Privacy Policy

Last Updated: April 11, 2025

1. SCOPE

This Privacy Policy (the “Privacy Policy”) serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use the website (the “Site”), services, software, mobile applications, content, and all other products and services (all of the foregoing collectively, the “Services”) owned, controlled or offered, directly or indirectly, by Silent Time, Inc. dba Tori Health (together with its subsidiaries and affiliates, “Company”, “we,” “our” or “us”).  We believe that the privacy of its users is paramount and strives to use Personal Information (as defined below) only in ways outlined in this Privacy Policy.  The Privacy Policy is incorporated by reference into our Terms of Service, currently available at www.torihealth.com/th-terms-of-service (the “Terms of Service”). By using the Services, you hereby warrant and represent that you have read, understand and agree to this Privacy Policy and the Terms of Service, that you are a resident of the United States and that you are over 18 years of age.  PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

We work closely with Tori Medical, PC, Tori Medical Wisconsin, PC and their licensed mental health professionals (“Providers”).  This Policy covers the activities of all of these entities for services delivered through these entities.  

Some Providers may have additional Privacy Policies or Informed Consent documents that describe their data practices; see those documents for more information on how your Provider may use your personal information during care. 

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect, with your consent, depend on how you interact with us, our Services, and the requirements of applicable law. For example, we may collect different information depending on whether you: (i) browse our Website, (ii) request additional information; (iii) are a patient; (or (iv) otherwise interact directly with us. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us:

  • Account Creation
    We may collect information when you create an account on our site or our care center, such as your name, date of birth, email address, IP address, account passwords, and phone number both for the provision of services and through our care center.

  • Contact Us
    If you use one of our “Contact Us,” “Get Help Now,” “Share feedback” or similar features or subscribe or register for one of our products or services (or create an account for any such product or service), we may collect your email address, first and last name, telephone number, address, and, if applicable, organization information.

  • Filling in Forms on our Websites
    If you request to receive information, subscribe to a mailing list, or register to volunteer, we will collect information such as your first and last name, email address, and telephone number.

  • Service Access
    We may collect information when you access our Services through our website or related online portals.

  • Your Communications with Us
    We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.

  • Surveys
    We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.

  • Business Development and Strategic Partnerships
    We may collect personal information from individuals and third parties to assess and pursue potential business opportunities. 

  • Job Applications
    We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.

B. Information Collected Automatically 

We may collect personal information automatically when you use our Services:

  • Automatic Data Collection Through Our Services.
    We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. 

  • Cookies, Pixel Tags/Web Beacons, and Other Technologies.
    We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. 

C. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, we may obtain information related to your medical history through your healthcare provider (a “Healthcare Provider”).  

3. HOW WE USE YOUR INFORMATION

We use your information to provide our Services and for a variety of business purposes, including administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

  • Managing your information and accounts;

  • Providing access to certain areas, functionalities, and features of our Services;

  • Answering requests or responding to comments for customer or technical support; 

  • Communicating with you about your account, activities on our Services, and policy changes;

  • Processing applications if you apply for a job we post on our Services; and

  • Allowing you to register for events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

  • The purposes set forth in the authorization you provide to Tori Health; 

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research or improving our Website or Services), network and information security, and fraud prevention;

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

  • Measuring interest and engagement in our Services; 

  • Short-term, transient use, such as contextual customization of ads;

  • Improving, upgrading or enhancing our Services; 

  • Developing new products and Services;

  • Ensuring internal quality control and safety;

  • Authenticating and verifying individual identities, including requests to exercise your rights under this policy;

  • Debugging to identify and repair errors with our Services;

  • Auditing relating to interactions, transactions and other compliance activities;

  • Protecting our Company and others;

  • Enforcing our agreements and policies; and

  • Complying with our legal obligations.

C. Marketing and Advertising our Products and Services

As permitted by applicable state and federal privacy laws, we may use personal information to tailor and provide you with content and advertisements. 

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time at team@torihealth.com.

D. Other Purposes

We also use your information for other purposes, as permitted by applicable state and federal privacy laws.

