PRIVACY POLICY

Effective Date: 01-25-22

INTRODUCTION

This privacy policy describes how Vertroos Health, Inc. d/b/a Belongly (“Belongly,” “we,” “us,” or “our”) collects, uses, shares, and otherwise handles personal information about individuals (“you” and/or “your”) who visit and use any of our websites or mobile applications that include a link to this privacy policy, and any related products, features, and services (collectively, the “Services”).

By using the Services you acknowledge that you have read this privacy policy, and consent to the handling of your personal information as described in this privacy policy, which we may update from time to time as described in the “Changes to this Policy” section, below.

Belongly is a United States company. The Belongly Services are not intended for users outside of the United States and non-US mental health practitioners and scholars are not eligible for Belongly membership. By using the Services, you consent to your personal information being stored and otherwise processed in the United States as described in this privacy policy.

  1. COLLECTON OF INFORMATION

We collect personal information that you provide us directly, from third-party sources, and automatically when you use the Services as follows:

Information That You Provide To Us Directly

Belongly Member Accounts

When you register a Belongly account and become a Belongly member, we require you to provide certain personal information that varies depending on whether we have already created a professional profile for you, as described in the “Belongly Profiles and Member Accounts” section below. If you already have a profile, we ask that you verify the information, and if you do not we ask that you provide us some of the information typically included in a Belongly profile. All Belongly members must provide their e-mail address, and mental health practitioners and scholars are required to provide certain information about their education, such as school attended, year of graduation, and specialty.

Registering Belongly members also have the option to provide additional information to include in their profile, including clinical and professional interests, languages spoken at the office, profile photo, clinical or professional group or affiliations, internship, employment history, speaking engagements, publications, memberships and board certifications. You may choose to update or supplement the information you have provided us at any time as described in the “Updating Your Account Information” section below.

To enhance the accuracy and integrity of the Belongly mental health practitioner directory, we require registering members to verify their identity and credentials, which verification may require them to answer identity verification questions and/or provide us a professional e-mail address, a copy of their professional license, medical ID (if applicable) or other relevant documentation. While we take steps to verify that Belongly members are actually the mental health practitioners they claim to be, we make no guarantee as to any member’s identity, professional credentials or licensure status.

Submissions

We collect content and information that you submit to the Services (and information about you may be provided by other Belongly members), including comments, searches, contacts, schedule details, your resume, survey responses, contest entries, creative submissions, and member support requests.

Communications Tools

The Services include secure communication tools that enable our members to communicate with each other. We collect information about usage of these tools, such as when a member uses the tool. We do not monitor communication content.

Information Collected Automatically When You Use the Services

In addition to your personal information that you provide to us directly, we collect a variety of personal information automatically when you use the Services through the use of cookies and similar technologies (e.g., pixels, web beacons and device identifiers), which we refer to as “Log Data” as further described in the “Cookies and Similar Technologies“ section below. Log Data includes activity information such as the date and time that you access one of our sites or apps, and whether you view, click or otherwise interact with content, including articles, links, advertisements promoting the products and services of Belongly or our customers, open or click a link in one of our e-mails, conduct a search on one of our websites, share an article displayed in your newsfeed, or send, receive, or engage with a message sent through the Services. We collect device information including your IP address (which is a unique numerical address that identifies your device when you access the Internet), your browser and device type and model, operating system, your ISP and mobile carrier, your advertising ID (which is a unique, user-resettable identification number associated with a mobile device), other unique identifiers associated with your computer or mobile device, and the URL of the site from which you access our site.

The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of our content, including ads, and saving your preferences. For information about how you can manage your cookie preferences, refer to the “Choices Regarding Personal Information” section, below.

We do not collect precise location information unless you elect to enable location services on your device, but we do receive information about your general location at a city or zip code level through your computer’s IP address and your mobile device.

Information Obtained From Third-party Sources

We collect information from third-party sources, including government agencies, publicly available databases, professional associations, publications, employers, our business partners, service providers, customers, and other Belongly members, some of which we may add to your professional profile as described in the “Belongly Profiles and Member Accounts” section, below. For example, we may use third-party sources to obtain your National Provider Identifier (NPI) record, specialty, office address, phone and fax numbers, educational background, certifications, professional group affiliations, your publications and other professional achievements. We also may obtain e-mail addresses that we use to promote the Services to members and potential members, and prescribing and claims data that we may use to personalize content, including advertising.

  1.  USES OF INFORMATION

Except as otherwise provided herein, we may use the personal information we collect about you for the following business and commercial purposes:

Provision of the Services

We use your information to provide, operate, support, and improve the Services, including through the development of new tools and features.

