request is fraudulent, We have the right to deny your request and will notify you of Our decision and the reason(s).

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent.

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business directly.

Extra Requests

For subsequent requests made in the same year or for requests that are manifestly unfounded, excessive, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs of providing the information or taking the action requested in which case We will first notify you along with the amount of the fee before We proceed with your request or (2) deny your request and notify you of Our decision and the reason(s).

Connecticut

Your Privacy Rights

As a Connecticut resident, you may have the below listed rights under the Connecticut Data Privacy and Online Monitoring Act (“CDPA”) that you may exercise once a year. However, these rights are not absolute and in certain cases We may deny your request or claim legal exemptions permitted by the CDPA and/or other applicable laws.

Right to know, access and data portability: you may request if We have processed or are processing your Personal Data that We hold and receive a list identifying the categories of Personal Data that We process or have processed via a secure transmission and in an electronic format that you can access, read and electronically transmit.
Right to correct: you may request Us to update or correct your identifiable Personal Data that We hold.
Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to withdraw: you may withdraw your previously given consent to collection, use, disclosure or any other form of processing of your Personal Data. Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.
Right to opt out of selling: We do not sell your Personal Data and you may request to receive confirmation of this from Us.
Right to opt out of targeted advertising: you may request to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy.

Right to opt in for targeted advertising as to children: We do not collect or process the Personal Data of children for purposes of target advertising or otherwise. If We have actual knowledge that you are between the ages of 13 to 17 years old, We will not process your Personal Data for targeted advertising purposes without the express consent of your parent or legal guardian.
Right to opt out of profiling: you may opt out of the automated processing of your Personal Data We hold and use to evaluate, analyze or predict personal aspects that specifically identifies you or can reasonably be linked to specifically identify you but only to the extent Our decision results in producing legal or similarly significant effects about you.
Right to opt in for sensitive Personal Data: the Site does not collect any sensitive Personal Data. Notwithstanding, if We collect any sensitive Personal Data about or from you via the Site, We will not process such data without your consent.
Right to appeal: you may request to appeal Our denial of any right you exercised. Within 60 days of Our receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s) for Our decision.
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.
Right to complain: if We deny your appeal, you have the right file a complaint with the Office of the Attorney General for Connecticut. For instructions, please visit: https://portal.ct.gov/ag/common/complaint-form-landing-page.

Request Submission Process

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. If Our verification process is successful, We will respond within 45 days of receiving your verifiable request. To the extent required, We reserve the right to extend this 45-day period by another 45 days by notifying you within 45 days of Our receipt of your request and the reason(s) We need the extension.

If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and the reason(s).

If We have a good faith, reasonable basis to believe that your request is fraudulent, We have the right to deny your request and will notify you of Our decision and the reason(s).

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

For a second or any subsequent requests made in the same year, or for requests that are manifestly unfounded, excessive or repetitive, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request in which case We will first notify you along with the amount of the fee before We proceed, or (2) refuse to act on the request and notify you of the reason(s) for Our decision.

Delaware

Your Privacy Rights: Effective 01/01/2025

As a Delaware resident, starting on January 1, 2025, you may have the below listed rights under the Delaware Personal Data Privacy and Consumer Protection Act (“DPCPA”) that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request or claim legal exemptions as permitted by the DPCPA and/or other applicable laws.

Right to know and access: you may request if We are processing or have processed your Personal Data that We hold along with a copy of that Personal Data and a list of the specific third-party recipients, or the categories of such third-party recipients, with whom We shared Your Personal Data.
Right to portability: you have the right to receive a securely transmitted copy of your Personal Data We hold in an electronic format that you can access, read and electronically transmit.
Right to withdraw: you may withdraw your previously given consent to collection, use, disclosure or any other form of processing of your Personal Data. Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App. Subject to Our satisfactorily verifying your identity and any applicable contractual or legal obligations, We will honor the request within 15 days of Our receipt.
Right to correct: you may request Us to correct any inaccurate, incomplete or outdated identifiable Personal Data about you that We hold.
Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to opt out of selling: We do not sell your Personal Data and you may request confirmation of this from Us.
Right to opt out of targeted advertising: you may request to opt out of Our processing your Personal Data for targeted advertising purposes.

Right to opt out of profiling: you may request to opt out of the automated processing of your Personal Data that We hold and use to evaluate, analyze, or predict personal aspects related to your economic situation, health, demographic characteristics, personal preferences, interests, reliability, behavior, location, or movements, but only to the extent that Our decision produces legal or similarly significant effects about you.
Right to opt in for sensitive Personal Data: the Site does not collect any sensitive Personal Data. Notwithstanding, if We collect your sensitive Personal Data via the Site, We will not process such data without your express consent.
Right to appeal: you may appeal Our denial of any right you exercised by email to privacy@betteroutcomesnow.com. Within 60 days of receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s).
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.
Right to complain: if We deny your appeal, you may contact the Department of Justice for the State of Delaware and file a complaint. To learn how, please visit: https://attorneygeneral.delaware.gov/fraud/cmu/complaint/.

