Privacy Policy 

1. About Your Privacy and This Privacy Policy

Your privacy is extremely important to us. We are constantly putting a great deal of thought, effort, tools, resources and procedures in place in order to protect and safeguard your privacy. This document is our "Privacy Policy" and it contains details on issues related to your privacy when using our services. This Privacy Policy applies to visitors to the public websites owned and operated by Better Speech, the registered users of Better Speech’s associated mobile and web application (collectively with the websites, the "Platform"), and to the Therapists that provide the Therapist Services ("Therapists"). It is intended to inform you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide through the Platform.

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California residents should read the information available in the Privacy Notice for California Residents below.

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European Union residents should read the information available in the Privacy Notice for European Union Residents below about the categories of personal information to be collected from them and the purposes for which the personal information will be used.

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The Privacy Policy is part of our Terms and Conditions. The terms in the Privacy Policy (such as, but not limited to, "we", "our", "us", "Platform", and "Therapist Services") have the same meaning as in our Terms and Conditions document. When you use our Platform you accept and agree to both the Terms and Conditions and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Platform immediately or cease to provide the Therapist Services, as applicable. By accessing and using our Platform or providing the Therapist Services, as applicable, you affirm that you have read the Terms and Conditions and the Privacy Policy and that you understand, agree to and acknowledge all the terms contained in both of them.

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2. Information Collection, Use, and Disclosure

Categories of Information Collected
 

To let us operate the Platform effectively and to let you use the Platform, including the Therapist Services, we may collect, use, and store the information described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Platform. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy.

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Visitor Data: Better Speech collects, uses, and stores data regarding user visits to its website and use of the Better Speech application ("Visitor Data"), including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to the Better Speech "FAQ" page, and information about the browser or device used to access the website and application, such as the user’s mobile device ID and IP address. These practices apply to users who visit pages for prospective new customers as well as those who visit pages for prospective Therapists.

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Onboarding Data: In addition to the questionnaire responses provided by users (including Therapists) in the process of initial registration, Better Speech collects, uses, and stores certain additional data from users during the onboarding process ("Onboarding Data"). This data includes the pages viewed by the user, whether the user clicks the "Get started" link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.

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Account Registration Data: Better Speech collects, uses, and stores certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number ("Account Registration Data"). Better Speech also assigns each user (including Therapists) who creates a Better Speech account an anonymized, randomly-generated client ID.

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Transaction Data: Better Speech collects, uses, and stores certain information regarding payment for its services by users and related transactions on its website, such as whether a user completed payment for Better Speech’s services, signed up for Better Speech’s services using a trial offer, canceled or otherwise ended a trial, or completed a request to receive financial aid for Better Speech’s services ("Transaction Data").

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Login Data: Better Speech collects, uses, and stores data regarding logins to Better Speech’s Platform by registered users (including Therapists) and activity conducted during that log in such as when a user logs in, the number of messages received or sent through Better Speech’s website or app during that log in, and whether a user has been assigned, started, or completed a Therapy goal ("Login Data"). Login Data does not include the content of any messages sent or received by users or the content of any Therapy goals.

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Therapy Session Data: Better Speech collects, uses, and stores certain general data regarding user Therapy sessions such as whether a live session has been scheduled by the user, whether a Therapist or user joins a scheduled session, when a Therapy session began and ended, and whether a Therapy session was canceled or re-scheduled.

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Customer Data: Better Speech collects, uses, and stores certain data from users that have signed up for Better Speech’s services such as a user’s self-reported name or nickname, age, e-mail address, phone number, and emergency contact information ("Customer Data").

Therapist Data: In order to credential, recredential, run checks and pay Therapists, Better Speech collects, uses, and stores certain data from Therapists. This data includes information such as the Therapist’s name, e-mail address, and phone number, address, NPI number (if applicable), CAQH number (if applicable) and education and job history ("Therapist Data").

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Communications Data: Better Speech collects, uses, and stores communications between users and Therapists on the Platform, and communications between users and Better Speech’s customer service team ("Communications Data").

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Protecting this information is important for us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless you requested or approved us to do so.

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Purposes for Which Information is Used

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We may use the information we collect for one or more of the following purposes:

 

Communication with you

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• To contact you or provide you with information, alerts and suggestions that are related to the Platform.

• To verify your identity.

• To complete an activity you requested, such as register for the Platform or obtain more information.

• To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
   

Delivery of services to you
 

• To create your account on our Platform and let you log in to your account and use the Platform.

