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:
3. COOKIES AND INFORMATION COLLECTED BY AUTOMATED MEANS
Certain information is automatically collected from you when you interact with our Services. This information includes:
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:
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:
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:
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:
8. NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (Cal. Civ. Code §1798.100 et seq., as amended, "CCPA", or "CPRA"), gives California residents rights and control over their Personal Information. Reciprocity Health provides this statement to California residents in accordance with requirements under the CCPA/CPRA to make certain disclosures about the collection and processing of their Personal Information. This is Reciprocity Health’s California-specific description of consumers' privacy rights under the CCPA/CPRA.
We Do Not Sell Your Personal Information
Under the CCPA/CPRA, a business that sells California residents’ Personal Information to others:
Reciprocity Health does not sell Personal Information, including Personal Information of anyone under 16 years old, without consent.
Your Rights Under the CCPA/CPRA
1. Right to know what Personal Information is being collected, for what purposes and with whom it is shared
California residents have the right to request from a business disclosure of the categories and specific pieces of Personal Information it has collected from them in the preceding 12 months, the categories of sources from which such Personal Information is collected, the business or commercial purpose for collecting or selling such Personal Information, and the categories of third parties with whom the business shares Personal Information.
If you request that a business disclose categories and specific pieces of Personal Information collected about you, you have the right to receive that information, free of charge, twice a year. The information may be delivered by mail or electronically and, if provided electronically, shall be in a portable and, to the extent technically feasible, readily usable format that allows the California resident to relatively easily transmit this information to another entity.
2. Right to know whether your Personal Information is sold or disclosed for a business purpose and to whom
California residents have the right to request from a business that sells or discloses Personal Information for a business purpose separate lists of the categories of Personal Information collected, sold or disclosed for a business purpose in the preceding 12 months, including the categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
3. Right to say no to the sale of your Personal Information
As explained above, the CCPA/CPRA requires businesses that sell Personal Information to allow residents the ability to opt out of the selling of their information.
4. Right to non-discrimination of service or price if you exercise your privacy rights
The CCPA/CPRA prohibits businesses from discriminating against a California resident for exercising any of their rights under the CCPA/CPRA, including by:
5. Right to deletion
California residents have the right to request that a business delete any of their Personal Information that the business collected from them, subject to the exceptions in CCPA §1798.105.
To Exercise Your CCPA/CPRA Rights
Request: Do Not Sell or Share My Personal Information
To request that Reciprocity Health does not share your personal health information, contact us at 1-866-469-7973 or by emailing help@therapayrewards.com. Please include your full name, phone number, email address, physical mailing address, which third party company you would like to apply this request to, what type of request you are making (i.e., Access My Information; Delete My Information; Request Categories of Information Collected/Shared; or Other), where you would like the information delivered (email or physical address), and how you prefer to be contacted (email or phone).
By submitting a request, you authorize a TheraPay representative to contact you to verify your request and to perform the Type of Data Request requested. Your request will not be performed until we are able to verify your identity, and the identity and authority of anyone who may attempt to act on behalf of another person, in accordance with applicable law. Any request may be denied if it cannot be verified.
Reciprocity Health will verify your request within seven (7) days and complete the request within 45 days from receipt of the request, as required by law.
Request: Limit the Use of My Sensitive Personal Information
To request that Reciprocity Health limits the use of your personal health information, contact us at 1-866-469-7973 or by emailing help@therapayrewards.com. Please include your full name, phone number, email address, physical mailing address, which third party company you would like to apply this request to, what type of request you are making (i.e., Access My Information; Delete My Information; Request Categories of Information Collected/Shared; or Other), where you would like the information delivered (email or physical address), and how you prefer to be contacted (email or phone).
By submitting a request, you authorize a TheraPay representative to contact you to verify your request and to perform the Type of Data Request requested. Your request will not be performed until we are able to verify your identity, and the identity and authority of anyone who may attempt to act on behalf of another person, in accordance with applicable law. Any request may be denied if it cannot be verified.
Reciprocity Health will verify your request within seven (7) days and complete the request within 45 days from receipt of the request, as required by law.
Appeals Process
If we deny your privacy request, you may ask us to review that decision. To appeal, please contact us within 30 days at help@therapayrewards.com or 1-866-469-7973 and include the details of your original request. We’ll review your appeal and respond within 45 days. If your appeal is denied, we’ll explain why and let you know how you can contact the California Privacy Protection Agency or the California Attorney General.
Security
Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. That said, we employ a variety of organizational, technical and administrative measures to provide a level of security appropriate to the risk associated with the Personal Information you trust us with.
To that end, we manage our data protection program consistent with ISO 27001 (ISO/IEC 27001:2022).
Reciprocity Health protects Personal Information under its control and requires its service providers to also protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to, personal data transmitted, stored, or otherwise processed.
If you have concerns about the security of your information with Reciprocity Health, please contact us immediately at help@therapayrewards.com to report an issue.
Data Retention & Limitation
We retain your Personal Information only as long as necessary to accomplish the business purpose for which it was collected or to comply with our legal and contractual obligations, and then securely dispose of that information. Reciprocity Health ensures that the contracts we enter into with clients and partners explicitly defines the limits to data use. If an individual wishes to opt out of, or limit the use of their data at any time, they can do so by contacting us at 1-866-469-7973 or emailing help@therapayrewards.com.
Reciprocity Health Sub-Vendor Directory
(Last updated: December 2024)
Reciprocity Health/Clutch shares information with service providers and other third parties who perform services on our behalf. This page provides a list of vendors with whom we share Personal Information as well as describes where each is located and what services these vendors provide for us.
Subvendor — Service Provided — Headquarters Location
9. 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.
Copyright © 2025 Reciprocity Health Inc.