Request Submission Process

If We have a good faith, reasonable basis to believe that your right to opt out request is fraudulent, We have the right to deny your request and notify you of Our decision and the reason(s).

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

For subsequent requests made in the same year or for any requests that are unfounded, excessive or repetitive, We may either (1) charge you a reasonable fee based on the administrative costs to comply with your request in which case We will first notify you along with the amount of the fee before We proceed with your request, or (2) deny your request and notify of Our decision and the reason(s).

Iowa

Your Privacy Rights: Effective 01/01/2025

As a resident of Iowa, starting on January 1, 2025, you may have the below listed rights under the Iowa Consumer Data Protection Act (“OCDPA”) that you may exercise twice in a year. However, these rights are not absolute and in certain cases We may deny your request or claim legal exemptions as permitted by the OCDPA and/or other applicable laws.

Right to withdraw: you may withdraw your previously given consent to collection, use, disclosure or any other form of processing of your Personal Data, subject to legal or contractual restrictions. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.
Right to know and access: you may request if We are or have processed your Personal Data that We hold and receive a list that identifies that data.
Right to portability: you have the right to receive a securely transmitted copy of the Personal Data We hold about you in an electronic format that you can access, read and electronically transmit.
Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to opt out of selling: We do not sell your Personal Data and you may request confirmation of this from Us.
Right to opt in for sensitive Personal Data: the Site does not collect any sensitive Personal Data. Notwithstanding, if We collect any sensitive Personal Data about or from you via the Site, We will not process that data without your express consent.
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.

Request Submission Process

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. If Our verification process is successful, We will respond within 90 days of receiving your verifiable request. To the extent required, We reserve the right to extend this 90-day period by another 45 days by notifying you within 90 days of Our receiving your request and tell you why We require additional time.

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

For any subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive, technically unfeasible, repetitive, or if We reasonably believe that your request is not for the primary purpose of exercising the right, We may either (1) charge you a reasonable fee based on the administrative costs to comply with your request in which case We will first notify you along with the amount of the fee before We proceed with your request, or (2) deny your request and notify you of Our decision and the reason(s).

Maryland

Your Privacy Rights: Effective 10/1/2025

As a Maryland resident, starting on October 1, 2025, you may have the below listed rights under the Maryland Online Data Privacy Act (“MODPA”) that you may exercise once a year. However, these rights are not absolute and in certain cases We may deny your request or claim legal exemptions as permitted by the MODPA and/or other applicable laws.

Right to know and access: you may request if We are processing your Personal Data that We hold, receive a copy of that data, and a list of the categories of third parties to whom We disclosed your Personal Data.
Right to portability: when exercising the right to access, you have the right to receive a securely transmitted copy of your Personal Data in an electronic format that you can access, read and electronically transmit.
Right to correct: you may request Us to correct any inaccurate identifiable Personal Data about you that We hold.
Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to opt out of targeted advertising: you may opt out of Our processing your Personal Data for targeted advertising purposes.
Right to opt in for targeted advertising as to children: We do not collect or process Personal Data of children for targeted advertising. Notwithstanding, if We have actual knowledge that you are between the ages of 13 to 17 years old, We will not process your Personal Data for targeted advertising without the consent of your parent or legal guardian.
Right to opt out of selling: We do sell your Personal Data and you may request confirmation of this from Us.

Right to opt out of profiling: you may request to opt out of the automated processing of your Personal Data We hold and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you, but only to the extent Our decision results in producing legal or similarly significant effects about you.
Right to appeal: you may appeal Our denial of any right you exercised by email to privacy@betteroutcomesnow.com. Within 60 days of receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s) for Our decision.
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.
Right to complain: if We deny your appeal, you may contact the Office of the Attorney General for the State Maryland and file a complaint. For information, please visit: https://www.marylandattorneygeneral.gov/Pages/CPD/complaint.aspx

Request Submission Process

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

For any subsequent requests made in the same year or for any requests are manifestly unfounded, excessive, technically infeasible, or repeated, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request in which case We will first notify you along with the amount of the fee before We proceed with your request, or (2) deny your request and notify you of Our decision and the reason(s).

Montana

Your Privacy Rights: Effective 10/01/2024

As a Montana resident, starting on October 1, 2024, you may have the below listed rights under the Montana Consumer Data Privacy Act (“MCDPA”) that you may exercise once a year. However, these rights are not absolute and in certain cases We may deny your request or claim legal exemptions as permitted by the MCDPA and/or other applicable laws.

Right to access and data portability: you may request for a securely transmitted copy of your Personal Data that We hold be sent to you in an electronic format that you can access, read and electronically transmit.
Right to correct: you may request Us to correct any inaccurate identifiable Personal Data about you that We hold.
Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to revoke: you may revoke your previously given consent to collection, use, disclosure or any other form of processing of your Personal Data. Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.
Right to opt out of selling: We do not sell your Personal Data and you may request confirmation of this from Us.
Right to opt out of targeted advertising: you may opt out of Our processing your Personal Data for targeted advertising purposes.

