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Privacy Policy

Privacy Policy

Mantra Health Privacy Policy

Last modified: August 17, 2023.

1. Introduction

This Privacy Policy (our “Privacy Policy”) supplements Mantra Health, Inc.’s (“Mantra,” “we,” “us,” and “our”) Terms of Use and describes how Mantra and Wellround collect, use, maintain, protect, and disclose Personal Data about you through the use of Site and Services, and through email, text, and other electronic communications between you and Mantra and/or Wellround.

We respect your privacy, and we are committed to protecting it through our compliance with this policy.

This Privacy Policy applies to information we collect:

  • on the Site;
  • in email, text, and other electronic messages between you and the Site;
  • through the Services;
  • when you interact with our advertising on third party websites and services, if such advertising includes links to this Privacy Policy.

It does not apply to information collected by any third party, including through any content (including advertising) that may link to or be accessible from or on the Site.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Site. By accessing or using the Site, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Site after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Protected Health Information

Please see the Wellround Notice of Privacy Practices below to understand how we protect, use and disclose your protected health information as defined under the Health Insurance Portability and Accountability Act of 1996 and related laws and regulations. Mantra follows the Notice of Privacy Practices as a “business associate” of Wellround. If your Personal Data is protected health information, we treat that data in accordance with the Notice of Privacy Practices.

3. Children Under the Age of 13 and Majority

The Site is not intended for children under the age of 13. Children under the age of 13 are strictly prohibited from using the Site and Services. We do not knowingly collect Personal Data from persons who are under the age of 13. If you are under the age of 13, do not use or provide any information on the Site or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under the age of 13, we will delete that information. If you believe we might have any information from a child under the age of 13, please contact us at hi@mantrahealth.com.

If you access or use the Site or Services, you represent and warrant that you are either at least 18 years old or otherwise have adequate authority and capacity to consent to use the Site and the Services under applicable state laws, federal laws or the authorization of a parent or legal guardian who agrees to be bound by these Terms (or have approval to treat from Mantra/Wellround). Anyone under age 18 that does not have sufficient authority and capacity to consent to access or use the Services may not provide any information to or through the Site without our permission. We do not knowingly collect Personal Data from persons who lack adequate authority and capacity to consent to access and use the Services. If you are under 18 and lack sufficient authority to access or use the Services, do not use or provide any information on the Site or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at hi@mantrahealth.com.

4. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally

We collect several types of information from and about users of the Site, specifically information:

  • by which you may be personally identified, such as name, postal address, billing address, shipping address, e-mail address, mobile telephone number, driver’s license (or other government identification) information, including number, photo, and other associated information, date of birth, credit or debit card number (for payment purposes only), photos of you, Social Security Number, your medical history, and health information (“Personal Data”);
  • that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to the Site, error information, clickstream data, and other communication data and the resources that you access and use on the Site; or
  • about your Internet connection, the equipment you use to access the Site and usage details.

We collect this information:

  • directly from you when you provide it to us;
  • automatically as you navigate through the Site (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies); and
  • from third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through the Site is:

  • information that you provide by filling in forms on the Site (this includes information provided at the time of registering to use the Site, using Wellround Provider consultation services, purchasing products, reporting a problem with the Site, or requesting further services);
  • records and copies of your correspondence (including email addresses), if you contact us; and
  • details of transactions you carry out through the Site and of the fulfillment of your orders (you may be required to provide financial information before placing an order through the Site).

You also may provide information (hereinafter, “posted”) to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

  • details of your visits to the Site, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to the Site, error information, clickstream data, and other communication data and the resources that you access and use on the Site; and
  • information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve the Site and to deliver a better and more personalized service by enabling us to:

  • estimate our audience size and usage patterns;
  • store information about your preferences, allowing us to customize the Site according to your individual interests; or
  • recognize you when you return to the Site.