  • Consent
    We may use personal information with your consent or as set forth in the Informed Consent.

  • De-identified and Aggregated Information
    We may use your personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified health information, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including the development of future learnings, research, internal analysis, analytics, and any other legally permissible purposes.

  • Share Content with Patients and Healthcare Providers
    Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your Healthcare Provider through our referral services. Our referral services may allow you to forward or share certain content with a Healthcare Provider. Please only share with us contact information of people with whom you have a relationship (e.g., your patients or Healthcare Provider) and in all cases in accordance with all applicable law.

4.HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. 

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below. 

  • Service Providers
    We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.

  • Business Partners
    We may share your personal information with business and co-branding partners to provide you with a product or service you have requested. We may also share your personal information to business and co-branding partners with whom we jointly offer products or services.

  • Affiliates
    We may share your personal information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide. 

  • Healthcare Providers
    We may share your personal information with your Healthcare Provider in order to provide the Services.

  • Third-Party Services
    Certain features and functionalities within the Services may allow you to interface or interact with, access, use, and/or disclose personal information to third-party services, products, technology, medical device implant manufacturers, health care providers, and applications (collectively, “Third-Party Services”). Tori Health does not provide any aspect of the Third-Party Services and is not responsible for your use of or sharing of information with the Third-Party Services. Once your personal information has been shared with the Third-Party Service, it will also be subject to the Third-Party Service’s privacy policy and the Third-Party Service may use your personal information for its own purposes. We encourage you to closely read each Third-Party Service’s privacy policy with whom you share your personal information. You acknowledge sole responsibility for and assume all risk arising from your use of or sharing of information with any Third-Party Services. Tori Health

  • APIs/SDKs
    We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us at team@torihealth.com.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices

The privacy choices you have about your personal information are determined by applicable law and are described below. 

  • Email and Telephone Communications
    If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy). 

  • Text Messages
    You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

  • Mobile Devices
    We may send you push notifications through our mobile application. You may opt out of receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

  • “Do Not Track.”
    Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Your Privacy Rights

In accordance with applicable law, you may have the right to:

  • Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; 

  • Request Correction of your personal information where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;

  • Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant; 

  • Request Restriction of or Object to our processing of your personal information when processing is noncompliant; 

  • Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;

  • Request data portability and receive an electronic copy of personal information that you have provided to us;

  • Be informed about third parties with which your personal information has been shared; and

  • Request the review of decisions taken exclusively based on automated processing if that could affect data subject rights.

If you would like to exercise any of these rights, please contact us as at team@torihealth.com. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

7. RETENTION OF PERSONAL INFORMATION 

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.  

8. ADDITIONAL DISCLOSURES FOR INDIVIDUALS RESIDING IN CERTAIN U.S. STATES

Depending on your state of residence, your state may have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Laws”).

Our Privacy Policy explains how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices.  Below, we use two different tables to explain this same information in accordance with the State Laws.  The tables describe our data practices now, and over the past 12 months. 

Category of Personal Information

Identifiers, such as your contact and account information, name, mailing address, and email address Protected classifications under California or Federal law, Commercial information, Biometric information, Internet or other electronic network activity information, Geolocation dataInferences, Sensory data, Professional or employment related information.

Categories of Recipients

Service providers, health care providers, business partners and affiliates (including fraud prevention partners, data analytics providers, marketing partners, customer support partners, Internet service providers, operating systems and platforms, customer feedback platforms, and cloud service providers), and governmental entities.

Use of Personal Information

Provide, maintain, improve, and develop our products and services; Personalize your experience with us; Send you technical notices, security alerts, support messages and other transactional or relationship messages; Monitor and analyze trends, usage, and activities in connection with our products and services; Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Tori Health and others; and Comply with our legal and financial obligations.

We retain personal information for as long as necessary to carry out the purposes for which we originally collected it and for other purposes described in this privacy policy.

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.

