Privacy Policy

Protecting your private information is our priority. This Statement of Privacy applies to all
Platinum Teletherapy websites and governs data collection and usage. By using any Platinum
Teletherapy website, you consent to the data practices described in this statement.

Collection of your Personal Information

Platinum Teletherapy (“Platinum”) may collect personally identifiable information, such as your
e-mail address, name, home or work address, or telephone number. If you purchase Platinum
products and services, we collect and store billing and credit card information. Platinum may
also collect anonymous demographic information, which is not unique to you, such as your
Postal Code, age, gender, preferences, interests, and favorites. Platinum will not delete customer
information for paying members. Information about your computer hardware and software also
may be automatically collected by Platinum. This information can include: your IP address,
browser type, domain names, access times, and referring website addresses. This information,
obtained through Google Analytics, is used by Platinum for the operation of the service, to
maintain quality of the service, and to provide general statistics regarding use of the website.
Should you desire to access or delete the information collected by Google, you can do so via My
Google Activity. Platinum encourages you to review the privacy statements of websites you
choose to link to from any Platinum website so that you can understand how those websites
collect, use, and share your information. Platinum is not responsible for the privacy statements or
other content on websites outside of the Platinum family of websites.

Use of your Personal Information

Platinum collects and uses your personal information to operate the website and deliver the
services you have requested. We will periodically send service updates to registered users.
Platinum may also use your personally identifiable information to inform you of other products
or services available from Platinum and its affiliates. Platinum may also contact you via surveys
to conduct research about your opinion of current services or of potential new services that may
be offered. Platinum does not sell, rent, or lease its customer lists to third parties. Platinum may,
from time to time, contact you on behalf of external business partners about a particular offering

that may be of interest to you. In those cases, your unique personally identifiable information (e-
mail, name, address, telephone number) is not transferred to the third party without your explicit

consent. In addition, Platinum may share data with trusted partners to help us perform statistical
analysis, send you email or postal mail, provide customer support, or arrange for deliveries.
Platinum may share your information with third parties who perform tasks required to complete a
purchase transaction. All such third parties are prohibited from using your personal information
except to provide these services to Platinum, and they are required to maintain the confidentiality
of your information. Platinum does not use or disclose sensitive personal information, such as
race, religion, or political affiliations, without your explicit consent. Platinum keeps track of the
websites and pages that our customers visit, in order to determine what services are the most
popular. This data is used to deliver customized content to customers whose behavior indicates
that they are interested in a particular subject area. Platinum websites will disclose your personal

information, without notice, only if required to do so by law or in the good faith belief that such
action is necessary to: (a) conform to the edicts of the law or comply with legal process served
on Platinum; (b) protect and defend the rights or property of Platinum; and, (c) act under exigent
circumstances to protect the personal safety of users of Platinum, or the public. Parents or
children under 13 have the option to agree to the collection and use of the child’s information
without consenting to the disclosure of the information to third parties. Children under 13 will
not be asked to disclose more information than is reasonably necessary to participate in an
activity as a condition of participation. If a parent of child under 13, wishes to review the child’s
personal information, ask to have it deleted, or refuse to allow any further collection or use of the
child’s information, that parent must contact Platinum.

Use of Cookies

Platinum may use “cookies” to help you personalize your online experience. A cookie is a text
file that is placed on your hard disk by a web page server. Cookies cannot be used to run
programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can
only be read by a web server in the domain that issued the cookie to you. One of the primary
purposes of cookies is to provide a convenience feature to save you time. The purpose of a
cookie is to tell the Web server that you have returned to a specific page. For example, if you
personalize Platinum pages, or register with Platinum, a cookie helps Platinum to recall your
specific information on subsequent visits. This simplifies the process of recording your personal
information, such as billing addresses, shipping addresses, and so on. When you return to the
same Platinum website, the information you previously provided can be retrieved, so you can
easily use the Platinum features that you customized. You have the ability to accept or decline
cookies. Most Web browsers automatically accept cookies, but you can usually modify your
browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be
able to fully experience the interactive features of the Platinum services or websites you visit.

Security of your Personal Information

You are responsible for safeguarding and preventing unauthorized access to the user information
and password that you use to access Platinum. You agree not to disclose your password to any
third party and you are responsible for any activity using your account, whether or not you
authorized that activity. You must immediately notify Platinum of any unauthorized use of your
account. Platinum secures your personal information from unauthorized access, use, or
disclosure. Platinum secures the personally identifiable information you provide on computer
servers in a controlled, secure environment, protected from unauthorized access, use or
disclosure. When personal information (such as a credit card number) is transmitted to other
websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL)

FERPA Compliance and Student Data Privacy

Platinum is a vendor to educational agencies and institutions (EAs) and receives personally
identifiable information (PII) contained in student records from the EAs. Only information that is
needed for Platinum and its employees and contractors to perform services is disclosed to