The technologies we use for this automatic data collection may include, among others:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting, you may be unable to access certain parts of the Site. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.
  • Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of certain parts of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, and other tracking technologies, to help the Site analyze how users use the Site. You can find out more about how Google uses data when you visit the Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

5. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

  • provide the Site to you;
  • provide products and Services to you;
  • provide you with information you request from us;
  • enforce our rights arising from contracts;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • notify you about changes;
  • provide you with newsletters, advertisements, and other promotional communications (with your consent); 
  • to contact you in response to a request;
  • to fulfill any other purpose for which you provide it; 
  • for any other purpose with your consent; and
  • provide you with notices about your Account.

With your consent, we may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by contacting us at hi@mantrahealth.com.

6. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. 

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

  • to service providers and other third parties we use to support our business (the services provided by these organizations include providing IT and infrastructure support services, and ordering, marketing, and payment processing services);
  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Mantra about the Site users are among the assets transferred;
  • to fulfill the purpose for which you provide it (for example, we may disclose your personal information to a health care provider);
  • for any other purpose disclosed by us when you provide the information; and
  • with your consent.

We may also disclose your Personal Data:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Mantra, our customers, or others (this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

In addition, we may disclose aggregated information about our Users, and information that does not identify any individual, without restriction.

7. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties as described in our Terms of Use. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

  • Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.
  • Promotional Offers from Mantra. If you do not wish to have your email address used by Mantra to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or by contacting us at hi@mantrahealth.com. This opt out does not apply to information provided to Mantra as a result of a product purchase, or your use of our Services.
  • Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

8. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You can review and change your Personal Data by logging into the Site and visiting your Mantra Portal Account Settings page. You may also contact us at  hi@mantrahealth.com regarding any of your rights under applicable state laws; any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible; or to delete your account. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

Please note that for your use of the Mantra Hub, only your preferred name and correct email address will be collected and cannot be changed.

9. Do Not Track Signals

We currently do not use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals.

10. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to the Site confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.

The safety and security of your information also depends on you. Where you have chosen a password for the use of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Site. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or in your operating system.

11. International Users

The Site and Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of the Site or Services may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal data as the one in which you reside. However, we will handle your Personal Data in accordance with this Privacy Policy regardless of where your Personal Data is stored/accessed.

12. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. If we make material changes to how we treat our Users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Site’s home page and invite you to review (and accept, if necessary) the changes. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Site and reviewing this Privacy Policy to check for any changes.

13. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below.

How to Contact Us:

Mantra Health, Inc.

Attn: Privacy Officer

c/o Primary Co-working

26 Broadway #356 

New York, NY 10004

Telephone: +1 240-307-4648

Email: privacy@mantrahealth.com

Notice of Privacy Practices

Last updated August 17, 2023

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This Notice of Privacy Practices (the “Notice”) describes how Wellround, as an affiliated covered entity composed of multiple distinct medical groups including but not limited to Wellround Provider Group, P.A., Wellround Medical Group, Wellround Provider Group of New Jersey, P.A., Wellround Provider Group of California, P.C., and Wellround Provider Group of Kansas, P.A. (collectively, “we” or “our”) may use and disclose your protected health information to carry out treatment, payment, or business operations and for other purposes that are permitted or required by law. “Protected health information” or “PHI” is information about you, including demographic information, that may identify you and that relates to your past, present or future physical health or condition, treatment or payment for health care services.

This Notice also describes your rights to access and control your protected health information.

USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION:

Your protected health information may be used and disclosed by our health care providers, our staff, and others outside of our office that are involved in your care and treatment for the purpose of providing health care services to you, to support our business operations, to obtain payment for your care, and any other use authorized or required by law. 

TREATMENT:

We will use and disclose your protected health information to provide, coordinate, or manage your health care and any related services. This includes the coordination or management of your health care with a third party. For example, your protected health information may be provided to any other health care provider with whom you have an existing treatment relationship to ensure the necessary information is accessible to diagnose or treat you.  

PAYMENT:

Your protected health information may be used to bill or obtain payment for your health care services. For example, we may use your PHI in connection with processing payments for services provided to you.