• To manage your account, provide you with customer support, and ensure you are receiving quality service.

• For billing and transaction processing purposes.

• To match users with Therapists and facilitate the Therapist Services.

• To provide, support, personalize, and develop our Platform and the Therapist Services.
   

Administration and improvement of services
 

• To supervise, administer and monitor the Platform.

• To measure and improve the quality, effectiveness and delivery of our services.

Customization and marketing
 

• To advertise and market the Platform and Therapist Services to potential users and Therapists.

• To personalize website experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads through our websites, third-party sites, and via email or text message.
   

Compliance with law
 

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and safety.
   

Other uses with consent
 

• Any other purpose with your consent.

Purposes for Which Information is Disclosed to Third Parties

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Information about you may be disclosed to third parties for one or more of the following purposes:

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For business purposes and advertising: We may share a user’s information with a Therapist and a Therapist’s information with a user only as necessary for facilitating the Therapist Services. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.

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With your direction or consent: We may share your information with third parties if you request or direct us to do so.

Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.

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In the context of a transaction: We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.

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For other business reasons: We may share your information to enforce any applicable Terms and Conditions and Terms of Use, and to ensure the safety and security of the Platform and our users.

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Note that if you make any information publicly available on the Platform, anyone may see and use such information.

 

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.

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4. Cookies and Web Beacons
 

Like many websites, we use "cookies" and "web beacons" (also known as pixels) to collect information. A "cookie" is a small data file that is transferred to your computer's hard disk for record-keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. A "web beacon" is a tiny and sometimes invisible image or embedded code, placed on a Web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users at a website for the purpose of web analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.
 

You can change your browser's settings so it will stop accepting cookies or to prompt you before accepting a cookie.

Use of Cookies, Web Beacons, and Similar Technology for Analytics

We may use third party cookies for the purposes of web analytics, attribution, and error management. Our Platform may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, indicate that you heard about us on television, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, and your response as to the referral source to the Platform.

 

Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our websites for purposes of analytics and analysis of certain Platform usage.
 

Use of Cookies, Web Beacons, and Similar Technology for Advertising Networks
 

You and others may see certain ads for our services or for the Platform on other websites because we participate in ad networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track individuals’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites.
 

5. Social and General Information Tools

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We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, and others (collectively "Social and General Information Tools"). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.

6. Phishing

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).
 

7. Links

The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use.
 

8. Security of Information

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 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.
 

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 without their parent or guardian. If you are 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.
 

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.
 

12. Changes to the Privacy Policy

We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform.
 

13. Contacting us

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by clicking the "Contact" link at the bottom of any page in our website.
 

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements and is expressly made part of the information contained in the Better Speech Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this Notice.
 

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 household ("personal information"). The description of the information that we collect is provided above, in the section titled "Categories of Information Collected." In particular, our websites have collected the following categories of personal information from 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:

The information that we share with third parties is described in greater detail below in the section titled "Purposes for Which Information is Disclosed to Third Parties."
 

Better Speech obtains the categories of personal information listed above from the following categories of sources:
 

• Directly from you. For example, from information you submit on the Platform during the process of using and paying for our Services.

• Indirectly from you. For example, from observing your actions on our websites or on an application provided by us.

• From third-party business partners such as social media sites, ad networks, and analytics providers.

 

   2. Use of Personal Information
 

We may use the personal information we collect for one or more of the following business or marketing purposes:

Category of Personal Information

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3. Disclosure of Personal Information
 

In the 12 months preceding the date of this Privacy Policy, Better Speech has shared personal information with the following categories of third parties:

 

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The CCPA defines "sale" broadly. It includes the sharing of personal information in exchange for anything of value. According to this broad definition, in the 12 months before this section was last updated, our use of analytics and targeting cookies and web beacons to deliver advertising tailored to individual interests may have been considered a "sale" of personal information.
 

4. Your Rights and Choices

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The CCPA provides 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 Better Speech disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will disclose to you:
 

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting that personal information.

• The categories of third parties with whom we shared that personal information.

• The specific pieces of personal information we collected about you.

• If we disclosed your personal information for a business purpose and identifying the personal information categories that each category of recipient obtained.
   

Right to Request Deletion of Information

You have the right to request that Better Speech delete any of your personal information that we collected about you and retained, subject to certain exceptions. 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.

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We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

We may also deny your request if the information in question is not subject to the CCPA. Examples of such information include de-identified information, information covered by the Health Insurance Portability and Accountability Act, and information covered by the California Confidentiality of Medical Information Act.

