Privacy Policy

TheraPro AI, Inc.

Last Updated: June 9, 2025

Thank you for doing business with TheraPro AI, Inc. (“TheraPro,” “Company,” “we,” “our,” or “us”). We welcome you and hope you find our website, APIs, applications, products, and our other subscription services and tools (collectively, the “Services”) helpful and useful. We have adopted this privacy policy (“Privacy Policy”) to help our website visitors, current and potential customers, clients, their patients and clients, employees, and other business partners (“you” or “your,”) understand what Data we collect, store, share, and use, how and why we do so, and what your rights are in regard to that Data.

We always seek to improve our Services to you, and that may require that we collect, store, share, and use information about you and your usage preferences. As we do so, we are committed to protecting your privacy and the security of your personal information.

In this Privacy Policy, we use the word “Data” to describe all the information we collect that relates to you or that relates to your use of our Services. “Data” is broken into different categories, which are defined in the “Data We Collect and How We Use It” section of this Privacy Policy. We may refer to the different categories separately, but when we use the word “Data,” we mean all the different categories described in this Privacy Policy. For clarity, the term “Data” does not apply to de-identified or anonymized data that may be derived from Data, including without limitation traffic patterns, search activity, and other information that cannot be reasonably connected with any individual (“De-identified Data”). We may use De-identified Data for our own purposes in any manner and without attribution or compensation to any person.

For clarity, when you enter into a separate agreement with us that governs the use of the Services, the provisions of that agreement regarding ownership and usage of the data processed in connection with that separate agreement are governed by that agreement and not by this Privacy Policy. This Privacy Policy applies with respect to that separate agreement only to the extent the ownership and usage of data is not addressed in that separate agreement.

1. DESCRIPTION OF SERVICES

TheraPro is in the business of providing healthcare-related apps, services, and other tools to therapists and other professionals, including tools that are used to summarize conversations between those therapists, other professionals, and their clients.

In this Privacy Policy, all the tools and services made available in connection with the Services, including our app, API, tools, and any other services that we provide directly to you, whether now known or developed later, are included in the term “Services.”



2. LAWFUL BASIS FOR PROCESSING

Many jurisdictions require that we disclose to you the lawful basis for our processing of your Data. We do that in Section 4 and throughout this Privacy Policy. In general, our lawful basis for processing your Data is based on your specific consent or your or your employer’s contract with us.

By accessing or using any of the Services or by otherwise interacting with us online, you consent to our use of your Data as described in this Privacy Policy. If our processing of your Data is based on your consent, you may withdraw your consent at any time, and we will cease collecting your Data. However, in some cases, this may result in your inability to receive partial or full access to the Services, and your withdrawal of consent does not limit our ability to use the Data that has been de-identified for use by us in connection with our legitimate business efforts in the future. In addition, your withdrawal of consent does not prevent us from retaining and processing Data if we are required or allowed to do so by applicable law or in order to preserve legal claims. It also doesn’t prevent us from processing Data that has been gathered pursuant to a different lawful basis. For example, if you give your consent for us to process your Data, but we are also required by law to keep your Data, that separate “lawful basis” will still apply, even if you withdraw your consent.

When you enter into an agreement with us, either by accessing the Services, by executing an agreement in hard copy, electronic copy, or by clicking “I Accept” or similar language online, we will process your Data for the purposes of fulfilling the terms of our contract with you. In that case, our processing of your Data is based on the contract, so your withdrawal of consent will only be effective after the purposes for processing that Data have been fulfilled and after we no longer have a legal obligation to keep that Data.

In all cases, we will comply with applicable law, and we will cease processing your Data after the legal right, obligation, or other lawful basis expires.



3. INTENDED USERS

The Services are directed solely to persons 18 years of age or older or of children under 18 who are supervised by a parent, guardian, or other caregiver. Other than for Data collected for the specific purpose of providing the Services to users, we do not knowingly collect Data from users who are under 13. If we become aware that we have gathered Data from a person under 13, except to provide the Services to such person, and except to the extent allowed or required by law, then we will attempt to delete such Data as soon as possible, subject to our obligations under applicable law. If you believe that we have gathered Data from a person under 13 in contravention of this policy, please contact us privacy@therapro.ai.



4. DATA WE COLLECT AND HOW WE USE IT

Listed below are the categories of Data we collect. We never sell your Data, and we always have a lawful basis for gathering the Data, but that lawful basis might be different for different categories, and we describe those uses below. Regardless, we never use the Data for any purpose other than the purpose for which we gathered the Data in the first place, unless we get your prior explicit consent.