Right to opt out of profiling: you may opt out of the automated processing of your Personal Data that We hold and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you, but only to the extent Our decision results in producing legal or similarly significant effects about you.
Right to opt in for sensitive Personal Data: the Site does not collect any sensitive Personal Data. Notwithstanding, if We collect any sensitive Personal Data from or about you via the Site, We will not process such data without your express consent.
Right to appeal: you may appeal Our denial of any right you exercised to privacy@betteroucomesnow.com. Within 60 days of Our receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s).
Right of no retaliation: we will not retaliate or discriminate against you for exercising any of your rights.
Right to complain: if We deny your appeal, you may contact the Office of Consumer Protection of Montana and file a complaint.

Request Submission Process

If We cannot verify your identity or there is no reasonable method by which We can verify your identity to the degree of certainty required, We will notify you and state the reason(s).

If We have a good faith, reasonable belief that your opt out request is fraudulent, We have the right to deny your request. In such a case, We will notify you and state the reason(s) for Our belief.

You may designate another person as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent.

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

For any subsequent requests made in the same year or for any requests are manifestly unfounded, excessive, technically infeasible, or repeated, We may either (1) charge a reasonable fee based on the administrative costs of comply with your request in which case We will first notify you along with the amount of the fee before We proceed with your request, or (2) deny your request and notify you of Our decision and the reason(s).

New Hampshire

Your Privacy Rights: Effective 01/01/2025

As a New Hampshire resident, starting on January 1, 2025, you may have the below listed rights under the New Hampshire Expectation of Privacy Act (“NHEPA”) that you may exercise once a year. However, these rights are not absolute, do not apply to Business Data, and in certain cases We may deny your request or claim certain legal exemptions as permitted by the NHEPA and/or other applicable laws.

Right to know and access: you may request if We process your Personal Data that We hold and receive a copy of that data.
Right to portability: you have the right to receive a securely transmitted copy of your Personal Data that We hold in an electronic format that you can access, read and electronically transmit.
Right to correct: you may request Us to correct any inaccurate identifiable Personal Data about you that We hold.
Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to revoke: you may withdraw your previously given consent to collection, use, disclosure or any other form of processing of your Personal Data. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App. Subject to any exceptions, if We satisfactorily verify your identity, We will honor your request within 15 days of Our receipt.
Right to opt out of selling: We do not sell your Personal Data and you may request confirmation of this from Us.
Right to opt out of targeted advertising: you may opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy.

Right to opt out of profiling: you may opt out of the automated processing of your Personal Data We hold and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you, but only to the extent Our decision results in producing legal or similarly significant effects about you.
Right to opt in for sensitive Personal Data: The Site does not collect any sensitive Personal Data. Notwithstanding, if We collect any sensitive Personal Data about or from you, We will not process that data without your express consent.
Right to appeal: you may appeal Our denial of any right you exercised to privacy@betteroutcomesnow.com. Within 60 days of Our receiving your appeal, We will inform of Our decision and state the reason(s).
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.
Right to complain: if We deny your appeal, you may contact the Office of the Attorney General of New Hampshire and file a complaint. For information, please visit: https://www.doj.nh.gov/consumer/complaints/index.htm

Request Submission Process

If We have a good faith, reasonable belief that your request is fraudulent, We have the right to deny your request and notify you of Our belief and the reason(s).

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

For any subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs of complying with your request in which case We will first notify you along with the amount of the fee before We proceed with your request, or (2) deny your request and notify you of Our decision and the reason(s).

New Jersey

Your Privacy Rights: Effective 04/15/2025

As a New Jersey resident, starting on April 15, 2025, the New Jersey Privacy Act (“NJPA”) provides you with the below listed rights that you may exercise once a year. However, these rights are not absolute and in certain cases We may deny your request or claim legal exemptions as permitted by the NJPA and/or other applicable laws.

Right to know and access: you may request whether We disclosed any of your Personal Data that specifically identifies you or that could reasonably be linked or restored to specifically identify you to any third party and, if so, a list identifying the categories of those third parties who received your data limited to the prior 12 months of your request.
Right to portability: you have the right to receive a securely transmitted copy of your Personal Data We hold in an electronic format that you can access, read and electronically transmit.
Right to correct: you may request Us to correct any inaccurate identifiable Personal Data about you that We hold.
Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to revoke: you may withdraw your previously given consent to Our collection, use, disclosure or any other form of processing of your Personal Data, subject to legal or contractual restrictions. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App. Subject to any exceptions, if We satisfactorily verify your identity, We will honor your request within 15 days of Our receipt.
Right to know of selling: We do not sell your Personal Data and you may request confirmation of this from Us.
Right to opt in for targeted advertising as to children: We do not collect or process the Personal Data of children for targeted advertising. If We have actual knowledge that you are between the ages of 13 to 17 years old, We will not process your Personal Data for targeted advertising without your parent’s or legal guardian’s express consent.
Right to opt in for sensitive Personal Data: the Site does not collect any sensitive Personal Data. Notwithstanding, if We collect any sensitive Personal Data from or about you via the Site, We will not process that data without your express consent.
Right to opt out of targeted advertising: you may opt out of Our processing your Personal Data for targeted advertising purposes.