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Right to opt out of sale

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You have the option to opt out of the use or disclosure of your information that is considered a "sale" under the CCPA. If you would like to opt out of the use and disclosure of your information, please email info@betterspeech.com.

 

Exercising Your Rights

 

To exercise the rights listed above, please submit a request in writing to Better Speech via info+DPO@betterspeech.com. 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.

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You may only make a request for access twice within a 12-month period. Your request must:

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• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
   

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.

 

You may submit a request by completing the form in writing and sending it to:

Better Speech
Data Protection Office
500 Westover Drive #11458
Sanford, NC 27330
info+DPO@betterspeech.com

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By calling our number: (203) 896-7995

 

Response Timing and Format

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We endeavor to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days from the day of receipt), we will inform you of the reason and extension period in writing.

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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.

5. Non-Discrimination

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We will not discriminate against you for exercising any of your CCPA rights. We will not:

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• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

​6. Other California Privacy Rights

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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 info+DPO@betterspeech.com.
 

7. Changes to Our Privacy Notice

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Better Speech reserves the right to amend this Privacy Notice at our discretion and at any time. When we make any changes to this Privacy Notice, we will post the updated Privacy Notice on our websites and update the Privacy Notice's effective date. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform. Your continued use of our websites and services following the posting of changes constitutes your acceptance of such changes.
 

8. Contact Information

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If you have any questions or comments about this Privacy Notice, the ways in which Better Speech 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:
 

Better Speech
Data Protection Office
500 Westover Drive #11458
Sanford, NC 27330
info+DPO@betterspeech.com

General Data Protection Regulation (GDPR) Notice
 

This section provides additional information about our Privacy Policy relevant to users from the European Union (EU) and Switzerland. It supplements and should be read in conjunction with the rest of the Privacy Policy. Under the GDPR, Better Speech is the Controller with respect to your Personal Data.

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Better Speech may use your personal information:

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• When it is necessary to do so to perform our obligations in accordance with any contract that we may have with you, for example to manage your account, and to respond to enquiries about your use of the Platform.

• When it is in our legitimate interests or a third party's legitimate interests to use personal information in such a way to ensure that we provide the Platform in the best way that we can. In particular, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Platform. We only rely on our or a third party's legitimate interests to process your personal information when these interests are not overridden by your rights and interests.

• When it is necessary to do so in order to comply with any legal obligations imposed upon us, for example under applicable law.

When you have consented to the use of your personal information, for example for marketing purposes or to track your online activities via Cookies and similar technologies.

1. Your Rights and Choices

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EU and Swiss residents have specific rights regarding their personal information. This section describes your rights if you are resident in the EU or Switzerland, and explains how to exercise those rights.
 

Right of access: You may be entitled to ask us for a copy of any personal information which we hold. This right is known as a ‘Subject Access Request.’ We will normally send you a copy of the personal information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the personal information that you request. There is usually no charge; but in exceptional circumstances we may charge but will discuss this with you if those circumstances apply.
 

Right to rectification: If the personal information we hold about you is inaccurate, you may request rectification. The personal information will be checked, and, where appropriate, inaccuracies will be rectified.
 

Right to erasure: In certain circumstances, you may be entitled to ask us to erase your personal information.

Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic personal Information that we hold about you to another organization.
 

Right to object: You may object to your personal information being used for direct marketing. You may object to the continued use of your personal information in any circumstances where we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for processing your personal information, you may object to us continuing to process your personal information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your personal information, we may continue to do so. In that event, we will let you know the reasons for our decision.

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Rights related to automated decision-making including profiling: We use limited personal information to operate the Platform and to carry out certain profiling activities to support and grow our business. When doing so, we rely upon our legitimate interests as the lawful basis for processing your personal information and you may exercise the above rights if you do not wish us to process your personal information in this way.
 

To exercise the rights in relation to your Personal Information set out in this section, please contact us by emailing info+DPO@betterspeech.com
 

2. International Data Transfers
 

The Platform is controlled and operated by us from the United States. By accepting the terms of this Privacy Policy you agree that any personal information you provide to us through use of the Platform may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy at all times.

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You can contact our Data Protection Officer with questions, about this policy, or about your personal information by writing to:

 

Better Speech
Data Protection Officer
500 Westover Drive #11458
Sanford, NC 27330
info+DPO@betterspeech.com

 

Whilst we will always work with you to resolve any concerns you have about the use of your personal information, under GDPR you have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your personal information.

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