1. Registration Data
1. Data Description: Registration Data consists of your name, e-mail address, street address, and other contact information, which we may obtain or you may provide. Registration Data also includes your username, client type and membership or subscription end date, if any.
2. Lawful Basis for Processing: Our lawful basis for processing Registration Data is (1) our contract with you or your employer, (2) our legitimate interest in providing the Services to you or your employer, and/or (3) your consent. We can only provide certain of the Services to you if we have the Registration Data, so we need to store and access that Registration Data during the term of our contract. Even when the Registration Data is not critically necessary to the provision of the Services, we may still process that Registration Data to facilitate our contractual interactions with you.
3. How We Use It and Who We Share It With: Registration Data is accessible only to us and to you. We use it only to provide the Services to you. At times, we may also share the Registration Data with other third parties to fulfill requests that you make of us. We may also use your Registration Data to offer our own goods or services to you, either directly through e-mails or through third party platforms, but you may opt out of those offers at any time. We will never share your username or password with any third party.
2. Engagement Data
1. Data Description: Engagement Data consists of all the information you input or record using the Services, except as otherwise stated in this policy. It also includes all information that is proprietary to you regarding your use of the Services (other than the data that qualifies as “Usage Data” below) that is collected or processed by the Services. For example, Engagement Data includes information about your engagement with clients and customers, personal information about you, and internal company communications that occur using the Services, among other things. Engagement Data also includes the business information you provide to us pursuant to a services agreement by which you obtain access to the Services, and where there is such a separate agreement that discuss data processing and handling, any terms of that separate agreement that conflict with this Privacy Policy will prevail over this Privacy Policy.
2. Lawful Basis for Processing: Our lawful basis for processing Engagement Data is (1) our contract with you or your employer, (2) our legitimate interest in providing the Services to you or your employer, and/or (3) your consent.
3. How We Use It and Who We Share It With: Your Engagement Data is accessible only to us, to our service providers, to you, and where it relates directly to a party who either provides services to you or receives services from you to that party, in which case that party will be obligated to protect the confidentiality of your Engagement Data. We do not share Engagement Data with other third parties, except at your specific request. However, we may use Engagement Data that has been de-identified to improve the Services.
3. Usage Data
1. Data Description: Usage Data consists of the following and similar information:
• Information about your interactions with the Services, including any tools, websites, applications, or products associated with the Services, which includes the date and time of any requests you make. This also may include details of your use of Third-Party Applications and any advertising you receive via the Services.
• Adjustments you make to the default state of the Services, such as custom categories or settings.
• The timing of the information you post to the Services including messages you send and/or receive via the Services and your interactions with our customer service team, but not including the content of those interactions and messages, which would be included as Engagement Data.
• Technical data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Services, unique device IDs, device attributes, network connection type (e.g. Wi-Fi, 4G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and application version.
• Most mobile phones are equipped with GPS, which uses signals from satellites to determine a device’s location. Other technical means may also use nearby Wi-Fi, mobile networks, and device sensors to determine your device’s location by periodically collecting location data from your device. When you access or use our Services, whether through a browser or an app, these tools may be accessed to allow us to determine where you are, so that we can provide our services to you. They may also be used to improve our services to other users, but only in a way that does not make use of any personally identifying information.
• Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope), if any, required for the purposes of providing specific features of the Services to you.
2. Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you or your employer, (2) our legitimate interest in providing the Services to you or your employer, and/or (3) your consent.
3. How We Use It and Who We Share It With: Usage Data is accessible to us, our service providers, and to you. We do not share it with other third parties, except at your specific request, but we or our service providers may use Usage Data to make improvements to the Services. To the extent we are required to delete any Usage Data about you, we may still retain de-identified information that may have originated as your Usage Data.
4. Payment Data
1. Data Description: Payment Data is only collected when your use of the Services is subject to the payment of a fee or other charge. Payment Data is the information necessary for us to process your payments for Services. Payment Data will vary depending on the payment method you use (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:
   • Name;
   • Certain credit card information used to reference a credit card; (Please note that we use a third-party provider to collect credit card information. The third party’s collection tool is layered over our shopping cart, so your credit card information never hits our system at all.)
   • Address and postal code; and
   • Mobile phone number
2. Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Payment Data we receive from you.
3. How We Use It and Who We Share It With: We only use Payment Data to facilitate payment, and we only communicate it to those parties who are strictly necessary for that purpose.
5. Acquired Data

We may acquire data for marketing purposes from third parties, such as data brokers, and should we do so, we will notify you by disclosing that fact in this Privacy Policy.



5. SHARING YOUR INFORMATION

Except where a specific limitation is noted above, we may share your Data as follows:

1. At Your Instruction. If you request us to make your Data available to a third party, and such request furthers the purposes of our Services, is not unduly burdensome, and is not legally prohibited, we will do so.
2. Sharing with Service Providers. In certain cases, we use the services of third-party service providers, to assist us in providing the Services. We may share your Data with such service providers solely for that purpose.
3. Third-Party Offers. We may allow other companies to offer you their products and services, including offers through our Services or via email. Whether or not you decide to participate in any such offers is up to you. If you purchase a product or service via a third-party offer on our Services that requires you to submit financial and personal information, you are also consenting to our delivery of this information to that party. Such third party will be authorized to use this information in keeping with our contractual relationship with them and in accordance with their own privacy policy and information practices. We do not control these third parties and you agree that we are not liable for their acts, or any failure to act on their part.
4. Third-Party Advertising. We may use de-identified information to describe our membership and to establish advertising and other business relationships with third parties. We may serve you with targeted advertisements based on your personal or profile information, but we do not provide any of this personal or profile information to an advertiser or any third party with the exception of those uses expressly disclosed in this policy. However, if you click or view an ad on our Services then you consent to the likelihood that the advertiser will assume that you meet the targeting criteria, if any, used to display such ad, and as described above, you will be subject to the advertiser's privacy policy and information collection practices (if any).
5. Internet Service Providers. We may provide certain portions of your Data, such as your email address or name, back to your internet service provider if we have an existing advertising relationship with them. This is done to allow them to target or discontinue your exposure to our advertisements, once you have become a participating member of our Services.
6. Business Transitions. In the event that we go through a business transition, such as a merger, acquisition, liquidation or sale of all or a portion of our assets, the information we have about you will, in most instances, be part of the assets transferred. We reserve the right to transfer that information in connection with such transactions without notice to you. We will not be required to obtain your consent for such a transfer.
7. Legal Disclosure. We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to conform to applicable law, comply with a judicial proceeding, court order or legal process served on us, protect and defend our rights or property, or investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our terms of service.

If we ever plan to use any Data in the future for any other purposes not identified above and we do not have a separate lawful basis for that new purpose for processing, we will only do so after obtaining your specific consent.



6. TECHNOLOGIES WE USE

The technologies we use for automatic Data collection may include the following:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
• Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of the Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Other Technologies. We may also use device identifiers, local storage, html modifiers, and different types of caching to help us understand the devices and users who access the Services. Those methods include device identifiers that are either hardware-based or software-based, persistent or non-persistent, and which may identify either a device or a software module within a device (such as a web browser).


7. YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR DATA

By using our Services, you agree that we may use your Data to market our other Services to you. If, after giving your consent, you wish to opt-out of our using your Data to market Services to you, please follow the instructions below.

1. Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by sending a request for list removal to privacy@therapro.ai.
2. Any other disclosure of your Data: Except as provided in this Privacy Policy regarding De-identified Data and except for Data that is processed by us pursuant to a lawful basis other than your consent, you may instruct us to cease disclosure or use of your Data by contacting us at privacy@therapro.ai.

We will comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the Services, and you cannot opt-out from receiving those messages.



8. PRIVACY FOR EU RESIDENTS

If you are in a country in the European Economic Area (EEA) or in the United Kingdom, you are entitled to the explanation of the legal bases we rely on to process your personal data that is set forth in Section 2 above. You also have the rights described below. You have the right to:

Access Your Personal Data

You have the right to obtain from us confirmation as to whether or not we are processing personal data about you and, if so, the right to be provided with the information contained in this Privacy Policy. You also have the right to receive a copy of the personal data undergoing processing.

Rectify Your Personal Data

You have the right to ask us to rectify any inaccurate personal data about you and to have incomplete personal data completed.

Restrict Our Use of Your Personal data

You have the right to ask us to place a restriction on our use of your personal data if one of the following applies to you:

• You contest the accuracy of the information that we hold about you, while we verify its accuracy;
• We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
• We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
• You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

Object to Our Use of Your Personal Data

You have the right to object to our use of your personal data where our reason for using it is based on our legitimate interests or your consent (rather than when the legal basis for using it is to perform an obligation due to you under a contract with us).

Delete Your Personal Data

You can ask us to delete your personal data if:

• We no longer need it for the purposes for which we collected it;
• We have been using it with no valid legal basis;
• We are obligated to erase it to comply with a legal obligation to which we are subject;
• We need your consent to use the information and you withdraw consent;
• You object to us processing your personal data where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities.

