Privacy Policy

Total Life, Inc. and its subsidiaries (“Total Life,” “we,” or “us”) owns and operates websites located at www.totallife.com (the “Website”) and/or other applications (collectively, the “Platform”). Your access and use of the Platform, any part thereof, or anything associated therewith, including its content (“Content”), any products or additional services provided through the Platform or otherwise by Total Life, and any affiliated website, software or application owned or operated by Total Life (collectively, including the Platform and the Content, the “Service” or “Services”) are subject to this Privacy Policy unless specifically stated otherwise. This Privacy Policy is part of our Terms of Use, and all capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the Total Life Terms of Use (“Terms of Use”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES. WHEN YOU USE OUR SERVICES AND PLATFORM YOU ACCEPT AND AGREE TO THIS PRIVACY POLICY.

We are committed to respecting the privacy of users of the Service. We created this Privacy Policy to tell you how Total Life collects, uses, and discloses information in order to provide you with the Service.

By creating, registering, or logging into an account through the Service, or otherwise accessing or using the Service, you are acknowledging the most recent version of this Privacy Policy. We will update this Privacy Policy when necessary to reflect material changes in the Service or how we use “personal information,” and as required by applicable law. If we make any changes to our Privacy Policy, we will post the revised Privacy Policy and update the “Last updated” date at the top of the Privacy Policy. If we make material changes to this Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law.

If you are using the Service on behalf of someone other than yourself, you represent and warrant that you are legally-authorized by such an individual to act on their behalf, and that such individual acknowledges the practices and policies outlined in this Privacy Policy.

The Service may only be used by individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. The Service is not designed or intended to attract, and is not directed to, children under eighteen (18) years of age. If we obtain actual knowledge that we have collected personal information through the Platform from a person under eighteen (18) years of age, we will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

When you set up an account with Total Life, you are creating a direct customer relationship with Total Life that enables you to access and/or utilize the various functions of the Platform and the Service as a user. As part of that relationship, you provide personal information to Total Life, including but not limited to, your name, email address, home or physical address, phone number and certain transactional information, which we do not consider to be “protected health information” or “medical information.”

However, when you use certain components of the Service, you may provide health or medical information that may be protected under applicable laws. Total Life is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, “HIPAA”). However, one or more of the Medical Groups may or may not be a “covered entity” or “business associate” under HIPAA, and Total Life may in some cases be a “business associate” of those Medical Groups. HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to your transactions or communications with Total Life and the Medical Groups. To the extent Total Life is deemed a “business associate” however, and solely in its role as a business associate, Total Life may be subject to certain provisions of HIPAA with respect to “protected health information” (“PHI”), as defined under HIPAA, that you provide to Total Life, the Medical Groups, or other Providers. In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, “Protected Information”), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws. The Medical Groups and Providers have adopted a Notice of Privacy Practices that describes how they use and disclose Protected Information. By accessing or using any part of the Service, you acknowledge receipt of the Notice of Privacy Practices from the Medical Groups and Providers.

By accessing or using any part of the Service, you understand that any information that you submit to Total Life that is not intended and used solely for the provision of diagnosis and treatment by the Affiliated Medical Groups, is not considered Protected Information, and will be subject only to our Privacy Policy and any applicable state laws that govern the privacy and security of this information. For purposes of clarity, information you provide to Total Life in order to register and set up an account on the Platform, including name, date of birth, username, email address, physical address, and phone number, are not considered Protected Information.

Personal information that we collect depends on how you interact with us, the services that you use, and the choices that you make with regards to the Services and your privacy choices.

We collect information about you from different sources and in different ways when you use the Services, including information that you directly provide us, information that we collect automatically, information that we collect from third-party sources, or information that we can infer or develop from other data.

