Little Otter, Inc. Privacy Policy

Effective Date: May 3, 2021

Last Updated: April 30, 2021

We at Little Otter, Inc. value your privacy and are committed to keeping your Personal Data confidential. We use your data solely in the context of providing you with a convenient and high-quality software solution that allows healthcare providers and patients to easily and purposefully connect with each other for the provision of telebehavioral health services. 

This privacy policy applies to Personal Data Little Otter, Inc. collects from (1) legal parents or guardians of child(ren) receiving treatment through the Little Otter website and application (the “App”) and any related services (the “Services”); and (2) healthcare providers providing treatment to pediatric patients on behalf of an organization authorized to use the App (individually a “User” and collectively the “Users”). “Personal Data” includes any information that can be used on its own or with other information in combination to identify or contact one of our Users. We believe that transparency about the use of Our Users’ personal information is of utmost importance. In this privacy policy, We provide Users with detailed information about our collection, use, maintenance, and disclosure of Users’ Personal Data. The policy explains what kind of information We collect, when and how We might use that information, how we protect the information, and User rights as a provider or parent/legal guardian.

BY USING THE APP, USER IS ACKNOWLEDGING THAT USER HAS READ AND AGREES TO THE TERMS OF THIS POLICY. IF USER DOES NOT AGREE, PLEASE DO NOT LOG INTO, ACCESS, OR, IF APPLICABLE, ALLOW YOUR CHILD TO LOG INTO OR ACCESS THE APP AND DO NOT SUBMIT ANY PERSONAL DATA TO US.

Notice Regarding Updates: Please note that We occasionally update this Privacy Policy. If We make a material change to this Privacy Policy, We will post a link to the modified terms on our website and will also notify User via email. User can store this policy and/or any amended version(s) digitally, print it, or save it in any other way. Any changes to this privacy policy will be effective immediately upon providing notice, and shall apply to all information We maintain, use, and disclose. If User does not agree to the changes, immediately delete the App and all associated files from User’s device. If User continues to use the App such notice, User is agreeing to those changes.

In case User has any questions or concerns after reading this Privacy Policy, please do not hesitate to contact Us at privacy@littleotterhealth.com. We appreciate your feedback. If you do not agree to the terms of this Privacy Policy or if you changes your mind at any point, you can delete your account by deleting the App or notifying us by email at privacy@littleotterhealth.com.

Responsible Entity

Little Otter, Inc. (“We”, “Us”, “the Company”) may process User Personal Data in accordance with this Privacy Policy. If We are processing Personal Data on behalf of a third party that is not an agent or affiliate of the Company, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy policy will apply. You can contact Us with any questions about our Privacy Policy at privacy@littleotterhealth.com

Links to Other Sites

Our App may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that User provides on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We are not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect User information, We recommend that Users carefully review the privacy policies of all Third-party Services that the User accesses.

What Personal Data do We collect?

We collect Personal Data, which includes the following types of data and may include healthcare information or “protected health information”. 

Demographic Data

We collect demographic information, such as your name and email address, to assist us in creating User’s User Account.

Parents/Guardians: We also collect Personal Data such as your child’s birth year, sex assigned at birth, gender, height, and weight to assist us in creating your User Account and communicating with your child’s provider.

Payment Data

If User makes payments via our App, We may require that Users provide to Us User’s financial and billing information, such as billing name and address, credit card number or bank account information.

Support Data

If User contacts Us for support or to lodge a complaint, We may collect technical or other information from User through log files and other technologies, some of which may qualify as Personal Data. (e.g., IP address). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Services in accordance with this Privacy Policy. Calls with Little Otter may be recorded or monitored for training, quality assurance, customer service, and reference purposes.

Device, Telephone, and ISP Data

We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data, from User’s computer or mobile device as Users navigate our Services, or interacts with emails We have sent you. The information We collect may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, to help Us provide and improve our Services and to guarantee their security and continued proper functioning.

Health and App Data (Parents/Guardians)

In addition to demographic information, We will collect information regarding your child’s health conditions, age, sex assignment at birth, gender, weight, height, medical history, symptoms, information from the App, and communications between your and the healthcare provider providing healthcare services to your child via the App. We collect this information to provide User with the Services and to provide User’s healthcare provider providing healthcare services through the App with the information required to provide medical treatment.

How will We use your Personal Data?

We process Users’ Personal Data based on legitimate business interests, in order to provide Our Services, to comply with Our legal obligations, and/or with User’s consent when we are required to obtain it. We only use or disclose Personal Data when it is legally mandated or where it is necessary to fulfill those purposes described herein. Where required by law, we will ask for your prior consent before doing so.

Specifically, we process Users’ Personal Data for the following legitimate business purposes:

  • To fulfill our obligations to User under the Terms of Service
  • To communicate with User about and manage User’s Accounts
  • To properly store and track User data within our system
  • To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings or court orders.
  • To protect Our rights, privacy, safety or property, and/or that of User by providing proper notices, pursuing available legal remedies, and acting to limit Our damages
  • To handle technical support and other requests from User
  • To enforce and ensure User compliance with Our Terms of Service or the terms of any other applicable services agreement We have with User
  • To manage and improve Our operations and the App, including the development of additional functionality
  • To manage payment processing
  • To evaluate the quality of service that User receives, identify usage trends, and thereby improve User’s experience
  • To keep Our App safe and secure for User, and for Us
  • To send User information about changes to Our terms, conditions, and policies
  • To allow Us to pursue available remedies or limit the damages that We may sustain
  • Parents/Guardians: To provide access to the authorized healthcare provider/caregiver (with User’s consent), to enable that individual to monitor your child’s progress and overall condition and to follow up with User, as they deem appropriate.

Where is User Personal Data processed?

Personal Data We through the App will be stored on secure cloud-based servers in the United States. Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. 

The mobile App from different App Stores is “native” to User’s devices, meaning information User enters into the App is also stored directly on the device User uses to access and enter information into the App. A non-native browser-based web application is also available for use. 

Will We share User Personal Data with anyone else?

Yes, with third parties that help Us power Our Services

We have a limited number of service providers and other third parties (“Business Partners”) that help Us run various aspects of Our business. These Business Partners are contractually bound to protect User’s Personal Data and to use it only for the limited purpose(s) for which it is shared with Us. Business Partners’ use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT services, customer service, and payment processing.

Yes, with third parties and the government when legal or enforcement issues arise

We may share Personal Data, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Privacy Policy or the Terms of Service; or (iii) bring legal action against someone who may be violating the Terms of Service or who may be causing intentional or unintentional injury or interference to the rights or property of Little Otter, Inc. or any third party, including other users of Our Services.

Yes, with third parties that provide advisory services

We may share Personal Data with third parties that provide use services, including but not limited to, Our lawyers, auditors, accountants, or banks, when We have a legitimate business interest in doing so.

Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Little Otter, Inc.’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).

If We share Personal Data with a third party other than as provided above, you will be notified at the time of data collection or transfer, and you will have the option of not permitting the transfer.

Parents/Guardians - Yes, with a healthcare provider, third-party, and/or caregiver for purposes of treatment or as you direct us to 

Parents/ Guardians- We will share information you enter into the App, as well as any reports generated by the Services based on the information you enter, with your child(ren)’s healthcare provider for treatment purposes. We will also share this information with any third-party or caregiver with whom you choose to allow Us to share such information. If, at any point, you want to deny access to one or more third parties, you can do so by emailing privacy@littleotterhealth.com. 

How long do We retain Personal Data?

We will retain Personal Data for as long as you maintain a User Account and up to 7 years after the account is closed. The exact period of retention will depend on the type of Personal Data, Our contractual obligation to you, and applicable law. We keep Personal Data for as long as necessary to fulfill the purpose for which it was collected, unless otherwise required or necessary pursuant to a legitimate business purpose outlined in this Privacy Policy. At the end of the applicable retention period, We will remove Personal Data from our databases and will request that our Business Partners remove Personal Data from their databases. If there is any data that We are unable, for technical reasons, to delete entirely from our systems, We will put in place appropriate measures to prevent any further processing of such data. We retain anonymized data indefinitely.

NOTE: Once We disclose Personal Data to third parties, We may not be able to access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom We have made those disclosures. Written requests for deletion of Personal Data other than as described should be directed to privacy@littleotterhealth.com.

What is Our Cookie Policy?

Cookies are small files that a web server sends to your computer or device when a User visits a web application that uses cookies to keep track of your activity on that site. Cookies also exist within applications when a browser is needed to view certain content or display certain content within the application. Cookies hold a small amount of data specific to a web application, which can later be used to help remember information User enters into the application (like your email or username), preferences selected, and movement within the application. If you returns to a previously visited web application (and User’s browser has cookies enabled), the web browser sends the small file to the web server, which tells it what activity User engaged in the last time User used the web application, and the server can use the cookie to do things like expedite logging in and retrieving user data and keeping  User’s browser session secure.

We use cookies and other technologies to, among other things, better serve Users with more tailored information, and to facilitate efficient and secure access to the Services. We only use essential cookies. Essential cookies are those necessary for Us to provide services to Users.  We have provided, below, a full list of Our cookies, categorized as described above. We have described the purpose of each, whether they are Our cookies or Third-Party cookies, and how to withdraw consent to their use. We have also indicated which cookies are “session cookies” (which last for as long as Users’ browsers remain open) and “persistent cookies” (which remain on a User’s hard drive until the User deletes them or they expire).

We may also collect information using pixel tags, web beacons, clear GIFs or other similar technologies. These may be used in connection with some website pages and HTML­ formatted email messages to, among other things, track the actions of users and email recipients, and compile statistics about usage and response rates.