Privacy Policy
Last Updated: 9/8/17
LARKR Privacy Policy
Welcome to LARKR! LARKR (also referred to as “we” or “us”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, and disclose information that you provide in order to use the LARKR mobile telepsychology and curated provider platform (“Platform”) and associated LARKR website located at http://www.larkr.com/ (“Website”). This information may be considered Personally Identifiable Information (“PII”), which is further defined below. PII that is linked with your personal health information is also covered by our HIPAA Policy. Any conflict between this Privacy Policy and the HIPAA Policy shall be resolved in favor of the HIPAA Policy. Please note that the capitalized terms in this Privacy Policy and HIPAA Policy have the same meanings as the Terms of Service (in the case of Members) and Therapist Agreement (in the case of Therapists), so please make sure you read and understand the those agreements, as applicable.
1. Changes to this Privacy Policy
If we make any substantial changes to this Privacy Policy, such as in the way we use your PII, we will notify you of those changes by posting on the Platform. Please also refer to the “Updated” date above which will also indicated when changes become effective.
2. Information Collected and How it is Used
2.1 Member Data
PII is personal information that can be used to identify an individual including, but not limited to, first and last names, email addresses, postal addresses, phone numbers, health information and social network usernames. The Platform collects certain PII that you, as a Member of the Platform, are requested to provide in order to use the Platform. This information may include your photo, date of birth, gender, email, phone number, emergency contacts, therapist preferences, medications, information (including PII) that you may input during your therapy Session (“Member Session Notes”), information (including PII) that your Therapist(s) may input about your Sessions with that Therapist (“Therapist Session Notes”), and other medical health information that you may input into the Platform (collectively “Member Data”). The Platform may access your personal information on your profile in your social networks, upon consent by you. The collection, confidentiality and use of your Member Data is further described in the HIPAA Policy. Member Data is also used by Therapists to provide you Sessions. Therapists may use your phone number to send you SMS messages or phone calls to provide you therapy or protect Members at risk. LARKR may disclose your Member Data as provided for in Section 4.
2.2. Therapist Data
The Platform collects certain PII that you, as a Therapist on the Platform, are requested to provide in order to use the Platform. This information may include your first and last name, your photo, and Therapist licensing data (including phone number, address, licensing body and licensing jurisdiction) and other general practice information (collectively “Therapist Data”). LARKR uses the Therapist Data to match Members with the Therapist. LARKR may disclose your Therapist Data as provided for in Section 4.
2.3 Member and Therapist Feedback
The Platform may allow Members to provide LARKR with confidential feedback about a Therapist with whom the Member conducted a Session, and may allow Therapists to provide LARKR with confidential feedback about a Member with whom the Therapist conducted a Session (collectively “Feedback”). LARKR only uses this Feedback for its own internal purposes, including quality control or matching Therapists with Members, and does not share any Feedback that identifies you personally, except as provided for in Section 4.3-4.5.
2.4 Log Information Collected Through Interaction With the Website or Mobile Device
When you use the Website, we automatically log your IP address (the Internet address of your computer) and other information such as your browser type, operating system, the web page that you were visiting before accessing our Website, and the pages or features that you engage with on our Website, to give us an idea of which parts of our Website you visit and how long you spend there; and similarly we collect certain information that your mobile device sends when you use our Platform such as a device identifier, user settings and the operating system of your device, as well as information about your use of our Platform (we refer to this information as "Log Data"). But we do not link your IP address to any PII unless you have logged into the Platform via your account. We use Log Data to improve, customize and enhance the Platform and Website by expanding their features and functionality and tailoring them to our users’ needs and preferences, and do not share any Log Data except as provided for in Section 4.3-4.5. You understand that, by logging into the Platform on your mobile device, your Member Data pertaining to your medical treatment may be stored to your mobile device. We are not responsible for any unauthorized access by any third party to such information on your mobile device.
2.5 Location Information
When you use our Platform, you may be prompted to accept or refuse geo-location tracking. In event you accept, the Platform and/or Website will collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or course location if you enable location services on your device. We may use location information to improve and personalize the Platform for you. If you do not want us to collect location information, you may disable that feature on your mobile device. We do not share this location information except as provided for in Sections 4.3-4.5, but your Member Data inputted by you may contain your general location.
3. Cookies and Web Beacons
A “cookie” is a small data file that is transferred to your computer hard drive when you visit a website. The cookie contains information that is used to track pages you have visited. A “web-beacon” (also known as a pixel tag or clear GIF) is a tiny graphic with a unique identifier that may be included on a website, mobile app or in an email that serves several purposes such as for delivering or communicating with cookies, tracking and measuring website performance, traffic, and effectiveness of advertising. We use cookies and web beacons, and similar technologies for mobile devices, to facilitate the functionality and effectiveness of our Platform and Website. If you prefer, you can change your browser’s settings to prompt you before accepting a cookie, however this could impair the functionality of the Platform. We may engage the services of some third-parties and they may also place cookies on your hard drive. This Privacy Policy does not cover such third-party use of cookies.
4. Sharing and Disclosure of Information.
LARKR does not share your information with third parties except as provided in this Privacy Policy.
4.1 Member Data and Therapist Session Notes.
LARKR shares Member Data with Therapists using the Platform once the Member has booked a Session with a Therapist. LARKR does not otherwise disclose your Member Data except as provided in Sections 4.3-4.5. Therapist Session Notes are also shared with other Therapists on the Platform that have booked a Session with the same Member.
4.2 Therapist Data.
You agree that your Therapist Data may be publicly disclosed to other Members and Therapists on the LARKR website. LARKR does not otherwise share your Therapist Data except as provided in Sections 4.3-4.5.
4.3 Information Shared with Service Providers
We employ third-party companies to perform billing, legal, and other operational services. These third-party service providers only have access to your PII as is necessary for the purpose of performing such services on our behalf. These third parties are expressly obligated not to disclose or use your PII for any other purpose.
4.4 Information Disclosed Compliance with Laws and Protection
We cooperate with law enforcement, government officials and Therapists to enforce and comply with the law as is necessary and may disclose your information as required by the legal process (such as a subpoena) and as required by HIPAA or related applicable local, state or federal laws (please refer to the HIPAA Policy). You understand that Therapists may also be required by their ethical and professional rules and regulations to disclose your information in certain cases.
4.5 Information Disclosed in Connection with a Change of Ownership
If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or sale of assets, your information may be transferred or disclosed to a third party acquirer in connection with the transaction.
5. Data Security
Your account information is password-protected for your privacy and security. LARKR uses industry standard best practices to safeguard the security of the information you provide to us with physical, electronic, and managerial procedures. We use industry-standard SSL-encryption to enhance the security of data transmissions. We review our information collection, storage and processing practices, including physical security measures to guard against unauthorized access to our Platform and Website. We also urge you to take every precaution to protect your information when you are using the Platform. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser.
6. Children and Privacy
The Platform is not directed toward children under the age of 13 (“Child” or “Children”) and LARKR does not knowingly collect information from Children. If you are a parent of a Child and become aware that your Child has provided personal information to us, please contact us at and you may request exercise of your applicable access, rectification, cancellation and/or objection rights.
7. Opt-out
Once you have voluntarily provided LARKR with your email address, you agree that we may periodically send you free newsletters and e-mails that directly promote the Platform. When you receive such promotional communications from us, you will have the opportunity to "opt-out" (either through your account or by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain important and necessary communications regarding the use of the Platform, including updates to our Terms of Service or this Privacy Policy or information about billing, and you will not be able to opt-out of those communications. You may also opt-out of receiving push notifications or alerts by toggling off the "Notifications" options within the "Settings" menu of our mobile application. This feature is available in the most recent versions of our iOS-based and Android-based applications.
8. Updating your Information
You can review, update and delete your Member Data (in the case of a Member) or Therapist Data (in the case of a Therapist) directly in your account within the Platform, except you cannot delete any Member or Therapist Session Notes about the Sessions, and such Session Notes are stored by LARKR in accordance with applicable laws. Note, if you do not provide the LARKR Platform with all requested information, you may be able to use the Platform.
9. Contact Information
If you have questions, concerns or a complaint about this Privacy Policy please send an email to contact@larkr.com.