Information You Directly Provide

We collect personal information that you directly provide to us when using the Services, filling out forms, requesting Services, or otherwise contacting or sharing information with us. For example:

• Name and contact information, such as your name, email address, phone number, and billing and physical addresses.
• Demographic data, such as your date of birth, ethnicity, and zip code.
• Social plug-ins, such as third-party websites, networks, platforms, servers and/or application information (e.g., Facebook, Twitter, Instagram).
• Payment information, such as your payment card number, financial account information, and other payment details.
• User Content, such as uploads and posts to the Services like photographs, videos, documents, feedback on the Services, and other files. This includes email messages and other communications you send to us asking for technical support or help.
• Employment information, such as content of job applications you submit to us and other information contained within them, including your resume.
• Sensitive Personal Information, for example:
  • Account & log-in information: Usernames or account numbers, your passwords, additional security questions, or other information that allows you to access your account.
  • Government IDs: Including your state or federal issued government IDs, passports, driver’s licenses, and social security numbers.
  • Sensitive demographic data: This includes information about your racial or ethnic origin.
  • Sex assigned at birth and sexuality: your sex assigned at birth and gender preferences, orientation, and other components of sexuality.
  • General health data: such as information about your symptoms, medical history, lifestyle, prescriptions, genetics, treatment options, and relevant physical characteristics (e.g., your height and weight) as well as medical photos you upload, lab results, and your health insurance information (including information about your plan sponsor or responsible family member).
  • Mental Health / Therapy Data: details about your mental health treatments and drug and alcohol use or dependency; and information you may share with your Provider to facilitate therapy, including journal entries, worksheets, audio messages, session recordings, etc.
  • Contents of the communications: Includes other data and information that you share or make available to us when accessing the Services.

Information We Collect Automatically

We collect information when you use our services or visit our Platform automatically, for example:

• Information and identifiers about your devices. We log your internet protocol (IP) address and information about your device, operating system, browser, and other software including type, version, language, settings, and configuration, including Cookies, Mobile IDs.
• Geolocation data. Depending on the services that you use and your device settings, we collect geolocation data when you use the Services such as the general location of your IP address.
• User behavior and activity. We automatically log your activity on our Websites, including referring and exit pages and URLs, pages that you viewed, and the order in which you viewed or interacted with the site, such as through your clicks, files that you download, how long you stayed on a page, the times you accessed the pages, and other actions that describe your use of the website and services. In some cases, this data may be considered sensitive personal information if it is obtained in relation to browsing activity on health-related pages for specific services.

Information We Obtain from Third-Party Sources

Sometimes, we collect the types of information described above from third parties we work or do business with. These sources can include, but are not limited to:

• Publicly available sources. Public sources of information such as open government databases.
• Third-party apps and partners. Third-party applications and services, including social media networks, or data from third party platforms like fitness trackers, sleep monitors, other wearable devices, and their associated data.
• Service providers. Third parties that collect or provide data in connection with work they do on our behalf.
• Co-branding/marketing affiliates. Affiliates with which we offer co-branded advertisements or services or whom we engage in joint marketing activities.

Information We Develop or Infer

We may develop or create inferences using information about you from the data we collect. Developing these inferences includes using automated means to infer information about your likely preferences or other characteristics.

Total Life provides business support services to the medical providers and certain pharmacies you may access through the Services. As a result, we may store additional health information on their behalf, including your medical record, communications with providers, therapy and other psychiatry notes, your medical history, and prescription information.

Cookies are small text files placed by a website and stored by your browser on your device. When you visit the same website again, your browser can send the cookie back to the website’s server. Cookies contain a unique set of numbers and letters that can identify your device and store other information about you. This helps websites recognize your browser over time.

Web beacons are tiny electronic images with unique identifiers (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party).

We, and our analytics and advertising partners, use these technologies in our websites, platform and online services to collect personal information when you use our services, including personal information about your online activities over time and across different websites or online services. This data is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop or create inferences, serve you interest-based advertising, combat fraud, and fulfill other legitimate purposes.

