This privacy policy (“Privacy Policy”) explains how the Grow Therapy Community (“we,” “us,” and/or “our”) collects, uses, and discloses information from individuals (“you” and/or “your”) who access and use our online community or mobile or other downloadable applications (collectively, the “Community”). Beyond the Privacy Policy, your use of the Community is also subject to our Community Terms of Service.

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases (for example if we plan to use your information in a way that materially differs from this Privacy Policy), we will provide you with additional notice (such as sending you a notification).

We encourage you to review the Privacy Policy whenever you access the Community or otherwise interact with us to stay informed about our information practices and the choices available to you.

Personal Information We Collect

Personal Information You Provide to Us.

Registration and Profile Information. When you open an account with us through the Community (“Account”), we may ask you to provide us with identifiers and contact information such as your name, email address, and any other information you may provide.

Communications. We may also collect identifiers, such as your name, email address, and other information you choose to provide, when you participate in any interactive features of the Community like send us a message through the Community, fill out a form, publish statements on our platform, participate in a contest or promotion, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us.

Messages Between Members. When you communicate with other members through the Community, we and our third-party partners receive the content of the messages you send and receive and information about those messages, such as when it was sent or received.

Content. We may collect other content and information you share through the Community when you submit information or content, such as by commenting on a blog or participating in online communities, or when you otherwise interact with the Community.

Personal Information That May Be Collected Automatically Through the Community.

When you access or use the Community or transact business with us, we and our third-party partners may automatically collect information you provide to us, information about how you access and use the Community and information about the device you use to access the Community, including:

Device Identifiers. Identifiers, such as your IP address, internet service provider, the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID), and identifiers associated with browser cookies, web beacons, and similar technologies we deploy on the Community.

Internet or Other Electronic Network Activity Information. We and our third-party partners may collect information about the devices and computers you use to access our Community, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you use our Community, we may collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Community and other information about your internet activity (“Usage Information”), including the pages you visit, the links you click, the ads you view and click on, videos you watch, your location when you access or interact with our Community, and other similar actions. We may also use third-party tools to collect Usage Information you provide to us or information about how you use the Community and may record your mouse movements, scrolling, clicks and keystroke activity and other browsing or search behavior. These tools may also record Usage Information you enter when you interact with the Community or engage in chat features through the Community.

Geolocation Information. We may derive the approximate location of your device from your IP address. We may combine this information with other location-based information, such as your postal code. You have the ability to stop the collection of precise location information at any time (see “Your Choices” below for details).

Information From Cookies and Similar Technologies. We and our third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Community.

Please review your web browser’s “Help” file to learn how you may modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Community, you may not be able to utilize the features of the Community to their fullest potential.

Personal Information Collected from Third Parties.

Information from Third-Party Sources. When you interact with our members in the Community, we may collect from them any content or information you choose to share or provide. We may also obtain information about you from other sources, including but not limited to social media platforms, marketing partners, and other third parties. For example, if you connect your social media account to your Account or create or log into your Account through a social media site, certain information from your social media account will be shared with us, which may include information that is part of your profile or your friends’ profiles.

Personal Information Usage

We use the information we collect about you to:

• provide, maintain, and improve the Community and to enhance and personalize your experience;
• send you technical notices, updates, security alerts, and support and administrative messages;
• respond to your comments, questions, and requests, and to provide customer service;
• communicate with you about products, services, offers, promotions, rewards, and events offered by the Community and others, and provide news and information we think will be of interest to you;
• monitor and analyze trends, usage, effectiveness and activities in connection with the Community, including our offers, advertising, communications features, and customer service;
• detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of the Community;
• facilitate contests, sweepstakes, and promotions, and process and deliver entries and rewards;
• link or combine with information we get from the Community and from others to help understand your needs and provide you with better service;
• maintain appropriate records for internal administrative purposes; and
• carry out any other purpose described to you at the time the information was collected or permitted by law.

A Note on Health Information. The Community is a peer discussion space and is not part of your clinical care, and it is not covered by HIPAA. Please do not post or share protected health information (PHI), medical record numbers, diagnoses, treatment details, or other sensitive health information about yourself or anyone else in the Community. Any health-related information you choose to share in posts, comments, or messages is treated as User Content under our Community Terms of Service, not as part of your medical record, and may be visible to other members. If you are in crisis or need clinical support, please contact your provider directly or call or text 988 (Suicide & Crisis Lifeline) or 911 for emergencies.

Personal Information Disclosure

With Partners and Affiliates. We may disclose any information we receive to our partners, corporate affiliates, parents, or subsidiaries for any purpose described in this Privacy Policy.

With Gradual. The Community is powered by a technology platform provided by Gradual, Inc. (“Gradual”). We may disclose your information to Gradual in connection with the provision of the Community.

With Service Providers and Vendors. We may disclose your information to other vendors, consultants, and service providers retained in connection with the provision of the Community.

With Other Members of the Community. If you provide or share information with other members of the Community, they may use it for their own purposes. If you post information or content, such as by posting photos, commenting on a blog, or participating in the Community, or when you interact with the Community through social media sites, plug-ins, or other applications, depending upon your privacy settings, this information may become public on the internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

With Analytics Partners. We may use analytics services to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources.

With Legal and Law Enforcement. We may share information collected about you with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Community member to legal liability or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

With Emergency Response Services. In rare circumstances, if we reasonably believe that another member may be at imminent risk of serious physical harm or self-harm, we may access or disclose limited personal information to appropriate emergency response services. We will limit such disclosures to the minimum amount of personal information necessary and use this information solely to protect life or physical safety.

With AI providers or Large Language Models (LLMs). We may use certain AI-powered features to help us operate this community. These features are provided through Gradual or other third-party vendors and operate on models built by trusted third‑party providers. These providers have been chosen for product fit and strong security and privacy oversight. Through these AI-powered features we may process your personal data to generate responses and enhance your experience. However, we will not use your personal data to train, fine-tune, or improve any external AI models. Data processed by AI models is handled securely and no information is stored, retained, or logged by the AI model provider.

With your Consent. Where applicable, we may share your information with your consent or at your specific direction.

In Connection with a Change of Control. We may transfer or disclose your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

Children’s Privacy

The Community is not intended for individuals under the age of 18. No one under the age of 18 is authorized to provide any personal information through the Community. We do not knowingly collect personal information from the Community from members in this age group. If we learn that we have collected or received personal information from a child under the age of 18, we will take reasonable steps to delete that information. If you believe we might have any information from or about a child under 18, please contact us at the email address below.

Social Sharing Features

The Community may offer social sharing features and other integrated tools, which let you share actions you take on the Community with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Third-Parties

The Community may contain links to other websites, including our affiliated or co-branded websites and communities. Other websites and communities may also reference or link to the Community. These other websites and communities may not be controlled by us. We encourage our members to read the privacy policies of every website, community, or mobile application that collects personal information. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of other websites, communities, or mobile applications. Visiting these other websites is at your own risk.

Security

We make reasonable efforts to protect your information by using security measures designed to safeguard the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Transfer of Information to the U.S.

The Community is hosted in the United States and is intended solely for use by individuals located in the U.S. If you access or use the Community from outside the U.S., please note that any information you provide, including personal information, will be transferred to and processed in the U.S., where privacy laws may differ from those of your country or region. By using the Community from outside the U.S., you acknowledge and consent to this transfer, storage, and processing in the U.S.

Your Choices

Account Information. You may update and correct certain Account information you provide to us at any time by logging into your Account. If you wish to delete or deactivate your Account, you may email us at community@growtherapy.com but note that we may retain certain information as required by law or for legitimate business purposes.

Location Information. If you initially consent to our collection of this location information through the Community, you can subsequently stop the collection of this information at any time through your device’s operating system settings. If you do so, certain features may no longer function properly.

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Mobile Push Notifications/Alerts. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Your California Privacy Rights
If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”):

• Right to Know. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the purpose for collecting it, and the categories of third parties with whom we share it.
• Right to Delete. You may request that we delete personal information we have collected from you, subject to certain exceptions permitted by law.
• Right to Correct. You may request that we correct inaccurate personal information we maintain about you.
• Right to Opt Out of Sale/Sharing. We do not sell personal information for money. However, our use of certain cookies and analytics/advertising technologies may be considered a “sale” or “sharing” of personal information under the CCPA. Gradual honors Global Privacy Control (GPC) signals as a valid opt-out request. If your browser or device sends a GPC signal, we will treat it as an opt-out of any sale or sharing of your personal information.
• Right to Limit Use of Sensitive Personal Information. We do not knowingly collect sensitive personal information through the Community. If we do collect sensitive personal information, you may direct us to limit its use to purposes necessary to provide the Community.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights.
• Authorized Agents. You may designate an authorized agent to submit requests on your behalf, subject to our ability to verify that authorization.

To exercise these rights, contact us at community@growtherapy.com. We will verify your request using information associated with your Account before responding, and you may appeal a denied request by contacting us at the same address.

Categories collected/disclosed: In the preceding 12 months, we have collected and disclosed the categories of personal information described in “Personal Information We Collect” above, for the business purposes described in “Personal Information Usage” and “Personal Information Disclosure.”

California Shine the Light. California residents may request certain information regarding our disclosure, if any, of personal information to third parties for their own direct marketing purposes during the preceding calendar year. To make such a request, please email us at community@growtherapy.com with “Shine the Light Request” in the subject line. We will respond within the time required by law.

Contact Us

If you have any questions, comments or concerns about our Community Privacy Policy, you may email us at community@growtherapy.com.