PRIVACY POLICY

Last Updated: April 2, 2025

Vital Start Health, Inc. (“Vital Start Health”) and Healing Circle, LLC (collectively, “Vital Start,” “we,” “us,” or “our”) are committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you access our website, vitalstarthealth.com (the “Website”), and use our virtual wellness and therapeutic services (the “Services”).

Table of Contents

1. Information We Collect
    1.1 From Qualified Mental Health Professionals (QMHPs)
    1.2 From Licensed Practitioners
    1.3 From Clients (Service Users)
    1.4 From Website Visitors
    1.5 Cookies and Tracking Technologies
2. How We Use Your Information
3. Information Sharing
4. Your Rights and Choices
5. Accessing and Managing Your Information
6. Marketing Communications
7. Do Not Track
8. Information Security
9. Age Restrictions
10. Changes to This Policy
11. Contact Us
12. Definitions

1. Information We Collect

1.1 From Qualified Mental Health Professionals (QMHPs)

QMHPs (Qualified Mental Health Professionals) are wellbeing counselors who provide non-clinical support through our platform. While most QMHPs are not licensed clinicians, some may hold licenses. Therapy services are only delivered by licensed Practitioners.

We collect the following from QMHPs:

• Full name and contact information
• Educational background and work history
• Username and password
• Profile image (optional)

This information is used to verify eligibility, set up your account, and enable participation in client care.

1.2 From Licensed Practitioners

Licensed Practitioners are clinicians (e.g., therapists, psychologists, LCSWs) who provide therapy through our platform. We collect:

• Full name and contact information
• Educational and licensure information
• License numbers, issuing states, and expiration dates
• National Provider Identifier (NPI) and insurance enrollment info
• Username and password

This information is used to verify your credentials, maintain compliance, and support clinical care and billing.

1.3 From Clients (Service Users)

When you register for and use our Services as a client, we collect:

• Name, email address, and account credentials
• Physical address, phone number, and date of birth
• Health insurance information for claims and billing
• Payment details (processed via secure third-party processor)
• Mental health history and other information shared during onboarding or care sessions
• Information collected during sessions with your assigned QMHP or Practitioner

We use this data to:

• Set up your account and verify eligibility
• Match you with a provider
• Bill your insurance or process direct payments
• Deliver services in accordance with HIPAA and state laws
• Improve and personalize your experience

All protected health information (PHI) is handled in compliance with HIPAA regulations.

1.4 From Website Visitors

If you visit the Website without registering, we may collect:

• Contact information provided through forms (e.g., for support or newsletters)
• Browsing behavior via cookies
• Device and browser data (IP address, location, browser type, etc.)

This data is used to operate the Website, respond to inquiries, and improve performance.

1.5 Cookies and Tracking Technologies

We use cookies and similar tools to collect:

• Pages viewed and time spent
• Device and location data
• Preferences and navigation behavior

Third-party tools used include:

• Google Analytics for performance tracking
• Facebook Pixel for targeted advertising

You can adjust cookie settings in your browser or opt out via the Digital Advertising Alliance or Network Advertising Initiative.

2. How We Use Your Information

We use the information we collect to:

• Deliver and personalize care
• Create and manage user accounts
• Match clients with QMHPs or licensed Practitioners
• Process insurance and direct payments
• Comply with legal and regulatory requirements
• Analyze and improve our Services
• Communicate with you about appointments, service updates, and system maintenance

We do not sell your personal data or PHI.

3. Information Sharing

We may share your information:

• With service providers (e.g., cloud hosting, billing, technical support)
• With QMHPs or Practitioners assigned to your care
• With third parties in the event of a merger, acquisition, or reorganization
• As required by law, subpoena, or government request
• To prevent fraud, security threats, or harm to others

We do not share SMS opt-ins or phone numbers for third-party marketing.

4. Your Rights and Choices

As a client, you have the right to:

• Request access to your medical records
• Request correction of inaccurate data
• Request deletion of your medical records once the 10-year retention period has passed
• Decline to provide certain information (though some features may be unavailable)
• Withdraw consent for marketing communications
• Disable cookies through your browser settings

Requests can be submitted to contact@vitalstarthealth.com.

5. Accessing and Managing Your Information

You can:

• Log into your account to update profile and contact information
• Request a copy of your medical or service records
• View session history or treatment summaries
• Ask to correct or supplement health information
• Request deletion of your records (following applicable retention timelines)

To exercise these rights, email us at contact@vitalstarthealth.com.

6. Marketing Communications

We may send newsletters, product announcements, or other promotional content to users who opt in. You may unsubscribe anytime by using the link in the email.

We will not use your PHI for marketing without your explicit HIPAA-compliant authorization.

7. Do Not Track

Our Website does not currently respond to “Do Not Track” browser signals.

8. Information Security

We implement reasonable and industry-standard safeguards, including:

• Data encryption
• Access controls and authentication
• Secure cloud infrastructure
• Routine audits and system monitoring

However, no method of internet transmission is 100% secure. We cannot guarantee absolute security.

9. Age Restrictions

The Website and Services are intended for users 18 years and older. We do not knowingly collect personal data from individuals under 18.

10. Changes to This Policy

We may revise this Privacy Policy at any time. Updates will be posted with a new “Last Updated” date. If changes materially affect your rights, we will notify you via email or through the Website.

11. Contact Us

For questions or to exercise your rights, contact:
📧 Email: contact@vitalstarthealth.com

12. Definitions

• QMHP: A Qualified Mental Health Professional (typically a wellbeing counselor, not a licensed therapist)
• Practitioner: A licensed mental health clinician (e.g., therapist, psychologist, LCSW)
• Client / Service User: A person receiving services from Vital Start
• PHI: Protected Health Information, as defined under HIPAA
• Website Visitor: An individual who accesses vitalstarthealth.com without using Services
• Services: Vital Start’s virtual wellness and therapeutic platform