TheraPay® Rewards Website and/or Application Privacy Policy
Effective: April 2, 2025
This Privacy Policy describes how Reciprocity Health ("Reciprocity Health" "we", "our", or "us") collects uses, shares, and protects personal information.
For questions about our privacy practices, please email us at privacy@reciprocityhealth.com.
1. SCOPE
This Privacy Policy applies to information we collect in our capacity as a controller when you interact with the TheraPay Rewards website (www.therapayrewards.com) and/or application (the "Services").
Reciprocity Health contracts with health plans and healthcare providers to deliver TheraPay, a program designed to improve health outcomes through incentive-based engagement. TheraPay acts as a processor or business associate when our clients engage us for these services. When we process information on behalf of a client in the course of these services, our processing is governed by our agreement with the client, and this Privacy Policy does not apply to such processing. If you have questions about how information is processed in those circumstances, or if you wish to exercise privacy rights for information we process on behalf of a client, please refer to the client’s policies and contact the client directly.
Please note that this Privacy Policy does not apply to non-Reciprocity Health websites or services that state that they are offered under a different privacy policy. Please review the privacy policies on those websites and applications directly to understand their privacy practices.
2. THE INFORMATION WE COLLECT
Depending on the nature of your interaction with Reciprocity Health, we may collect personal information as follows:
- Directly from you, when you provide information to us or interact with us:
- Account information, such as your name, email address, and selected password.
- Contact information, including your name, telephone number, email address, mailing address, and any other information you choose to include when you communicate with us.
- Survey information in response to questions we may send you, including for feedback and research purposes.
- Any additional information you choose to provide, including questions, suggestions, and feedback.
- Automatically from you, device information and online user activity when you visit our Services, as described in the next section.
3. COOKIES AND INFORMATION COLLECTED BY AUTOMATED MEANS
Certain information is automatically collected from you when you interact with our Services. This information includes:
- Usage details about your interaction with our Services, such as the date, time, and length of visits, specific pages or content accessed during the visits, search terms, frequency of the visits, and referring website address.
- Device information about the device you use to access our Services, such as IP address, device type, unique device identifier, operating system, browser type, and mobile network information.
- Location information where you choose to provide us with access to information about your device’s location.
Much of this information is collected through cookies and other tracking technologies, which may be operated by our partners who assist us in providing the Services, understanding usage of the Services, security, and fraud prevention.
You can modify your browser setting to disable or reject cookies across the internet; but if you do so, some features of our Services may not function properly or be available. Please note that you will need to set preferences on each device you use to visit our Services.
You may opt-out of some third-party cookies by visiting their opt-out pages. These are examples of our cookie providers, but the list is not exhaustive. In addition, we are not responsible for the effectiveness of any of these opt-out mechanisms:
- We use Google Analytics to collect Services usage details. You can learn more about privacy and Google Analytics here, and opt out of collection of your data by using the Google Analytics Opt-out Browser Add-on.
Because definitions and rules for "Do Not Track" have not yet been established, we do not respond to "Do Not Track" signals.
4. HOW WE USE YOUR INFORMATION
We use the personal information we collect from you to:
- Provide our Services to you; manage, maintain, and operate your account and the Services; diagnose or fix technology problems; monitor the performance of the Services; and understand Services usage.
- Respond to your requests and questions; communicate with you; provide troubleshooting and other support; provide important notices; and send you information that may be of interest to you.
- Improve the Services; grow our business; better understand our consumer base; administer surveys for market research; and develop new products and services.
- Design and administer marketing campaigns and evaluate the effectiveness of these campaigns.
- Comply with legal requirements; defend against legal claims or other demands; respond to subpoena, court order, or other legal process or request; protect the rights of Reciprocity Health, you, or others; and detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
We may use and share information in an aggregated or de-identified manner our discretion, including for research, analysis, modeling, marketing, and improvement of our Services.
5. HOW WE SHARE YOUR INFORMATION
We may share the information we collect in the following instances:
- With service providers that we believe need the information to perform a technology, business, or other professional function for us such as IT services, accounting, auditing, and tax services, and other professional services.
- With entities in our corporate family, for purposes consistent with this Privacy Policy, to carry out our business activities, and to the extent permitted by law.
- When a corporate event occurs, we reserve the right to transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.
- For legal purposes; where necessary to comply with the law; in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights; as required to enforce our terms of use or other contracts; to defend against legal claims or demands; or to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
6. HOW WE PROTECT AND STORE YOUR INFORMATION
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf. If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries
7. INFORMATION CHOICES
You may have certain choices when it comes to how we collect and use your personal information:
- Account information: Please visit your TheraPay account to update and view certain information associated with your account, such as your password.
- Email marketing: If at any time you no longer wish to receive marketing communications from us, you can click the unsubscribe link at the bottom of any email.
- Push notifications: The Services may send push notifications. If you no longer wish to receive push notifications, you can opt out by adjusting your device setting or preferences.
8. UPDATES TO THIS PRIVACY POLICY
We may make changes to this Privacy Policy from time to time. The date at the top of this Privacy Policy indicates when this Privacy Policy was last revised. If we make material changes to this Privacy Policy, we will notify you through written, electronic, or other means.