Belongly Profiles and Member Accounts

We use your information to create and update your professional profile, which is generally viewable within the Services by default, regardless of whether you have registered a Belongly account, to create and maintain your Belongly member account if you choose to register, and to support and respond to your inquiries and requests.

Communications

We use your information to communicate with you about the Services. These communications may contain information about your professional connections, professional opportunities, conferences and other events (including whether your colleagues plan to attend, as informed by the event sponsor), relevant editorial content, and marketing about products and services of Belongly and our customers. These communications may be sent through a variety of channels, including on-site or in-app notifications and e-mail. We also use your information to process, store, and transmit your communications through the Services.

Professional Connections

We use your information to suggest potential connections to you and other Belongly members. For example, if we see that you and another member share a contact or attended the same university, we may suggest that you and that member connect as colleagues. We use your information to enhance our Belongly search feature to help you find information and learn more about other Belongly members. For example, you can search for mental health practitioners and scholars with particular expertise, or that you may know from your university or clinic/hospital. We also use your information, including your name and photo, to notify other Belongly members of notable professional events, such as when you receive an award, are mentioned in the news or publish a work. We may also inform your connections when you like, share or comment on a newsfeed article, make a new Belongly connection or update your profile.

Professional Opportunities

We use your information to recommend professional opportunities to you (and you to those offering such opportunities), including through our career search function, advertisements, and direct messages that we may send to you on behalf of recruiters and other Belongly clients with whom you may not be directly connected on Belongly, as further described in the “Commercial Clients“ section below.

Personalizing your Experience

We use your information to personalize the Services including content, employment opportunities, marketing messages, and advertising served to you on our sites and third-party sites, and to generally enhance your Belongly experience. For example, we tailor your newsfeed to focus on content relevant to your practice, specialty and inferred interests based on your profile and how you engage with the Services. We use your information to target (and measure the performance of) advertising and other content sponsored by third parties, including (for example) promoting relevant potential career opportunities to you. Advertising will be identified as an “Advertisement,” “Sponsored,” “Promoted” or some similar designation indicating that the content is promotional and has been selected by the third-party sponsor.

Other Uses of Your Information

We also use your information to detect, investigate, and prevent fraudulent, harmful, unauthorized, unethical or illegal activities to protect the rights, safety and property of Belongly, our members and others, including through the enforcement of our Terms of Service, in connection with legal proceedings, including arbitration, and to comply with our legal obligations. Also, we may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

  1. SHARING OF INFORMATION

In connection with the activities described above, we may share your personal information with third parties as follows:

Social Networks

As described in the “Belongly Profiles and Member Accounts” section above, we create your professional profile within the Services, which is generally viewable within the Services by other members of the Services by default.  Once you create a Belongly account and claim your profile, you are able to designate certain aspects of your profile as private, such as mobile phone, home phone, other phone, and e-mail address (“Private Profile Information”). We will only share Private Profile Information with Belongly members who you authorize, except as otherwise specified in this privacy policy. Note that any personal information you elect to share within Belongly’s social network is visible to Belongly’s members. For example, if you engage in social actions, e.g., by liking or commenting on an article in your newsfeed, those activities will be shared with other Belongly members. Also, we may include social widgets on our sites and apps that enable you to interact with the associated social media services, e.g., to share an article, and in connection with such interaction these third parties may collect personal information about you. You may be able to manage your privacy preferences directly with the applicable social network platform.

Business Partners

We may share your profile information with trusted business partners that we work with to provide services to you and others, including mental health practitioner directories and ranking bodies. These services increase the visibility of our members and their employers in the mental health market, thereby increasing their business and professional opportunities.

Service Providers

We may share your information with third parties that help us provide the Services and operate our business, including in the areas of website and database hosting and maintenance, telecommunications, information security, fraud detection and prevention, e-mail management, data analytics, marketing, advertising, member support, and identity and professional credential verification.

Commercial Clients

We provide our commercial clients, including hospitals, outpatient facilities, recruiters, colleges and universities, and life science companies, with profile search and messaging tools as part of our talent and marketing services businesses. They use these tools to select members that may be interested in their information and opportunities, including in the areas of employment and other professional opportunities, events, clinical trials, innovative therapies, and other clinical and non-clinical solutions, and we communicate their messages to the selected Belongly members on their behalf. We may also provide our commercial clients with limited member information in connection with our audience development and performance reporting for their advertising and other sponsored content programs delivered through the Services. When you engage with sponsored content, we may share with the sponsor and its agency limited information from your Belongly profile such as your name, expertise, and zip code, along with details about the engagement such as whether you viewed and or interacted with an advertisement. Prior to sharing this information, we require the recipients to agree to limit their use to the authorized purpose. We do not share your Private Profile Information or any personal contact information with our commercial clients without your consent.