We use the personal information we collect for purposes described in this Privacy Policy or as otherwise disclosed by you, subject to the limitations addressed in the “Protected Information” section above. These purposes include:

• Product and service delivery. To provide, manage, and deliver the Services, including troubleshooting, improving, and personalizing those services.
• Business operations. To operate our business, such as billing, processing your payments, accounting, administering your account, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.
• Healthcare operations. To provide support to our affiliated medical groups and their providers, to assist with patient intake, eligibility to participate in the services, including insurance checks and coordination.
• Product improvement, development, and research. To develop, test, or improve the Services and content, features and/or products or services offered via the Service, and to analyze traffic and user behavior.
• Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services.
• Customer support. To provide customer support, fulfill your requests, respond to your questions, and to assist you in connecting with healthcare providers.
• Communications. To send you information about us or our affiliated entities, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners.
• Advertising. To promote and market our and our Affiliated Entities’ Service, and the products and/or services offered via the Service.

We may also aggregate and/or de-identify your information in ways that it may no longer be associated or linked to you or your devices. We can then develop, create, and use the aggregated and/or de-identified data for any business purpose not prohibited by applicable law, including research or marketing.

We use Artificial Intelligence (“AI”) technologies to process information that we collect about you, including information that you share with the Medical Group providers, as detailed throughout this Privacy Policy. Our use of the information we collect may include some automated and some human (or manual) methods of processing. The automated processing typically includes features aimed at completing manual, repetitive tasks more efficiently. Some of these tasks may include contacting you for appointment reminders or follow ups, enhancing your engagement with the platform, and care coordination; however, at no time should you consider Total Life’s AI-related features and content to be medical advice.

We also use AI to help therapists and healthcare providers manage and document their interactions with you more effectively. AI is never solely used to make medical decisions or provide healthcare and therapy directly to you. Use of AI technologies does not replace the professional judgment of licensed healthcare providers and therapists, who remain fully responsible for all clinical decisions.

All data processed by AI tools is integrated into the Services in accordance with applicable laws, including HIPAA and other data protection laws, clinical guidelines, and ethical practice standards. Importantly, your PHI and other sensitive data collected and used within our AI systems is not shared with any third party for their use or improvement of their products and services. Our AI tools used in the Services operate within secure, controlled environments and are designed to respect patient confidentiality and data security. We do use your de-identified information to train and improve Total Life’s AI models, and we may also use stored recordings, transcripts, and other information about you, including your health information, notes about your therapy sessions, or any other information that you have shared with your provider to develop our AI technologies.

IF YOU DO NOT CONSENT TO OUR USE OF AI THEN YOUR SOLE AND EXCLUSIVE REMEDY IS TO NOT USE THE SERVICES. BY USING THE SERVICES, YOU EXPRESSLY ACKNOWLEDGE AND CONSENT TO OUR USE OF AI TECHNOLOGIES AS DESCRIBED HEREIN.

• Subsidiaries and Affiliated Entities. We may disclose personal information to our subsidiaries and Affiliated Entities, which include healthcare providers and therapists, to allow us to provide the Services and for the Medical Groups to provide you with therapy and other healthcare services and to collect your payment on their behalf.
• Service Providers. We may use independent contractors, vendors, and suppliers to provide specific services and products related to our Platform, such as providing payment processing, fraud screening, implementation of AI technologies, and IT hosting and security, development, and support.
• Financial Services & Payment Processing. When you make a purchase, we share your payment details and other personal information with banks and other financial institutions to process payments, prevent fraud, and manage other financial services.
• Marketing and Advertising Partners. We may provide personal information, including information obtained through cookies, to marketing and advertising partners to deliver personalized advertising to you or to people with similar interests.
• Laws, Law Enforcement, and Legal Rights. We may share your personal information if we are legally required to do so, such as complying with a law, court order, or any other valid legal process. We may also share personal information if necessary to protect the safety of our users, our website, or the public.
• Sale or Business Transaction. We may disclose personal information to third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, or assignment of assets or business merger or divestiture.

We value your choices and provide a variety of ways for you to control what personal information we store about you and choices about how we use that data.

