2. Information Collection, Use, and Disclosure
To let us operate the Platform effectively and to let you use the Platform, including the Therapist Services, we may have to collect your personally identifiable information (such as, but not limited to, your name, phone number, email address, and address), billing and payment information, profile information, log data (information such as your computer, Internet Protocol address (“IP”), pages that you visit and the amount of time spent on those pages, actions you take and other statistics), information related to the Therapist Services or your need for Therapist Services, and any information which is exchanged between you and your Therapist (collectively the "Information").
The Information may be used or disclosed to third parties for one or more of the following business or marketing purposes:
3. Opting out of Marketing Communication
You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.
4. Cookies and Web Beacons
5. Social and General Information Tools
Online identity theft and account hacking, including the practice currently known as "phishing", are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).
While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with or exceed all applicable federal laws, state laws, and regulations regarding data privacy.
9. Service Providers
We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.
9. Children's Privacy
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you're aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.
10. International Transfer
Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction. Regardless of where your data is stored, it will be maintained securely as outlined in this policy. Your consent to our Terms and Conditions followed by your submission of such information represents your agreement to such transfers.
11. Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Therapists may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.
11. General Data Protection Regulation (GDPR) Notice
You can view and edit any personal data that you have provided to us using this website. Automated processing of your Personal Information is necessary to operate the Platform effectively and to provide counseling and related services.
You can exercise any of the rights the law confers to you, like for example: opt-out of all data processing, or request erasure of your data by emailing firstname.lastname@example.org for instructions. In some cases, we may be required to retain personal data to comply with applicable medical record retention laws.
Total Life Inc. is the Controller with respect to your Personal Data. You can contact our Data Protection Officer with questions, concerns or objections about this policy, or about your data by writing to:
Total Life Inc.
1951 NW 7th Ave, #600, Miami, FL, 33136 or emailing to:
You can contact our EU Representative by emailing to:
Total Life Inc. EU Representative
C/O Legal Department
13. Contacting us
Privacy Notice for California Residents
1. Information We Collect
Through your use of our website, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Websites have collected the following categories of personal information from its consumers within the last twelve (12) months.
Additionally, we have disclosed the following categories of information for a business purpose in the past twelve (12) months with each line representing: the
Category (A. to K.), 2. Collected (Yes/No), and
3. Disclosed for a business purpose (Yes/No).
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C. Protected classification characteristics under California or federal law.
D. Commercial information.
E. Biometric information.
F. Internet or other similar network activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
K. Inferences drawn from other personal information.
Personal information does not include:
Total Life Inc. obtains the categories of personal information listed above from the following categories of sources:
2. Use of Personal Information
First and foremost, Total Life Inc. does not sell and has not sold any Personal Information in the preceding twelve (12) months.
We may use or disclose the personal information we collect for one or more of the following business or marketing purposes:
Total Life Inc. will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. Disclosure of Personal Information
Total Life Inc. may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share the minimum necessary personal information with the following categories of third parties:
4. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Request Access to Information
You have the right to request that Total Life Inc. notifies you of the personal information about you that we have collected and used. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
Right to Request Deletion of Information
You have the right to request that Total Life Inc. deletes any of your personal information that we collected about you and retained. Once we receive your request and verify who you are, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Your Rights
To exercise the rights listed above, please submit a request in writing to Total Life Inc. via the contact information listed in the Contact Information section. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.
You may only make a request for access twice within a 12-month period.
Your request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify your identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. We will not:
6. Other California Privacy Rights
California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that 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, please send an email to DPO@Totallife.com.
7. Changes to Our Privacy Notice
8. Contact Information
If you have any questions or comments about this Notice, the ways in which Total Life Inc. collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Total Life Inc.
Data Protection Officer
1951 NW 7th Ave, #600, Miami, FL, 33136
Last Updated and Effective: November 20, 2020