Right to opt out of profiling: you may opt out of the automated processing of your Personal Data We and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you, but only to the extent Our decision results in producing legal or similarly significant effects about you.
Right to appeal: you may appeal Our denial of any right you exercised to privacy@betteroutcomesnow.com. Within 45 days of Our receiving your appeal, We will inform of Our decision and state the reason(s).
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.
Right to complain: if We deny your appeal, you may contact the New Jersey Division of Consumer Affairs and file a complaint. For information, please visit: https://www.njconsumeraffairs.gov/Pages/Consumer-Complaints.aspx

Request Submission Process

If We have a good faith, reasonable belief that your request is fraudulent, We have the right to deny your request and notify you of Our belief and state the reason(s).

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

Nevada

Your Privacy Rights

As a Nevada resident, the Nevada Security and Privacy of Personal Information Act restricts the sale of your Personal Data to third parties. We do not sell your Personal Data to any third party, and you may request confirmation of this from Us by sending an email to privacy@betteroutcomesnow.com.

To protect your Personal Data, We must be able to verify your identity when you submit a request to exercise your right. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. If Our verification process is successful, We will respond to your request within 60 days of receiving your verifiable request. To the extent required, We reserve the right to extend this by notifying you with 60 days of Our receiving your verifiable request and telling you why We require the extension.

If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Oregon

Your Privacy Rights

As an Oregon resident, you may have the below listed rights under the Oregon Consumer Privacy Act (“OCPA”) that you may exercise once a year. However, these rights are not absolute and in certain cases We may deny your request or claim legal exemptions as permitted by the OCPA and/or other applicable laws.

Right to know and access: you may request if We are or have processed your Personal Data that We hold and request the categories of Personal Data that We process or have processed.
Right to correct: you may request Us to correct inaccurate identifiable Personal Data about you that We hold.
Right to revoke: you may withdraw your previously given consent to Our collection, use, disclosure or any other form of processing of your Personal Data, subject to legal or contractual restrictions. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App. Subject to any exceptions, if We satisfactorily verify your identity, We will honor your request within 15 days of Our receipt.
Right to delete: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to portability: you have right to receive a securely transmitted copy of the Personal Data We collected and hold about you in an electronic format that you can view and transmit.
Right to opt out of selling: We do not sell your Personal Data and you may request confirmation of this from Us.
Right to opt out of targeted advertising: you may opt out of Our processing your Personal Data for targeted advertising purposes.

Right to opt out of profiling: you may opt out of the automated processing of your Personal Data We hold and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you, but only to the extent Our decision results in producing legal or similarly significant effects about you.
Right to opt in for sensitive Personal Data: the Site does not collect any sensitive Personal Data. Notwithstanding, if We collect any sensitive Personal Data about or from you, We will not process that data without your express consent.
Right to appeal: you may appeal Our denial of any right you exercised to privacy@betteroutcomesnow.com. Within 45 days of receiving your appeal, We will inform you of any action We took or did not take and explain the reason(s).
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.
Right to complain: if We deny your appeal, you may contact the Oregon Department of Justice, Consumer Protection division and file a complaint. For information, please visit: https://www.doj.state.or.us/consumer-protection/contact-us/

Request Submission Process

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. If Our verification process is successful, We will respond within 45 days of receiving your verifiable request. To the extent required, We reserve the right to extend this 45-day period by notifying you within 45 days of your request and telling you why We require an extension.

If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required and We will state this in Our response and explain why We have no reasonable method by which We can verify your identity.

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

Except for a request to verify that We corrected any inaccuracies you reported to Us or a request to verify the deletion of your Personal Data, for any subsequent requests made in the same year or for requests that are manifestly unfounded, excessive, technically infeasible, or repeated, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request in which case We will first notify you along with the amount of the fee before We proceed with your request, or (2) deny your request and notify you of Our decision and the reason(s).

Virginia

Your Privacy Rights

As a Virginia resident, you may have the below listed rights under the Virginia Consumer Data Protection Act (“VCDPA”) that you may exercise twice a year. However, these rights are not absolute and in certain cases We may deny your request or claim legal exemptions as permitted by the VCDPA and/or other applicable laws.

Right to know and access: you may request if We process your Personal Data that We hold and receive a copy of that data.
Right to portability: you have the right to receive a securely transmitted copy of the Personal Data We collected and hold about you in an electronic format that you can access, read and electronically transmit.
Right to correct: you may request Us to correct any inaccurate identifiable Personal Data about you that We hold.
Right to delete: under certain circumstances, you may have the right to request that We permanently and complexly delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to opt out of selling: We do not sell your Personal Data and you may request confirmation of this from Us.
Right to opt out of targeted advertising: you may opt out of Our processing your Personal Data for targeted advertising purposes.

Right to opt out of profiling: you may opt out of the automated processing of your Personal Data We and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you, but only to the extent Our decision results in producing legal or similarly significant effects about you.
Right to appeal: you may appeal Our denial of any right you exercised to privacy@betteroutcomesnow.com. Within 60 days of Our receiving your appeal, We will inform of any action We took or did not take and explain the reason(s).
Right of no retaliation: We will not retaliate or discriminate against you for exercising any of your rights.
Right to complain: if We deny your appeal, you may contact the Office of the Attorney General of Virginia and file a complaint. For information, please visit: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint

Request Submission Process

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

Extra Requests

For any subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive or repetitive, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request in which case We will first notify you along with the amount of the fee before We proceed with your request, or (2) deny your request and notify you of Our decision and the reason(s).

Foreign Countries – Country Specific Privacy Rights

Note On International Transfers of Personal Data

As a global company operating in the United States, We collect, store and process Personal Data from individuals and businesses located in various countries. The United States may not have data protection laws as comprehensive or protective as those in your country of residence. When We collect Personal Data internationally, We implement appropriate technical and organization measures to protect your Personal Data, regardless of where it is processed or stored and comply with applicable legal requirements for international data transfers, such as, without limitation, using standard contractual clauses approved by relevant authorities or using other legally recognized and acceptable transfer mechanisms as required by applicable jurisdictions.

By using the Site or App, you acknowledge and consent to the transfer of your Personal Data from your country of residence to the United States, subject to the terms of this Policy and applicable data protection laws. If you have any questions or concerns about international transfers of your Personal Data, you may contact Our Privacy Officer at privacy@betteroucomesnow.com.

Argentina

Under the Argentina Personal Data Protection Law No. 25.326 (“PDPL”) you may have the below listed rights. However, these rights are not absolute and in certain cases We may deny your request and claim legal exemptions for certain types of data permitted by the PDPL and/or other applicable laws.

Right to information, access and content of information: you may request if We are processing your Personal Data that We hold, including the identity of the data controller, the purpose of Our processing, and the categories of data being processed. You may request to receive a copy of that data in which case We will deliver it to you within 10 calendar days of Our receipt, subject to Our verification of your identity. This right is exercisable free of charge at intervals of not less than 6 months. You have the right to receive a copy of your Personal Data in language accessible to the average knowledge of the population. At your option and direction, We can provide this to you in writing, by electronic, telephone, image or other suitable means.
Right to rectify: you may request Us to correct or update any inaccurate or incomplete identifiable Personal Data about you that We hold. Subject to Our satisfactory verification of your identity, We will correct and update such data within 5 working days of Our receiving your request.
Right to erase: under certain circumstances, you may have the right to request that We erase your Personal Data that We hold it’s no longer necessary for the purposes for which it was collected, subject to legal or contractual restrictions.
Right to object: you may object to Our processing of your Personal Data, including for automated decision-making, profiling, and for direct marketing purposes.
Right to withdraw: you may withdraw your previously given consent to Our processing of your Personal Data that We hold, subject to legal or contractual restrictions. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.

Request Submission Process

We will respond to your request within 10 calendar days of receiving your request. To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. We reserve the right to extend the 10-day period to respond to your request by notifying you within 10 days of receiving your request. In such cases, We will state reason(s) for the extension along with an estimated timeframe of when We will respond to your request [VC4] .

If We cannot verify your identity, We have the right to deny your request. In such cases, We will notify you and state the reason(s).

If your request involves data that is under the control or responsibility of another business, We will notify you within the same 10-day period and provide you with information about which entity is responsible and, where possible, how you can contact them to exercise your rights.

Canada

Under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), you may have the below listed rights. However, these rights are not absolute, and in certain cases We may deny your request or claim legal exemptions permitted by PIPEDA and/or other applicable laws.

Right to withdraw: you may withdraw your previously given consent to Our collection, use, disclosure or any other form of processing of your Personal Data. Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.
Rights to know, access or correct: you may request to know the types of your Personal Data We collected, the sources of Our collection, the categories of individuals who have access to the information within Our organization, the retention period for such information, whether your Personal Data is being sold or shared, and to whom it is being sold or shared. As stated in earlier this in Policy, We do not sell Personal Data and you may request confirmation of this from Us, and to receive a copy of this information. You may also request that We correct any inaccurate, outdated or incomplete identifiable Personal Data about you that We hold.
Right to delete: under certain circumstances, you may have the right to request We erase your Personal Data that We hold, subject to legal or contractual restrictions.
Data portability: you may request to receive your Personal Data We hold in a structured, commonly used and machine-readable format. You may also require that We share this information to another entity, where this is technically feasible.
Right to object or restrict processing: you may object to or restrict Our processing of your Personal Data under specific circumstances. Where your Personal Data is subject to restriction, We will only process it with your consent or for the establishment, exercise or defense of legal claims. In addition, you may have the right to object to processing (including profiling) where We are relying upon legitimate interests to process Personal Data.
Right to object to direct marketing (including profiling): you may object to Our use of your Personal Data (including profiling) for direct marketing purposes.

Request Submission Process

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. Once We have verified your identity, We will respond to your request within 30 days. If We require additional time or information to process your request, We will notify you along with specifying the additional time needed and the reason(s).

Our response is generally free of charge. In cases where Our performance to respond to your request requires significant resources, We reserve the right to charge a reasonable fee to cover Our actual cost of locating, retrieving, reviewing and copying the data related to your request.

We reserve the right to deny your request if We deem the request to be frivolous or vexatious. If We exercise this right, We will notify you and state the reason(s).

If your request involves data that is under the control or responsibility of another business, We will notify you within the same 30-day period and provide you with information about which entity is responsible and, where possible, how you can contact them to exercise your rights.

Chile

Under Protection of Personal Data Law of Chile (“PPDL”), you may have the below rights. However, these rights are not absolute, and in certain cases We may deny your request or claim legal exemptions as permitted by the PPDL and/or other applicable laws.

Right to know and access: you may request if We are processing your Personal Data, the sources from where We collected your Personal Data, the purpose of Our storage, and the recipients to whom We disclosed your Personal Data and receive a copy of this from Us.
Data portability: you have the right to receive a copy of your Personal Data that We hold in a structured, commonly used, and machine-readable format (such as an excel spreadsheet).
Right to correct: you may request Us to correct any inaccurate, incomplete or outdated identifiable Personal Data about you that We hold.
Right to erase: under certain circumstances, you may have the right to request that We erase your Personal Data that We hold if the purpose of Our storing it is no longer necessary for the purpose it was collected or to comply with Our legal, regulatory or contractual obligations.
Right to revoke: you may withdraw your previously given consent to collection, use, disclosure or any other form of processing of your Personal Data, subject to legal or contractual restrictions. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.
Right to object: object to Our processing of your Personal Data for direct marketing purposes.
Right to block: if you dispute the accuracy of your identifiable Personal data We hold or the lawfulness of Our processing, you may request that We temporarily suspend Our processing of your identifiable Personal Data until such time that the dispute is resolved or you authorize Us to lift the block.

Request Submission Process

We will respond to your request within 2 working days Our receipt of your request. Our response will be free of charge, provided it has been at least 6 months since this right was last exercised.

For requests that are repetitive, duplicative, vexatious, unusually complex or requires a significant amount of time and resources for Us to fulfill, We have the right to charge you a reasonable fee based on the administrative costs to comply with your request. In that case, We let you know before We take any action to comply with your request along with the amount of the fee.

If you are exercising a right that is the responsibility of another business, We will let you know so you may contact that business.

China

Under the Personal Information Protection Law of the People’s Republic of China (“PIPL”) you may have the below listed rights. However, these rights are not absolute, and in certain cases We may deny your request or claim legal exemptions permitted by the PIPL and/or other applicable laws.

Right to know and access: you may request if We process your Personal Data and, if so, receive a copy of it.
Right to correct: you may request Us to update, correct, complete or supplement any identifiable Personal Data about you that We hold.
Right to delete: you may request that We delete your Personal Data that We hold if the purposes of Our processing and storage have been achieved and We have no legal or compliance obligations for retaining it. However, if Our storage retention period has not expired, or the deletion of your Personal Data is difficult to be achieved technically, We will stop processing your Personal Data for all other purposes beyond storage and take necessary security measures.
Right to limit processing: you may request that We limit or restrict Our processing of your Personal Data, including by others who work on Our behalf, subject to legal or contractual restrictions.
Right to portability: you may request that We transfer your Personal Data that We hold to another processor that you designate, subject to Our means for the transfer satisfying the conditions prescribed by the cyberspace administration.
Right to withdraw: you may withdraw your previously given consent to Our future processing of your Personal Data that We hold. Consent may be withdrawn at any time, subject to legal or contractual restrictions. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.
Right of close relatives: in the event of your death, and unless you have arranged otherwise, any of your close relatives may exercise your rights to know, access, correct or delete and other rights related to your Personal Data.

Request Submission Process

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. We will respond to your request within a reasonable time of Our receipt of your verifiable request (typically within 30 days of receiving your request). Our response is free of charge.

If you are exercising a right that is the responsibility of another business, We will notify you so you may contact that business.

