Last Updated: March 3, 2020
WHO WE ARE
We are Lyra Health, Inc., a company focused on helping people feel emotionally healthy at work and at home. As an employer-sponsored benefit that connects employees and their dependents with effective and convenient care for their mental and emotional well-being, we combine technology, research-backed therapeutic methods, and top providers to offer personalized care.
WHAT WE COLLECT
We get information about you in a range of ways.
Information You Give to Us or Lyra affiliated entities. We may collect your name, postal address, email address, phone number, username, password, demographic information (such as your gender and birth date) as well as other information you directly give us on our Site and/or through our Services. By providing us with an email address, you consent to receiving information from us by email to that address, including protected health information which is private to you and protected by HIPAA.
Information We Get From Your Lyra Benefit Sponsor. We may receive information from your Lyra benefit sponsor (typically your employer) to enable us to confirm you, your dependents, or your household member(s)’ eligibility for Lyra benefits, to contact you in order to inform you of the availability of the Lyra benefit, and to help us measure the effectiveness of the Lyra benefit.
Information Automatically Collected. We automatically log information about you and your computer, phone, tablet, or other devices you use to access the Site and/or Services. For example, when visiting our Site or when using the Company’s mobile applications, we log your computer or device identification, operating system type, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site or in the Company’s mobile applications. How much of this information we collect depends on the type and settings of the device you use to access the Site and/or Services.
Cookies. We may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Other similar tools we may use to collect information by automated means include web server logs, web beacons and pixels. This type of information is collected to make the Site and/or Services more useful to you and to tailor the experience with us to meet your special interests and needs.
California Do Not Track Disclosure. We currently do not support the Do Not Track browser setting or respond to Do Not Track signals. Do Not Track (or DNT) is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you. For more details about Do Not Track, including how to enable or disable this preference, visit https://termsfeed.com/do-not-track.
If you choose to interact on the Site and/or through the Services (such as by registering; using our Services; completing questionnaires, surveys, service contacts, or requests for information) the Company will collect the personal information that you provide. We may collect personal information about you that you provide through telephone, email or other communications. If you provide us with personal information regarding another individual, we will assume that you have that person’s consent to give us his or her personal information.
USE OF PERSONAL INFORMATION
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you. We use your personal information as follows:
- To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to
- help establish and verify the identity and eligibility of users;
- provide search results and notifications that are most relevant for you;
- open, maintain, administer, and manage Service users profiles and accounts;
- provide, deliver, operate and maintain the Services and other products and services that you request, including those from our selected partners;
- link or combine user information with other personal information, such as when you use Services offered by Lyra Clinical Associates P.C. or our other contracted providers of clinical services;
- respond to comments and questions and provide customer service; and
- send information including confirmations, notices, updates, security alerts, and support and administrative messages.
- For example, we use the information you provide when you register(e.g., first name, last name, the micro-site you are using) to verify eligibility for our Services. When you share with Lyra your needs and preferences around clinical care, we may use algorithms and automated decision-making to identify and surface providers who may be a good fit for you based on the information you provide (although you always have the choice to consider more providers than what Lyra surface). When you seek clinical care through one of affiliated providers, we may combine information about you and your clinical activities to provide an integrated experience.
- For research and development: We are always looking for ways to make our Services smarter, secure, integrated and useful to you. We use collective learnings about how people use our Services and feedback provided to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services; to analyze and improve our Site and/or Services (including developing new products and services); improving safety; managing our communications; analyzing our products; performing market research; for peer-reviewed and non-peer-reviewed clinical research; and performing data analytics. For example, we used information collected about how users engage with our micro-sites to design a better, more user-friendly user experience. In some cases, we may apply these learnings across all our Services to improve and develop similar features or to better integrate the Services you use. We also test and analyze certain new products, workflows, and user experiences with some users before rolling them out to all users.