Request Access, Portability, Correction, and Deletion

If you wish to request further access, download, copy, request correction, or delete your personal information that we hold, please email privacy@totallife.com to make your request. We will respond to your requests in a reasonable timeframe and explain any denials if they occur.

We will not penalize, discriminate, or retaliate against anyone that makes a rights request, but in some cases we will not be able to provide our Services to you without that information.

Opt Out of Sale or Sharing for Advertising

If you are a resident of certain states, you may choose to opt out of the sale, sharing, and/or processing of your personal information through cookies, web beacons, and similar online tools for personalized advertising. You may opt out by clicking on the “Your Privacy Choices” link on our Website. Our Website also recognizes Global Privacy Control (GPC) browser signals to the extent required by applicable laws.

Marketing Preferences

You can opt out of receiving communications about products, services, promotions, and events by email, postal mail, or phone by contacting us using the details below. In commercial emails, you can also opt out by following the instructions at the bottom of the email.

• Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our Platform.
• Global Privacy Control.Some browsers and browser extensions support the “Global Privacy Control” (GPC) that can send a signal to the websites you visit indicating your choice to opt out from certain types of data processing, including data sales and/or personalized advertising, as specified by applicable law. When we detect such a signal, we will make reasonable efforts to respect your choices.
• Do Not Track.Some browsers include a “Do Not Track” (DNT) setting. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals.
• Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.
• Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, which prevents the automatic connection to the web servers that host those images.

We retain personal information only as long as necessary to provide services, fulfill your transactions and requests for Services, comply with legal obligations, resolve disputes, enforce agreements, and for other lawful and legitimate business purposes. Our data retention periods may vary based on factors like data type, user consent, information sensitivity, availability of options for deletion, and our legal or contractual obligations.

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information.

• Notice at Collection. At or before the time of collection, you have a right to receive notice of our privacy practices, including the categories of personal and sensitive personal information collected, purposes for which your information is collected or used, whether the information is sold or shared, and how long the information is retained.
• Right to Know. You have a right to request that we disclose to you the personal information we have collected about you, and how it has been used, disclosed, or sold. You may make a “request to know” by contacting us at privacy@totallife.com.
• Rights to Request a Correction or Deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request, email us at privacy@totallife.com.
• Right to Opt Out / Do Not Sell or Share My Personal Information. You have a right to opt out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA. We do not knowingly collect, sell, or share the personal information of minors under 18 years of age.
• Right to Limit Use of Sensitive Personal Information. You have a right to limit our use of sensitive personal information for any purposes other than to provide the products or services you request or as otherwise permitted by law.
• Authorized Agent. You can appoint an authorized agent, either in writing or through a power of attorney, to submit your requests or exercise your rights under the CCPA.

Additionally, under California Civil Code section 1798.83 (the “Shine the Light” law), California residents have the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information with third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their own direct marketing purposes.

We will not discriminate against anyone exercising these CCPA rights.

Securing Accounts & Password Information

We take actions to implement appropriate physical, technical, and administrative safeguards to protect information from unauthorized access, use, disclosure, alteration, or destruction. However, it is your responsibility to maintain the confidentiality of your account information and password. You must use a strong, unique password for your account and never share it with others. If you suspect your account’s security has been compromised, please contact us promptly.

Linked Sites

The Site may contain links to third-party owned or operated websites, including social media websites (“Linked Sites”). This Policy and the practices that we follow under this Policy do not apply to Linked Sites. We are not responsible for the content, accuracy, or opinions expressed on any Linked Site or for the privacy practices or security standards used by third parties on such Linked Sites.

We may update this Privacy Policy to reflect changes in law, our data practices, Services, or technology. The revised policy will be available through the Services, and you should review it periodically. The last revision date is at the top of the document. Your continued use of our Websites or Services after changes (and notice, if applicable) signifies your acknowledgment of Privacy Policy updates.

If you have any questions or comments about this Privacy Policy, please contact us: