CALIFORNIA PRIVACY NOTICE

Effective Date: 01-25-2022

This privacy notice applies only to California residents. It describes how Vertroos Health, Inc. d/b/a Belongly (“Belongly,” “we,” “us,” or “our”) collects, uses and shares Personal Information of California residents in connection with their use of the Services and their rights with respect to that Personal Information. For purposes of this notice, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA, including protected health information subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). This notice is intended to supplement, and should be read in conjunction with, our Privacy Policy.

  1. Categories of Personal Information we collect and share with third parties for business and commercial purposes.The following is a list of all categories of Personal Information specified in Section 1798.140(o)of the CCPA that Belongly has collected from California residents in the twelve (12) months prior to the Effective Date, together with (1) examples of the types of Personal Information we collect within that category, and (2) the categories of sources from which we collect such Personal Information:
CategoriesExamplesSources
IdentifiersName, username/password, email address, office and/or home address, office and/or personal phone numbers, IP address or mobile device ID and other similar identifiersYou, third parties including public sources, service providers, publications, commercial clients
Customer Records InformationName, physical characteristics or description (which may be apparent from a photo), address, telephone number, education, employment and employment historyYou, and third parties including business partners, service providers, commercial clients, employers, public sources, publications
Protected Class CharacteristicsAge and sex (we may not intentionally collect this information, but it may be revealed by other information we collect, e.g., photo, year of graduation, affiliations, etc.)You and third parties including business partners, employers, service providers, public sources
Internet or Network InformationBrowsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisementYou
Geolocation DataCity, state, and zip codeYou (directly and indirectly from your IP address and/or mobile device ID)
Employment InformationCurrent and past employmentYou and third parties including business partners, service providers, commercial clients, employers, public sources, publications
Inference DataInferred preferences and interestsAutomatically generated internally based on other information we collect about your use of the Services as described in this notice

You can learn more about our Personal Information source, the business or commercial purposes for which we collect your Personal Information, and the categories of third parties with whom we share your Personal Information in our Privacy Policy.

  1. Your California privacy rights.California residents have the rights listed below. However, these rights are not absolute and exceptions apply, so in certain cases we may decline your request as permitted by law.
  2. Information.You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected
  • The categories of sources from which we collected Personal Information
  • The business or commercial purpose for collecting and/or selling Personal Information
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient
  1. Access.You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  2. Deletion.You can ask us to delete the Personal Information that we have collected from you.
  3. Opt-out of sales.If we sell your Personal Information, you can opt-out.
  4. Nondiscrimination.You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.
  5. How to exercise your rights. If you are a California resident, you may exercise your California privacy rights described above, subject to certain exceptions, as follows:
  • You can request to exercise your information, access and deletion rights by contacting us via your account at [email protected]. We will verify your request using information associated with your Belongly account. Government or other identification may be required. You may designate an authorized agent to make a request on your behalf, in which event we will require a valid power of attorney and the authorized agent’s government issued identification, and we may verify the authenticity of the request directly with you. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. Also, if we are unable to verify your identity or authority, we may not be able to fulfill your request. We do not keep sufficient information to enable us to readily link an identified individual with information collected from such individual in connection with a prior visit to the Services unless the individual accessed the Services as a logged-in member.

Note that we may deny your deletion request if retaining your information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Also, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication from some of its requirements, including access and deletion rights.

  1. Response times and format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will deliver our written response to you via e-mail and/or by posting such response to your Belongly account. Any disclosures we provide will only cover the 12-month period preceding our receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
  2. Right to opt-out of the “sale” of your Personal Information. Like many providers of free online resources, Belongly relies on advertising revenue to support the operation and development of our Services, including editorial content, communication tools, and professional networking and employment opportunities. Also, like some other providers of online commercial resources intended for use by mental health professionals, we may report to our commercial clients if and how specific Belongly members engaged with their advertising content displayed on the Belongly platform, as described in our Privacy Policy. These reporting activities have involved the sharing of your name, zip code, and ad engagement information during the twelve (12) months prior to the Effective Date. Based on our current understanding of the CCPA, these reporting activities may constitute a “sale” of Personal Information. California residents can request to opt-out of such sales by sending a request to [email protected]or by submitting a request via mail to: Vertroos Health, Inc. d/b/a Belongly, Attn: Legal Department, 964 High House Rd #3011, Cary, North Carolina 27513. We will send a message to your Belongly account asking that you verify your request. Please note that we do not provide advertisers with our members’ personal contact information or information about non-member visitors.
  3. Changes to this Privacy Notice.Belongly reserves the right to modify this notice at any time in our sole discretion in accordance with the procedure described in our Privacy Policy.
  4. Contact Information.If you have any questions about this notice or Belongly’s privacy practices, or wish to exercise your rights under California law, please do not hesitate to contact us any time by e-mailing [email protected] or by contacting us at:

Vertroos Health, Inc. d/b/a Belongly
Attn: Legal Department
964 High House Rd #3011
Cary, North Carolina 27513