Hue Arts, LLC d/b/a Spool Health ("we," "us," "our," or "Company") recognizes that the privacy of your information is important. This Online Services Privacy Policy ("Privacy Policy") describes our practices in connection with information we collect through online and mobile websites, platforms, services, and applications that we own or operate and that contain a link to this Privacy Policy (collectively, "Online Services"). Our Online Services are designed to provide a platform through which you can connect with licensed mental health providers and access mental health services, including individual therapy, group therapy, and couples and family therapy.

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We comply with this Privacy Policy and, where applicable, the Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations (collectively, "HIPAA") with respect to any information that constitutes protected health information ("PHI") under HIPAA. This Privacy Policy is separate from any HIPAA Notice of Privacy Practices we may provide to you.

By using our Online Services, you consent to our collection, use, disclosure, and storage of information as described in this Privacy Policy.

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1. What Information We Collect
When you register for or use our Online Services, we may collect the following information from you or your dependent:

• First and last name

• Email address

• Date of birth

• Gender

• Health plan provider name, Member ID, and Group ID (optional)

• Information about your current or previous mental health providers (optional)

• Video recordings (optional, used in onboarding and certain programs)

• Assessment scores and questionnaire responses

• Medical history, current medications, and allergies

• App usage and engagement data

• Device and system data, such as device type and operating system

• Other information described in this Privacy Policy

 

We may also collect information automatically through the Online Services using common technologies such as cookies, tokens, tags, beacons, scripts, and web server logs, as well as functionality that collects data from a mobile device. This automatically collected information may include demographic data, technical information about your device, web browser information, IP address, operating system, geolocation information (where permitted), and patterns of application usage.

 

In certain circumstances, we may request or permit the submission of video recordings as part of onboarding or treatment-related programs. Participation is voluntary.

 

We will only create or retain recordings with your consent. Recordings are used solely for the purpose explained at the time they are collected and are accessible only to authorized personnel and providers with a legitimate need to access them.

 

2. How We Use Your Information
We may use the information we collect for purposes that include:

• Providing mental health services to you, including individual therapy, group therapy, and couples and family therapy

• Responding to your emails, inquiries, or specific requests

• Communicating with you about appointments, treatment, and services

• Providing content through our Online Services or other services we may offer

• Processing applications for products or services as requested by you

• Authenticating your identity on our Online Services and with vendors acting on our behalf

• Administering surveys and promotional programs

• Personalizing your experience on our Online Services

• Providing informational or promotional offers, as permitted by law

• Performing analytics and improving our products, services, and Online Services

• Complying with applicable laws, regulations, and legal process

• Protecting the health, safety, or welfare of any person

• Protecting our rights and the rights of affiliates or related third parties

• Maintaining records of our transactions and communications

• Any other purpose permitted by law or for which you have provided consent

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We may contact you by email, phone, or SMS message using contact information you provide through our Online Services. Where permitted, we may combine your information with information from other sources to improve our services and personalize your experience. We may use and disclose de-identified and aggregated data for any lawful purpose, including analytics and program improvement.

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3. How We Share Your Information
We will only share your information with third parties as outlined in this Privacy Policy, as otherwise permitted by law, or with your consent.

 

Business Transactions
We may share your information if all or part of the Company is sold, merged, dissolved, acquired, or restructured, or in connection with steps taken in anticipation of such events.

 

Legal Requirements
We may share your information in response to a court order, subpoena, search warrant, or to comply with applicable laws or regulations. We may also cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our policies, or may be harmful to others.

 

Within Our Company
We may share your information within the Company, including among affiliates, subsidiaries, or parent entities.

 

Service Providers and Business Associates
We may disclose protected health information and other personal information to third-party service providers and business associates that help us operate and provide our services. These may include electronic health record providers, telehealth platforms, billing and claims processors, cloud hosting providers, communication vendors, transcription services, and other technology or administrative support providers.

 

Where required by law, we enter into Business Associate Agreements or other contractual arrangements with these providers to help ensure that information entrusted to them is appropriately protected. These providers are permitted to use and disclose information only as necessary to perform services on our behalf or as otherwise permitted or required by law.

 

Restrictions on Sharing
We will not share mobile opt-in information or SMS consent data with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.

 

4. Cookies and Tracking Technologies
We may use various technologies including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to automatically collect information when you use our Online Services. This information may include your IP address, device type, operating system, browser type, pages visited, and patterns of application usage ("Activity Information").

 

We may also use third-party analytics companies to help us understand how users interact with our Online Services. These third parties may use cookies and similar technologies to collect information about your browsing activity over time and across websites.

 

You can manage your cookie preferences by adjusting your browser settings at any time; however, disabling cookies may limit your ability to use certain features of our Online Services. Additional opt-out options include:

• Managing Flash technologies using tools available on Adobe's website

• Opting out of display advertising through Google's ad settings

• Visiting the Digital Advertising Alliance at www.aboutads.info/consumers to opt out of targeted advertising

 

Please note that we do not currently respond to web browser "Do Not Track" signals, as there is no universal standard for how such signals should be interpreted.

5. How We Protect Your Information
We maintain administrative, technical, and physical safeguards designed to protect the information you provide through our Online Services. These safeguards are calibrated to the sensitivity of the information collected, used, and stored. However, no security system is impenetrable, and we cannot guarantee the absolute security of your information or any transmissions made over the Internet.

 

You are responsible for safeguarding the devices you use to access our Online Services. If your device is lost, stolen, or used by others, your account and personal information may be at risk. You should always affirmatively log out of your account before ending a session, particularly on public or shared devices.

 

We retain your information for as long as necessary to fulfill the purposes for which it was collected, subject to any longer retention period required by applicable law or legal obligation.

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6. Children Under 13
We will not intentionally collect personal information (as defined under the Children's Online Privacy Protection Act) from children under the age of 13 through our Online Services without obtaining verifiable parental consent. If you believe we have inadvertently collected such information, please contact us immediately at privacy@spoolhealth.com.

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7. Social Security Number Protection
It is our policy to protect the confidentiality of Social Security numbers ("SSNs") that we receive or collect in the course of business. We maintain physical, technical, and administrative safeguards to protect against unauthorized access, and we limit access to SSNs to that which is required by law. We prohibit the unlawful disclosure of SSNs.

 

8. Security Breach Notification
In the event of a security breach affecting your personal information, we will notify you in accordance with applicable law. Unless otherwise required by law, breach notices will be sent to the email address associated with your account. Please ensure your email address is current and that communications from Spool Health (spoolhealth.com) are not blocked by your spam or junk mail filters.

 

9. Posting Messages, Comments, and Content
Our Online Services may include collaboration areas, such as blogs or message boards, where users can share information. Any information you post to these areas, including any display name or image you select, may be visible to other users. Please be thoughtful about what you post and be aware that such content may become publicly accessible.

 

10. Managing Your Information
Where our Online Services permit, you may be able to review, update, or request deletion of your profile and related information. Please note that if we have already disclosed certain information to third parties, we may not be able to require those parties to delete or modify that information.

 

SMS message and data rates may apply. You may stop receiving SMS messages by replying STOP at any time. To opt out of transactional SMS messages (e.g., appointment reminders), contact us at privacy@spoolhealth.com. For additional assistance opting out, contact us at the same address. Note that certain communications, such as account status updates or legally required notices, may not be subject to opt-out.

11. Privacy Rights
Depending on your state of residence and applicable law, you may have certain rights regarding your personal information. These rights may include:

• Requesting access to personal information we maintain about you.

• Requesting correction of inaccurate information.

• Requesting deletion of certain information, subject to legal and regulatory retention requirements.

• Receiving a copy of certain information in a portable format.

• Withdrawing consent where processing is based on consent.

• Exercising additional rights provided under applicable state laws.

 

To exercise your privacy rights, please contact us at privacy@spoolhealth.com. We may need to verify your identity before processing your request. Certain information may be retained as required by law, professional obligations, or recordkeeping requirements.

 

12. AI tools and Third Party Vendors
We may use third-party service providers to support our operations, including electronic health record vendors, cloud hosting providers, billing vendors, communication platforms, telehealth technologies, and other service providers that help us deliver and improve our services.

 

We may also use technology-assisted tools, including documentation or transcription services, to support administrative and clinical workflows. We evaluate these vendors for privacy and security and require contractual protections where appropriate.

 

Where required by law, we enter into Business Associate Agreements or other contractual arrangements with vendors that create, receive, maintain, or transmit protected health information on our behalf.

 

Our service providers are permitted to access information only as necessary to perform services for us and are required to protect the confidentiality and security of that information.

 

13. Additional Rights for California Residents
California law permits our users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, contact us at the address below and include "California Privacy Rights" in the subject line along with sufficient information to identify your account.

 

This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted outside the specified contact channels.

California Minors Under 18
If you are a California resident under the age of 18 and a registered user of our Online Services, you may request removal of content you have posted that is accessible by other users. To make such a request, contact us at the address below and describe the content and its location. Please note that removal under this provision may not result in the complete deletion of the content from all our systems.

 

14. HIPAA and Health Privacy
Certain information you provide through our Online Services may constitute protected health information under HIPAA. We handle such information in accordance with HIPAA and our HIPAA Notice of Privacy Practices, which is available separately. For questions about how your health information is used and disclosed, please refer to our Notice of Privacy Practices or contact us.

 

15. Social Media 
We may maintain a presence on social media platforms including Facebook, Instagram, and others. If you interact with us on those platforms, please be aware that:

• Information you post may be visible to others and may persist online

• We are not responsible for content posted by others on pages we manage

• Social media platforms have their own privacy policies that govern your use of those platforms

• Content posted on our social media pages is for general informational purposes only and does not constitute medical advice

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If you are experiencing a mental health emergency, please call or text the suicide hotline at 988 or call 911 or go to your nearest emergency room. 
 

16. Group & Family Therapy
If you participate in group or family therapy or other shared treatment settings, information you disclose may be heard by other participants. While we ask all participants to respect the privacy and confidentiality of others, we cannot guarantee that other participants will maintain confidentiality. 

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17. Health and Safety
We may use or disclose information when permitted or required by law, including circumstances involving a serious threat to health or safety, suspected abuse or neglect, court orders, legal proceedings, or other situations where disclosure is authorized or required under applicable law and professional obligations.

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18. When This Privacy Policy Applies
This Privacy Policy applies to Online Services that we own or operate. It does not apply to information collected through other means, such as by telephone or in person, or to the practices of third-party websites or applications that may be linked from our Online Services. Some services we offer may be governed by a separate privacy policy.

 

This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

 

19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the effective date at the top of this document and, where appropriate, notify you by email or through our Online Services. We encourage you to review this Privacy Policy periodically.

 

20. How to Contact Us
If you have questions about this Privacy Policy or our privacy practices, or if you believe your information has been misused, please contact us:

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Hue Arts, LLC d/b/a Spool Health
Email: privacy@spoolhealth.com

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We take all privacy concerns seriously and will respond to your inquiry as promptly as possible.