CME/CE Providers

As part of our Services, we may share your personal information with Continuing Medical Education (CME) and Continuing Education (CE) providers who provide and/or certify CME and CE activities that we offer through the Services, for the purpose of processing CME or CE activities in which you choose to participate, and as required for their accreditation compliance and record keeping purposes. We may forward to you e-mails from these organizations in connection with your participation in the applicable activities, including to send you CME/CE credit certificates you have earned.

Advertising Partners

We work with third-party partners to serve advertising for us on third-party sites and to evaluate the effectiveness of our advertising. These third parties use cookies and similar technologies to collect information about your use of our sites, other sites and online services over time, including certain Log Data described above, so they can display our ads to you on other sites and apps. For example, if you visit Belongly and also use a social media platform, you may see a Belongly ad in your social media newsfeed. We also work with third-party partners to develop custom audiences to whom our ads can be delivered outside of Belongly. For example, we may provide hashed versions of member e-mail addresses to Facebook who then matches it to the corresponding Facebook member accounts to create a Belongly “Custom Audience” on Facebook, to which it can target Belongly ads. These activities, known as interest-based advertising, are intended to make the ads you see online more relevant to your interests. Please see the “Choices Regarding Personal Information” section below for information about opting out of interest-based based advertising.

Business Transferees

We may share your personal information in connection with a business transaction (or potential transaction) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Belongly or our corporate affiliates (including, in connection with a bankruptcy or similar proceedings).

Affiliated Companies

We may share personal information with our corporate affiliates for use consistent with this privacy policy.

Authorities

We may access, preserve, and share your information with third parties, as required or permitted by applicable law, if we believe it is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us, which may involve disclosure to law enforcement, courts, or governmental authorities. Also, if you provide us information about an adverse event relating to a pharmaceutical product or medical device, we may be required to report this information along with your contact information to the manufacturer so it can comply with legally required reporting obligations.

Other Third Parties

We may access, preserve, and share your information if we determine it is reasonably necessary or appropriate to investigate, prevent or take action regarding suspected fraudulent, harmful, unethical or illegal activities, or any violation of our Terms of Service or to protect and defend the legal rights, safety, and property of Belongly, our employees, agents and contractors (including to enforce our agreements) or in connection with any safety or security concerns, including the personal safety of our members and the public.

With Your Consent

We also may share your personal information with a third party in a manner not addressed by this privacy policy with your consent.

  1.  COOKIES AND SIMILAR TECHNOLOGIES

We and our service providers and partners, as described above, use various tools to collect data when you visit our sites and apps, including cookies, pixel tags, and other similar technologies. These technologies enable us to track usage of the Services and to enhance the user experience by providing a more relevant and personalized online experience. A cookie is a small data file that is sent to a user’s browser when visiting a website. It is stored, accessed and maintained on the computer’s hard drive or on a tablet or mobile device. A cookie contains a unique number that allows a website to recognize a particular user’s device each time that user visits the website so they don’t need to log in each time they visit and their preferences can be stored. Cookies enable us to measure the use and effectiveness of our content, track user trends, monitor and stabilize our websites, and improve the quality of the Services and content personalization (including ads) both on Belongly and third-party sites.

Most browsers can be set to reject all cookies, including third-party cookies, however, if you choose to reject our cookies, your ability to access and use the Services will be limited. We and our partners also use pixel tags, often in conjunction with cookies. Pixel tags are small pieces of code that are embedded on web pages and apps in order to provide us with information about how our sites and apps are used. We also include pixel tags in our e-mails to inform us whether the recipient has opened those e-mails and/or clicked on links in those e-mails.

  1. THIRD-PARTY LINKS

Our Services may contain links to third-party sites. Any access to and use of such linked sites is not governed by this privacy policy, but instead is governed by the privacy policies of those third-party sites, which we encourage you to read. We are not responsible for the information practices of such third-party sites.

  1. SECURITY

We employ technical, administrative and physical safeguards designed to protect your personal information. However, no security measure can guarantee security and that data will not be accessed, disclosed, altered, or destroyed. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a complex password that nobody else knows or can easily guess, and keeping your log-in credentials private. We are not responsible for any lost, stolen, or compromised passwords or for any unauthorized account activity.

  1.  DATA RETENTION

We will retain your personal information for at least the period reasonably necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. If we delete some or all of your personal information, we may continue to retain and use aggregate or anonymous data previously collected and/or aggregate or anonymize your personal information.

  1. CHOICES REGARDING PERSONAL INFORMATION

Your Account and Profile Information.

If you have registered a Belongly account, you may review and update certain personal information through your account settings. If you prefer to submit an update request to us directly, or if you wish to close your account, please contact us at [email protected].