HEALTH CARE OPERATIONS:

We may use or disclose, as needed, your protected health information in order to support the business activities of this office. These activities include, but are not limited to, improving quality of care, providing information about treatment alternatives or other health-related benefits and services, development or maintaining and supporting computer systems, legal services, and conducting audits and compliance programs, including fraud, waste and abuse investigations.  We may de-identify and anonymize your information such that it is no longer considered protected health information or personally identifiable information and as such, will not contain any reference to you. In that instance, we may modify or create derivative works which contain this de-identified and anonymized information and may use that information as may be necessary to enhance the services we are providing. In addition, we may use this de-identified information for non-commercial purposes including but not limited to analytics, research, preparation of case studies and other educational and research related publication and usage. Under no circumstances will we sell or commercially market your information.

USES AND DISCLOSURES THAT DO NOT REQUIRE YOUR AUTHORIZATION

We may use or disclose your protected health information in the following situations without your authorization. These situations include the following uses and disclosures: as required by law; for public health purposes; for health care oversight purposes; for abuse or neglect reporting; pursuant to Food and Drug Administration requirements; in connection with legal proceedings; for law enforcement purposes; to coroners, funeral directors and organ donation agencies; for certain research purposes; for certain criminal activities; for certain military activity and national security purposes; for workers’ compensation reporting; relating to certain inmate reporting; and other required uses and disclosures. Under the law, we must make certain disclosures to you upon your request, and when required by the Secretary of the Department of Health and Human Services to investigate or determine our compliance with the requirements of the Health Insurance Portability and Accountability Act (“HIPAA”). State laws may further restrict these disclosures.

If you are a student user accessing the Site by virtue of an agreement between Mantra, Wellround and your school (“University”) for the provision of the telemental health services (“Student User”), you will receive treatment from Wellround physicians, nurse practitioners, therapists, and other providers (“Wellround Providers”) through the Mantra platform. Your protected health information (“Student Patient Information”) means information, data, and other content, including, but not limited to, clinical, laboratory data, or referral information provided by your University or you to Mantra and/or Wellround, in any form or medium. You acknowledge that as a result of the Services to be provided hereunder, Mantra and Wellround will have access to and/or obtain your Student Patient information including, but not limited to, your medical and referral records. Mantra and Wellround may share that information with relevant University providers or officials as may be applicable and consistent with any agreement that Mantra and Wellround have with your University.

USES AND DISCLOSURES THAT REQUIRE YOUR AUTHORIZATION:

Other permitted and required uses and disclosures will be made only with your consent, authorization or opportunity to object unless permitted or required by law. In such cases, without your authorization, we shall not use or disclose your protected health information.

You have the right to receive an accounting of certain disclosures of your protected health information that we have made, paper or electronic, except for certain disclosures which were pursuant to an authorization, for purposes of treatment, payment, healthcare operations (unless the information is maintained in an electronic health record), or for certain other purposes.

You have the right to obtain a paper copy of this Notice, upon request, even if you have previously requested its receipt electronically by e-mail.

REVISIONS TO THIS NOTICE:

We reserve the right to revise this Notice and to make the revised Notice effective for protected health information we already have about you as well as any information we receive in the future. You are entitled to a copy of the Notice currently in effect. Any significant changes to this Notice will be posted on the Site. You then have the right to object or withdraw as provided in this Notice.

BREACH OF HEALTH INFORMATION:

We will notify you if a reportable breach of your unsecured protected health information is discovered.

Notification will be made to you no later than 60 days from the breach discovery and will include a brief description of how the breach occurred, the protected health information involved and contact information for you to ask questions.

COMPLAINTS:

Complaints about this Notice or how we handle your protected health information should be directed to our HIPAA Privacy Officer. If you are not satisfied with the manner in which a complaint is handled you may submit a formal complaint to the Department of Health and Human Services, Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

We must follow the duties and privacy practices described in this Notice. If you have any questions about this Notice, please contact us at 303-502-6672 and ask to speak with our HIPAA Privacy Officer.