General Data Protection Regulations

If you are located in the EU, the EEA, UK or another country governed by the General Data Protection Regulations (“GDPR”) where the Site and App is made available, you may have the below listed rights[VC11] . However, these rights are not absolute, and in certain cases We may deny your request or claim legal exemptions permitted by the GDPR and/or other applicable laws [VC12] .

Right to know and access: you may request if We process your Personal Data and, if so, receive a copy of that data along with a statement that describes Our business purposes for processing, a list of the categories of your Personal Data We process, and a list of the recipients or categories of recipients to whom We have disclosed or intend to disclose the data.
Right to portability: you have the right to receive a copy of your Personal Data that We hold in a common, structured and machine-readable format that you can access, read and electronically transmit.
Right to correct: you may request Us to update, complete, or correct any identifiable Personal Data about you that We hold.
Right to erase: under certain circumstances, you may have the right to request that We permanently and completely delete your Personal Data that We hold, subject to legal or contractual restrictions.
Right to object to or limit processing: under certain circumstances, you may object to Our processing of your Personal Data that We hold if We no longer have a business purpose or where the accuracy of your identifiable Personal Data is disputed as inaccurate but only during the period of time in which We can verify the accuracy of the data at issue.
Right to withdraw: you may withdraw your previously given consent at any time, subject to legal or contractual restrictions. Note that your withdrawal will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your withdrawal.
Right related to automated decision-making and profiling: under certain circumstances, you have the right not be subject to decisions based solely on automated processing, including profiling, used to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you, but only to the extent the decision results in producing legal or similarly significant effects about you, subject to contractual obligations.
Right to complain: If you believe Our denial of any request you submitted to Us violates your rights or that We mishandled your Personal Data in violation of your legal rights, you may file a complaint with the applicable Supervisory Authority of the European Data Protection Board. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en

Request Submission Process

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. We will respond to your request within a reasonable time of Our receipt (typically within 30 days). If We are unable to verify your identity or not honor your request for other reasons, We will notify you and state the reason(s).

Our response to your request is free of charge, unless We find your request to be unjustified or excessive and, in this case, We will notify you and state the fee. For additional copies, We may also charge you a fee based on the administrative costs of complying with your request and, in this case, We will notify you in advance and state the fee amount.

If you are exercising a right that is the responsibility of another business, We will notify you so you may contact that business.

Mexico

Under Mexico’s Protection of Personal Data Held by Private Parties Law (“PPDHPPL”), you may have the below listed rights. However, these rights are not absolute, and in certain cases We may deny your request or claim legal exemptions permitted by the PPDHPPL and/or other applicable laws.

Right to know and access: you may request if We hold your Personal Data, how We obtained it, the purposes of Our processing, and with whom We share it with and receive a copy of this information delivered to you in a structured, commonly used and machine-readable format.
Right to rectify: you may request Us to correct any inaccurate, incomplete or outdated identifiable Personal Data about you that We hold.
Right to cancel: under certain circumstances, you may have the right to request that We delete your Personal data that We hold, subject to legal or contractual restrictions.
Right to object to processing: you may object to the processing of your Personal Data that We hold for direct marketing purposes, if your identifiable Personal Data We hold is inaccurate or incomplete, or where Our processing is excessive or disproportionate.
Right to revoke: you may revoke your previously given consent to Our collection, use, disclosure or any other form of processing of your Personal Data that We hold, subject to legal or contractual restrictions. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App.

Request Submission Process

You may exercise your right to access, rectification, cancellation and objection once every 12 months free of charge. You may submit a written request to privacy@betteroutcomesnow.com. When submitting your request, please include your full name, contact information, the nature of your request and any additional details that may help Us locate your Personal Data (e.g., website visitor, App subscriber, approximate timeframe when you used the Site).

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. If We cannot verify your identity, We have the right to deny your request. In such cases, We will inform you of the denial and the reasons.

We will respond to your request within 20 working days of receipt of your verifiable request. To the extent required, We reserve the right to extend the initial response period of 20 days by an additional 20 business days. If We exercise this right, We will notify you in writing before the expiration of the original response period, explaining the reasons for the extension.

You may also exercise your rights through your designated legal representative, subject to Our being able to verify their identity and authority to act on your behalf.

If you are exercising a right that is the responsibility of another business, We will notify you so you may contact that business.

Extra Requests

For additional access requests within the same 12-month period, We may charge a reasonable fee to cover the administrative costs of reproduction. We will inform you of any such costs within our response period before proceeding with your request including the amount of the fee.

New Zealand

Under the New Zealand Privacy Act 2020 (“NZPA”), you may have the below listed rights. However, these rights are not absolute, and in certain cases We may deny your request or claim legal exemptions permitted by the NZPA and/or other applicable laws.

· Right to know and access: you may request if We hold your identifiable Personal Data and receive a copy of that data.