- To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including sending you reminders, responding to your comments, questions and requests, providing customer support, soliciting outcomes and feedback, and sending you technical notices, updates, security alerts, and administrative messages. Depending on your settings, we send you email notifications when you or others interact on the Services, for example, when you are sent a message from your Lyra provider through our Services. We also provide tailored communications based on your activity and interactions with us. For example, certain actions you take in the Services may automatically trigger a feature or third-party app suggestion within the Services that would support your care. We also send you communications as you onboard to a particular Service to help you in using that Service. These communications are part of the Services and in most cases you cannot opt out of them as they are an integral part of our Services. If an opt out is available, you will find that option within the communication itself or in your account settings.
- To market, promote, and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, products and services offered by our selected partners, survey requests, and articles we think may be of interest to you. You can control whether you receive these communications within the communication itself or in your account settings.
- For Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services. Where you give us permission to do so, we share your information with a Lyra expert for the purpose of responding to support-related requests.
- For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity, identify violations of Service policies, authenticate, protect against, investigate, and deter fraudulent, unauthorized, or illegal activity.
- To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, accounting, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
- With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured client stories to promote the Services, with your permission.
- If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
We may combine all of the information that we collect with data obtained from third parties or through our products and Services. We may also collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
Lyra will take reasonable precautions to protect your information from loss, misuse or alteration. Please be aware, however, that any text, email or other transmission you send unencrypted through the Internet cannot be completely protected against unauthorized interception. In particular, we want to make you aware that personal email may be unsecure, and Lyra cannot be responsible for any unauthorized access to information when information is sent to your personal email. You are not required to authorize the use of email for this purpose, a decision not to consent or to opt out of receiving these emails will not restrict your ability to access care from your provider, and you can continue to receive other emails from Lyra, using our secure electronic communication system instead of your personal email. Our secure electronic communication system will require you to log into a separate portal to access the email that is being sent.
SHARING OF PERSONAL INFORMATION
Personally Identifiable Information: We will not rent or sell your personally identifiable information to others without your consent, although we may share it with partners for the purposes described above under “Use of Personal Information”, such as the provision and personalization of Services. For example, we may share your personal information with our contracted partners, such as Lyra Clinical Associates P.C., to provide you with Services, with third parties who help us with our business functions, such as payment processing or data storage, and with business partners. Such third parties are not authorized to use or disclose your information except as necessary to perform Services or comply with legal requirements, and are subject to agreements requiring them to maintain the confidentiality of any such information. If you seek treatment or other services from a clinical provider, such as Lyra Clinical Associates P.C. in its capacity as a health care provider, the use and disclosure of your health information in connection with such services will be governed by its separate HIPAA Notice of Privacy Practices, available at www.lyrahealth.com/hipaa-notice/. We also reserve the right to disclose personal data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
We may store personal information in North American locations outside our direct control (for instance, on servers or databases co-located with hosting providers). In the event that personal information is compromised as a breach of security, Lyra will promptly notify our customers, users, and clients in compliance with applicable law. We will retain personal data we process for as long as needed to provide our Services, and as recommended to comply with our legal obligations (including those under HIPAA), resolve potential or actual disputes, conduct research and development for our Services, or enforce our agreements.
Any personally identifiable information you elect to make publicly available on our Sites or through the Services, such as posting comments on our blog page, will be available to others. If you remove information that you have made public on our Sites or through the Services, copies may remain viewable in cached and archived pages of our Sites or through the Services, or if other users have copied or saved that information.
Non-Personally Identifiable Information: We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help us understand the usage patterns for certain Services and those of our partners. Lyra may also share with your Lyra benefit sponsor the outcomes and impact of our Services, which would consist solely of non-personally identifiable information, e.g., aggregated and anonymized data. Non-personally identifiable information may be stored indefinitely.
HOW INFORMATION IS STORED AND PROCESSED
Your information is stored in databases maintained by the Company or third parties that are located within North America, where privacy rules differ and may be less stringent than those of the country in which you reside. For E.U. residents, please note that we are not located in the E.U., nor do we collect or process the personal data of EU residents. As such, Lyra is neither a controller nor a processor under the EU’s General Data Protection Regulation (GDPR).