Your Privacy Rights

Opt Out of Sales, Sharing, and Targeted Advertising

Some of the activities described in the Targeted Advertising and Analytics section above may be considered “sales” or “sharing” of your personal information or use of your information for “targeted advertising” under the law that applies to you. You can opt out of cookie-based ad targeting on our website by contacting us directly at team@torihealth.com. You will need to renew your opt-out choice if you visit our website from a new device or browser or if you clear your cookies because your opt-out choice will be linked to your browser only. 

In addition to cookie-based ad targeting, we may disclose information about your purchases and contact information (such as email and mailing address) to our affiliates, advertising partners, and other third parties for marketing and advertising purposes, which may constitute “sales” or “sharing” of your personal information or use of your information for “targeted advertising.” You can opt out of having your information disclosed to these third parties by filling out our web form.

Access, Correction, and Deletion

Depending on your state of residence, you may have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. To request access, correction, or deletion of your personal information, please contact us directly at team@torihealth.com. We will verify your request by asking you to provide certain information, such as your name, email address, mailing address, and phone number.

Appeals

If we deny your request, you may appeal our decision by contacting us directly at team@torihealth.com. If you have concerns about the results of an appeal, you may contact the attorney general in the state where you reside.

Nondiscrimination

We will not discriminate against you for exercising your privacy rights.

In certain states, you can designate an authorized agent to submit a privacy rights request on your behalf. We may ask authorized agents to submit proof of your authorization to make the request, such as a valid power of attorney or proof that they have signed permission from the individual who is the subject of the request. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm the authorized agent has permission to submit this request. If you are an authorized agent seeking to make a request, contact us directly at team@torihealth.com.

Any request to exercise one of these rights will be assessed by Tori Health on a case-by-case basis. There may be circumstances in which we are not legally required to comply with your request because of a relevant legal exemption provided for under applicable law. We will not discriminate or retaliate against you for exercising your privacy rights. If you choose not to disclose certain personal information, this may limit our ability to perform the Services to you. 

“Sales” and “Sharing” of Personal Information

We do not sell your personal information to anyone.  We may share your information with third-parties in order to provide the Service. We do not have any knowledge of any “sales” or “sharing” of the personal information of minors under 16 years of age.  You have the right to opt out of sharing at any time by contacting us directly at team@torihealth.com. Please see the “Your Privacy Choices and Rights” section above for more information about your privacy rights and how to exercise them.

Accessibility
This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF. 

California Shine the Light
The California “Shine the Light” law permits users who are California residents to request certain details about how their information is disclosed to third parties for direct marketing purposes and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for such purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.  Under the law, we must either provide this information or permit California residents to opt into, or out of, this type of disclosure. We qualify for this alternative option. To opt out of having information about you disclosed to affiliates or third parties for direct marketing purposes, please contact us directly at team@torihealth.com.

9. OTHER PROVISIONS

Third-Party Websites/Applications
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk. 

Changes to our Privacy Policy
We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

10. HIPAA COMPLIANCE AND PROTECTED HEALTH INFORMATION (PHI)

Tori Health is committed to complying with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and its implementing regulations, in our handling of your Protected Health Information (PHI). PHI includes individually identifiable health information that we receive, create, or maintain about your physical or mental health condition, the provision of healthcare to you, or payment for healthcare.

A. How We Use and Disclose PHI

Tori Health may use and disclose your PHI for purposes related to: Treatment – coordinating or managing your healthcare and related services with your healthcare providers; Payment – billing and collecting payment for services we provide; Healthcare operations – activities such as quality improvement, staff training, compliance auditing, and internal analytics; Other purposes as permitted or required by law, including public health reporting, law enforcement, or legal proceedings, with appropriate safeguards. 

We will only use or disclose your PHI for marketing, research, or other non-treatment purposes with your explicit written authorization, unless an exception under HIPAA applies.

B. Your HIPAA Rights

Under HIPAA, you have the right to: Access and receive a copy of your health records; Request corrections to your PHI; Request an accounting of certain disclosures; Request restrictions on certain uses or disclosures; Receive confidential communications; 

File a complaint if you believe your privacy rights have been violated.To exercise these rights, contact us at: team@torihealth.com

12. CONTACT US 

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Silent Time, Inc. dba Tori Health

team@torihealth.com