Platinum by the EA. These disclosures are authorized under the Family Educational Rights and
Privacy Act (FERPA). Platinum, as a contractor to the EA, receives the disclosures on the same
basis as school officials employed by the EA, consistent with FERPA regulations, 34 CFR
§99.31(a)(1)(i)(B). Consistent with those regulations, Platinum has a legitimate educational
interest in the information to which it is given access because the information is needed to
perform the outsourced service, and Platinum is under the direct control of the EA in using and
maintaining the disclosed education records, consistent with the terms of its contract.
Platinum is subject to the same conditions on use and redisclosure of education records that
govern all school officials, as provided in 34 CFR §99.33. In particular, Platinum must ensure
that only individuals that it employs, contracts with, or that are employed by its contractor, with
legitimate educational interests – consistent with the purposes for which Platinum obtained the
information — obtain access to PII from education records it maintains on behalf of the district
or institution. Further, in accordance with 34 CFR §99.33(a) and (b), Platinum may not
redisclose PII without consent of a parent or an eligible student (meaning a student who is 18
years old or above or is enrolled in postsecondary education) unless the agency or institution has
authorized the redisclosure under a FERPA exception and the agency or institution records the
subsequent disclosure. An example of such a disclosure is when Platinum is requested by a
school district to assist the district in the transfer of the student records from our system to
another system.
Platinum will not sell or otherwise use or redisclose education records for targeted advertising or
marketing purposes. Platinum does not allow advertising within its products or services, and
therefore there is no behavioral or targeted advertising. Platinum uses data within its products
and services only to deliver the services contracted by the educational institution. Platinum may
use anonymized, non-PII data internally to improve the products and services it delivers to EAs.
Platinum employs extensive technological and operational measures to ensure data security and
privacy, including advanced security systems technology, physical access controls, and security
and privacy training for employees regarding compliance with FERPA, HIPAA, and other
applicable privacy laws.
Platinum does not own any of the student data or district-created data within its products. These
data within the products are property of, and under the control of, the EA.
In the event any third party seeks to access education records, Platinum will immediately inform
the EA of such request in writing. Platinum shall not provide access to such data or information
or respond to such requests unless compelled to do so by due process, court order or lawfully
issued subpoena from any court of competent jurisdiction or directed to do so by the EA. Should
Platinum receive a court order or lawfully issued subpoena seeking the release of such data or
information, Platinum shall provide immediate notification, along with a copy thereof, to the EA
prior to releasing the requested data or information, unless such notification is prohibited by law
or judicial and/or administrative order or subpoena.
If the EA is unable to fulfill a request of an eligible student or parent/guardian to review the
student’s records, Platinum can assist at the direction and expense of the EA. In such an event

where a parent, legal guardian, or eligible student seeks to make changes to the data within our
products, parents, legal guardians, or eligible students shall follow the procedures established by
the EA in accordance with FERPA. Generally, these procedures establish the right to request an
amendment of the student’s education records that the parent or eligible student believes is
inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA.
Parents or eligible students who wish to ask the EA to amend their child’s or their education
record should write an EA official (often a Principal or Superintendent), clearly identify the part
of the record they want changed, and specify why it should be changed. If the EA decides not to
amend the record as requested by the parent or eligible student, the EA will notify the parent or
eligible student of the decision and of their right to a hearing regarding the request for
amendment. Additional information regarding the hearing procedures would be provided to the
parent or eligible student when notified of the right to a hearing.
In the event Platinum becomes aware of a data breach or inadvertent disclosure of PII, Platinum
shall take immediate steps to limit and mitigate such security breach to the extent possible.
Platinum will notify a senior member of the affected EAs leadership team, ideally the
Superintendent or similar chief executive. This typically will occur within 48 hours of
confirmation of the event and would include the known relevant details. The EA and Platinum
will work cooperatively in determining an action plan, including any required notification of
affected persons.
In the event of termination to use our services or products, and at the written request of the EA or
in accordance of the terms of the EAs contract, Platinum will make commercially reasonable
efforts to destroy all student records contained in our systems. Furthermore, Platinum shall
ensure that it disposes of any and all data or information received from the EA in a commercially
reasonable manner that maintains the confidentiality of the contents of such records (e.g.
shredding paper records, erasing and reformatting hard drives, erasing and/or physically
destroying any portable electronic devices). At the written request of the EA, Platinum will
provide a written certification of destruction.
If the EA does not make a written request, Platinum retains student data for a period 6 years.
To the extent parents, guardians or students have questions regarding the content of, or privacy
associated with, any applications used by the educational institution, please contact that agency
or institution.

HIPAA Compliance

Student records that are disclosed to Platinum by EA and maintained within Platinum products
are by definition “education records” under FERPA and not “protected health information” under
the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Because student
health information in education records is protected by FERPA, the HIPAA Privacy Rule
excludes such information from its coverage. See the exception at paragraph (2)(i) to the
definition of “protected health information” in the HIPAA Privacy Rule at 45 CFR § 160.103.
See, also, Joint Guidance on the Application of the Family Educational Rights and Privacy Act
(FERPA) and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to

Student Health Records, USED and U.S. Department of Health and Human Services (November
However, Platinum strives to comply with all privacy laws and therefore has taken measures to
ensure that we are HIPAA compliant.

Changes to this Statement

Platinum will occasionally update this Statement of Privacy to reflect company and customer
feedback, and to be in compliance with evolving state and federal laws and regulations. A
message will be posted on Platinum websites to notify you of the changes. Platinum encourages
you to periodically review this Statement to be informed of how Platinum is protecting your

Contact Information

Platinum welcomes your comments regarding this Statement of Privacy. If you believe that
Platinum has not adhered to this Statement, please contact us.
(888) 270-1148

Last Updated: May 20, 2020