If you do exercise a valid right to have your personal data deleted, we will also request that any third party to whom we have provided your information delete it. Additionally, deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Transfer Your Personal Data to Another Service Provider

You may request that we transfer some of the personal data you have provided to you or another service provider in electronic copy. This applies to personal data we are processing to service a contract with you and to personal data we are processing based on your consent.

To exercise any of these rights, please contact us as described in the “How to Contact Us” section below.

Make a Complaint

If you have any concerns or complaints regarding our processing of your personal data, please contact us as described in the “How to Contact Us” section below and we will do our best to answer any question and resolve any complaint to your satisfaction.

If, for whatever reason, you feel we do not meet the standards you expect of us, you are also entitled to make a complaint to your local supervisory authority.



9. PRIVACY FOR CALIFORNIA AND OTHER STATE RESIDENTS

California Shine the Light Law

We do not disclose personal information obtained through our Site or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

California Consumer Privacy Act

California has adopted the California Consumer Privacy Act (“CCPA”), which took effect at the beginning of 2020. We comply with the requirements of the CCPA to the extent they apply to us.

If you are a California resident and we qualify as a “business” under the terms of that law, you will have the following rights:

• You have the right to request that we disclose the categories and the specific items of Data about you that we collect, use, disclose, and/or sell and that Data about you that we have collected, used, disclosed, and/or sold during the 12 months prior to your request.
• You also have the right to have the Data we collect about you deleted. We use a two-step process to verify your identity and to have the information deleted. Your rights to have Data deleted are subject to several exceptions, specifically the Data that is necessary for us to:
  • complete your transaction;
  • provide you a good or service;
  • perform a contract between us and you;
  • protect your security and prosecute those responsible for breaching it;
  • fix our system in the case of a bug;
  • protect the free speech rights of you or other users;
  • comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
  • engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
  • comply with a legal obligation; or
  • make other internal and lawful uses of the information that are compatible with the context in which you provided it.
• To make any request under the CCPA, you must send an e-mail to privacy@therapro.ai. You will be asked to give us your name, e-mail address, telephone number, and any other information we request to reasonably verify your identity. We will respond to your request within 10 days after receipt of your request, and we will then take action to verify your identity and fulfill your request, as required by the CCPA.
• We will provide you with a CSV copy of your stored data within 45 days of your request, assuming we are able to verify your identity in that period and so long as you provide a correct email address for successful correspondence.
• You have the right not to receive discriminatory treatment by us for the exercise of any privacy rights conferred by the CCPA, which means that we will not take any action to hurt or punish you for exercising your rights under the CCPA.
• You may designate an authorized agent to make a request under the CCPA on your behalf by writing us at privacy@therapro.ai. Upon receipt of your request, we will provide you with the information you will need to designate that agent.

Note that we are not allowed by law to at any time disclose your Social Security number, driver’s license number, or other government-issued identification number, financial account number, any health insurance or medical identification number, or any account password or security questions or answers.

We have listed the specific and general categories of information we have collected, disclosed, or sold in the last 12 months in the section above entitled “Data We Collect and How We Use It.” That section also lists the specific and general categories of Data we have disclosed to third parties for our business purposes.

We do not sell your Data.

We do not sell the personal information of minors under 16 years of age.

For more information, please direct your questions to us at privacy@therapro.ai.



10. SECURITY

The security of your Data is important to us. We make commercially reasonable efforts to store and maintain your Data in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.



11. THIRD-PARTY POLICIES

You may be able to access third-party websites and other tools and services or products via a link, or via our other tools. The privacy policies of these third parties are not under our control and may differ from ours. The use of any Data that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any offering, site or other products and Services used in connection with the Services. The inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.



12. RETENTION

We will keep your information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of de-identified data, account recovery, or if required by law. All retained information will remain subject to the terms of this Privacy Policy. Please note that if you request that your information be removed from our databases, it may not be possible to completely delete all of your information due to technological and legal constraints.



13. AMENDMENT OF THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Any change to this Privacy Policy will become effective on the date the change is made to the Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all Data that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.



14. ACCESS AND ACCURACY

You have the right to access the information we hold about you in order to verify the information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your information as appropriate. As appropriate, this amended information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate information about you enables us to give you the best possible service.



15. HOW TO CONTACT US

You can help by keeping us informed of any changes such as a change of your personal contact information. If you would like to access your information, if you have any questions, comments or suggestions or if you find any errors in our information about you, please contact us at privacy@therapro.ai. If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.