Opting Out of Marketing E-mails

You may opt-out of receiving marketing e-mails from Belongly at any time by opting out via the link the e-mail footer, adjusting your account settings or sending an opt-out request to [email protected]. Please be aware that you cannot opt-out of receiving services messages from us including security and legal notices.

Controlling Cookies and Interest-based Advertising

If you would prefer not to accept cookies, visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. Most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Note that rejecting cookies will not prevent device identification and related data collection from occurring. Also, if you choose to reject cookies, your access to some functionality and areas of the Services may be restricted. For additional information about cookies visit www.allaboutcookies.org.

As described above, we allow certain third-party partners to place tracking technologies on the Services for the purpose of delivering interest-based advertising to you on third-party sites. You can opt-out of certain third-party interest-based advertising services we may use by visiting the following links: for Google: Google Marketing Platform opt-out page; For Twitter: Twitter’s Privacy Controls for Personalized Ads; For Facebook: Facebook Ad Preferences; and for LinkedIn: LinkedIn General Advertising Preferences.

You can learn more about managing your preferences for interest-based ads online, particularly for many third-party advertising networks, by visiting the Network Advertising Initiative and the Digital Advertising Alliance. Note that even if you opt-out from interest-based advertising through these organizations’ tools, cookies may still be used to collect data for purposes other than interest-based advertising, including analytics. Also, you will still see ads, but they will not be targeted based upon the information collected through these tracking technologies. When using the preferences and opt-out settings described above, you will need to apply them on every device and on every browser from which you wish to opt-out. Because some of these settings rely on a cookie that stores your preferences, if you delete or clear your browser’s cookies, you may need to opt-out again. You can also control interest-based advertising on your mobile device by enabling the “Limit Ad Tracking” setting on your iOS device or “Opt out of Ads Personalization” on your Android devices.

Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. We do not respond to “Do Not Track” signals at this time.

Google Analytics

We use Google Analytics to track and analyze certain traffic and usage statistics regarding the use of our Services, such as the number of visitors to our Services, how visitors are navigating to our Services, visitors’ general geographic region information, how long individuals are visiting our Services, and information about the equipment individuals are using to access our Services (e.g., browser version and operating system).  Google Analytics may use a Google Analytics cookie and may collect your IP address or mobile device ID as part of this service (but neither we nor Google Analytics otherwise collects or processes any of your personal information in connection with our use of the Google Analytics services).  We use this traffic and usage information to gauge, internally, the effectiveness of our advertising efforts and to make improvements to our Website and our marketing and promotional efforts.

In addition, we may use the following Google Analytics Advertising Features:

  • Remarketing
  • Google Display Network Impression Reporting
  • Google Analytics Demographics and Interest Reporting
  • Google Ads (an integrated service with Google Analytics)

By enabling these features, we would be permitting Google to collect certain additional traffic and usage data using a Google Advertising cookie and other identifiers not tied to your personal information.  This information includes demographic information about our Services and general information about our visitors’ interests, but does not identify our visitors individually.  In fact, we are prohibited by Google policy from using this information to try to identify individual users and from merging non-personally identifiable information obtained from Google with personal information we otherwise have about you without obtaining your separate consent.  We use the information collected through our use of the Google Analytics Advertising Features to segment our audience and to better target our advertising and marketing efforts.  For more information, please review the following:

You can opt out of our use of certain Google Analytics features by updating the “Ads Settings” in your browser (www.adssettings.google.com/authenticated) or mobile device (www.support.google.com/ads/answer/1660762#mob), by visiting the Network Advertising Initiative’s Consumer Opt-Out page at www.optout.networkadvertising.org/, or by visiting Google’s currently available opt-outs over the web at www.tools.google.com/dlpage/gaoptout/.

Push Notifications

If you consent to receive push notifications, you may withdraw your consent at any time by adjusting the appropriate operating system settings on your mobile device.

  1.  CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this privacy policy at any time and in our sole discretion. When we make a change, we will update the “Effective Date” and post the updated policy on or through the Services. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as by e-mail (if you have an account where we have your contact information) or another manner through the Services. Any modifications to this privacy policy will be effective upon posting or as otherwise indicated at the time of posting. In all cases, by continuing to use the Services after posting of the updated policy, you are consenting to the changes. If you object to any changes, you may close your account by contacting [email protected].

  1. CALIFORNIA PRIVACY NOTICE

California law provides its residents with additional rights regarding their personal information. To learn more about California privacy rights, please visit our California Privacy Notice.

  1. CONTACT US

If you have any questions about this privacy policy or Belongly’s privacy practices, you may reach us at 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