You should be aware that when you are on the Site and/or using our Services, you can be directed to other websites that are beyond our control, and we are not responsible for the privacy practices of third parties or the content of linked websites.
HOW INFORMATION IS PROTECTED
We are committed to protecting your privacy and data. We encrypt sensitive information (e.g. your login credentials, PII) during transmission and storage. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you, other involved parties, and any applicable regulator(s) of a breach where we are legally required to do so.
However, no method of transmission over the Internet or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of our Services, you can contact us at firstname.lastname@example.org.
INFORMATION CHOICES AND CHANGES
Our marketing emails tell you how to “opt-out.” After doing so, you will not receive future promotional emails unless you open a new account, or sign up to receive newsletters or emails. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about personal information to our Contact Information below or to email@example.com. You can request to change contact choices, opt out of our sharing with others, and update your personal information.
You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.
RIGHTS OF CALIFORNIA RESIDENTS
This privacy notice describes the personal information we collect or process about California residents in connection with the Site or the Services, how we use, share, and protect that personal information, and what your rights are concerning personal information that we collect or process.
In this section, “personal information” has the same meaning as under the California Consumer Privacy Act (CCPA), California Civil Code Section 1798.83: information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include information that has been de-identified or aggregated or information that is considered “PHI” under HIPAA or medical information protected under California’s Medical Information Act.
Personal Information We Collect and Share, and For What Purpose: In the past 12 months, we have collected and shared personal information from visitors in the following circumstances when they interact with the Site or the Services, as described in detail above:
- Information You Give to Us or Lyra affiliated entities
- Information We Get From Your Lyra Benefit Sponsor
- Information We Get From Others
- Information Automatically Collected
As described in detail above, we use your personal information for a variety of purposes to operate, assess activity on, and improve the performance of the Site, including the following:
- To provide the Services and personalize your experience
- For research and development
- To communicate with you about the Services
- To market, promote, and drive engagement with the Services
- For Customer support
- For safety and security
- To protect our legitimate business interests and legal rights
Except as described in detail above, we will not share with third parties information about you without your consent.
We do not share your personal information with third parties for third party marketing purposes.
Your Rights as a California Resident: Under California law, users who are California residents have specific rights regarding their personal information. These rights are subject to certain exceptions described below. When required, we will respond to most requests within 45 days unless it is reasonably necessary to extend the response time.
Right to Disclosure of Information: You have the right to request that we disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:
- The categories of personal information we have collected about you in the last 12 months.
- The categories of sources for the personal information we have collected about you in the last 12 months.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.
Right to Delete Personal Information: You have the right to request that we delete any of your personal information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your personal information, we will do so unless otherwise authorized by law.
How to Exercise these Rights: You may submit a verifiable consumer request to us for disclosure or deletion of personal information by clicking here. We will respond to verifiable requests for disclosure or deletion of personal information free of charge, within 10 days of receipt.
In order to protect your privacy and the security of your information, we verify consumer requests by matching personal information that you provide with information in our possession, in order to confirm your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney under Probate Code sections 4000-4465 may submit a request on your behalf.
Right to Opt Out of Sales of Your Personal Information: You have a right to opt-out of the sale of your personal information. You may, at any time, direct businesses that sell your personal information to third parties not to sell your personal information.
We do not sell your personal information and therefore do not provide any mechanism for you to exercise the right to opt out.
Right to Non-Discrimination: You have the right not to be discriminated against for the exercise of your California privacy rights described above.
Minors: We do not knowingly collect or maintain the personal information of children under 13. If we learn that we have collected any personal information of a child under 13 without affirmative authorization under the CCPA or verifiable parental consent under the Children’s Online Privacy Protection Act (COPPA), we will delete that information from our files as quickly as possible.
Lyra Health, Inc.
287 Lorton Avenue
Burlingame, California 94010