Right to correct: you may request Us to correct any inaccurate, outdated, incomplete or misleading identifiable Personal Data about you that We hold. Subject to verifying your identity, We will notify you within 20 working days of receiving your request whether (1) We corrected or will correct your Personal Data, or (2) Our denial of your request along with the reason(s). In the case of denial, you have the right to provide Us with your written statement of correction that We will maintain with Our records of your identifiable Personal Data and to complain to the Privacy Commission about Our denial of your request. We reserve the right to extend the 20-day period to respond to your request by up to an additional 20 working days by notifying you within 20 working days of receiving your request, specifying the period of the extension and the reason(s [VC13] ), and any other information We may find is necessary.
Right to delete: under certain circumstances, you may have the right to request that We delete your Personal Data that We hold, subject to legal or contractual restrictions.

Request Submission Process

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. If We cannot verify your identity, We have the right to deny your request. In such cases, We will inform you of the denial and the reason(s).

You may ask that We treat your request of access or correction as urgent provided that your request states the reasons as to why your request should be treated as urgent. In such cases, We will consider your request and stated reasons to determine the priority to be given to responding to your request.

If you are exercising a right that is the responsibility of another business, We will either (1) transfer your request to that business within 10 working days of receiving your request and notify you along with the name of the business, unless you direct Us not to make the transfer in your original request, or (2) notify you within 20 working days of receiving your request that We do not hold your Personal Data or We do not hold your Personal Data in a way that enables Us to readily retrieve it.

We reserve the right to charge you a reasonable fee that covers Our administrative costs to respond or assist you with your request. In such cases, We will notify you of the cost and whether We require all or part of the cost to be paid in advance.

You may also exercise your rights through your designated agent, subject to Our being able to verify their identity and authority to act on your behalf.

South Korea

Under South Korea’s Data Protection Law (“DPL”), you may have the below listed rights. However, these rights are not absolute, and in certain cases We may deny your request or claim legal exemptions permitted by the DPL and/or other applicable laws.

Right to know, access and portability: you may request if We process your Personal Data, how We use it, with whom We have shared it, and receive a copy of it in electronic, machine-readable format that you can access, read and electronically transmit. You may exercise your right of access one per year free of charge. For any additional requests to access made in the same year, We reserve the right to charge you a reasonable fee and, in such cases, We will notify you and state the amount of the fee before We proceed with your request.
Right to consent: you have the right to decide whether or not to consent to the processing of your Personal Data that We hold and determine the scope of your consent to which We may process your Personal Data.
Right to correct: you may request Us to correct, update, or change any identifiable Personal Data about you that We hold.
Right to delete: under certain circumstances, you may request Us to delete your Personal Data that We hold when the original purpose for Our collection has been fulfilled, subject to legal or contractual restrictions.
Right to withdraw: you may withdraw your previously given consent to collection, use, disclosure or any other form of processing of your Personal Data, subject to legal or contractual restrictions. Depending on the circumstances, however, any withdrawal or amendment to your consent may prevent Us from providing you, or continuing to provide you, with Our services of the Site or App. Note that your withdrawal will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your withdrawal request.
Right to opt in for sensitive Personal Data. The Site does not collect any sensitive Personal Data. Notwithstanding, if We collect any sensitive Personal Data about or from you, will not process that data without your express consent.
Right to withdraw consent for business transfers: if We intend to transfer your Personal Data due to a business sale, merger or other type of business transfer, We will provide you with advance notice along with the name and contact information of the recipient and a method and procedure for you to withdraw consent if you so wish.
Right to withdraw consent for overseas transfers: you may withdraw your consent with respect to the transfer of your Personal Data to an overseas recipient. In such case, We will provide you with advance notice including the name and contact information of the recipient and a method and procedure for you to withdraw your consent.

Request Submission Process

To protect your Personal Data, We must be able to verify your identity. To verify your identity, We may compare the information you provide in your request to the personal information We have on file or ask for additional details. If We cannot verify your identity, We have the right to deny your request. In such cases, We will let you know and state the reason(s).

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your available rights, subject to Our being able to verify their identity and authority as your designated authorized agent.

Extra Requests

We reserve the right to charge you a reasonable fee if We find your request to be manifestly unfounded, excessive or repetitive in character. Before We proceed with your request or charge a fee, We will notify you and state the fee amount.

Changes to This Policy

We may add to, change, or otherwise update this Policy from time to time. We will post all changes to this Policy on this webpage. The updated policy will be effective as of the date it was posted. Your continued use of this Site or App after the “Last Updated” date indicated at the top of this Policy will constitute your acceptance and agreement to any changes and to Our collection and use of your personal information according to the terms and condition of Our then-current Policy. If you do not agree with this Policy at any time, you should not use the Site or App.

Contact Us

If you have any questions about this Policy, you may contact Us using any of the below contact details:

By Email: privacy@betteroutcomesnow.com

By Telephone: +1 (561) 239-3640, Monday through Friday, 9:00 AM to 5:00 PM Eastern Standard Time.

By Mail: Better Outcomes Now, Attn: Privacy Officer, 816 Avon Rd., West Palm Beach, Florida 33401