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These terms of use (the “Terms of Use”) govern your access and use of the public website located at https://greenspacehealth.com/ (the “Website”) and the private portal which requires registration to be accessed located at https://app.greenspacehealth.com/ (the “Private Portal”, and together with the Website, the “Platform”). The words “Greenspace,” “we,” “us,” or “our” mean, collectively, Greenspace Mental Health Ltd. and all of its respective affiliates, successors or assigns. “You” or “your” means the patient (“Patient”) who is prompted to use the Platform at the direction of a Treatment Provider or healthcare organization.

By creating an account or accessing the Platform, you acknowledge and agree to be bound by these Terms of Use, which constitute a binding legal agreement between you, as a user of the Services (as defined in Section 4 below), and Greenspace. These Terms of Use govern your access to and use of the Platform.

USE OF THE SERVICES IS NOT FOR EMERGENCIES. IF YOU HAVE A MEDICAL OR MENTAL HEALTH EMERGENCY, OR IF AT ANY TIME YOU ARE CONCERNED ABOUT YOUR CARE OR TREATMENT, CALL 911 OR GO TO THE NEAREST OPEN CLINIC OR EMERGENCY ROOM.

IF YOU ARE CONSIDERING OR CONTEMPLATING HARMING OR KILLING YOURSELF OR ARE CONCERNED THAT YOU ARE A DANGER TO YOURSELF OR TO OTHERS, YOU MUST DISCONTINUE USE OF THE SERVICES IMMEDIATELY, CALL 911 OR GO TO THE NEAREST OPEN CLINIC OR EMERGENCY ROOM.

1. Documents Incorporated by Reference

These Terms of Use incorporate by reference the following documents, which shall be construed as forming part of these Terms of Use.

2. Definitions

“HIPAA” means the Health Insurance Portability and Accountability Act of 1996;

“Protected Health Information” or “PHI” means protected health information as defined by HIPAA’s Privacy Rule found at 45 C.F.R. § 160.103;

3. Treatment Providers

A “Treatment Provider” is a regulated professional who is permitted to provide psychotherapy services and is registered as a Therapist on the Platform. Treatment Providers may include, but are not limited to, psychiatrists, psychologists, clinical social workers, registered psychotherapists, professional counselors and marriage and family therapists. “Treatment Providers” include employees, agents, or independent contractors of Treatment Providers.

4. Services

The Platform includes, without limitation, the following services (collectively, the “Services”):

the facilitation of the delivery of assessments to You as provided by your Treatment Provider(s);
the display of the results of such assessments to You and your Treatment Provider(s);
the provision of other information about Greenspace and our products and services through the Platform.

For clarity, Greenspace is not a provider of telemedicine or telemedicine services.

THE SERVICES DO NOT INCLUDE THE PROVISION OF HEALTH CARE SERVICES, MENTAL HEALTH SERVICES OR SOCIAL OR PSYCHOTHERAPY SERVICES, OR ANY OTHER PROFESSIONAL SERVICES BY GREENSPACE. Greenspace is only a technology service provider that facilitates the Services through the Greenspace platform.

TREATMENT PROVIDERS ARE NOT THE EMPLOYEES OR AGENTS OF GREENSPACE AND ARE NOT CREDENTIALED BY GREENSPACE. GREENSPACE DOES NOT HAVE ANY OVERSIGHT OF THE CARE PROVIDED TO YOU BY PROVDERS. Each Treatment Provider is an independent practitioner who is solely responsible for any health care services or social or psychotherapy services provided to you, and is also solely responsible for obtaining your informed consent, where required, to any medical treatment, including without limitation, your consent to use the Services, to the extent such consent is required by applicable state legislation.

5. Applicability of These Terms of Use

Your access to and use of the Platform and the Services is conditioned on your compliance with these Terms of Use. By becoming a registered user and/or accessing and/or using the Platform and Services, you agree to be bound by these Terms of Use and all applicable laws and regulations governing the Services. If you do not agree with these Terms of Use, you are not authorized to access the Platform or use the Services for any purpose. Additional terms and conditions applicable to specific areas of the Platform, together with the Terms of Use, govern your use of those areas. If you do not agree with any of these additional terms and conditions, you are not authorized to access or use those areas of the Platform.

6. Medical Advice

While the Services may provide access to certain general medical information, the Services cannot and are not intended to provide medical advice. We advise you to always seek the advice of a physician or other regulated health professional with any questions regarding your personal health or medical conditions. Never disregard, avoid, or delay in obtaining medical advice from your physician or other regulated health professional because of something you have read on the Platform. If you have or suspect that you have a medical problem or condition, please contact a physician or other regulated health professional immediately.

THE CONTENT ON THE PLATFORM IS NOT AND SHOULD NOT BE CONSIDERED MEDICAL ADVICE OR A SUBSTITUTE FOR INDIVIDUAL MEDICAL ADVICE, DIAGNOSIS, OR TREATMENT. YOU SHOULD ALWAYS TALK TO YOUR PHYSICIAN OR OTHER REGULATED HEALTH PROFESSIONAL FOR DIAGNOSIS AND TREATMENT, INCLUDING INFORMATION REGARDING WHICH DRUGS OR TREATMENT MAY BE APPROPRIATE FOR YOU. NONE OF THE INFORMATION ON THE WEBSITE REPRESENTS OR WARRANTS THAT ANY PARTICULAR DRUG OR TREATMENT IS SAFE, APPROPRIATE, OR EFFECTIVE FOR YOU.

7. Eligibility Requirements

Access to certain portions of the Platform, Services and content is restricted to users registered on the Platform.

There is no guarantee that you will be accepted as a registered user. Even if you are accepted as a registered user and have a pre-existing connection with a registered Treatment Provider, your Treatment Provider may determine that use of the Services is not appropriate for some or all of your treatment needs, and accordingly may elect not to facilitate your use of the Services.

8. Registration and Passwords

Patients can obtain access and use our Services in a number of ways once a file is created by the Patient or for the Patient by an Administrator or Treatment Provider (whether directly on the Platform, through an integration or the browser extension): (i) offline where your participation is directly facilitated by the Treatment Provider or Administrator; (ii) by invitation sent to you via an email and/or text message with a request to complete personalized assessments; or (iii) by creating a Patient user account to allow you to complete personalized assessments and view assessment results (an “Account”). To use the Services or access the Platform, you must be of legal age to form a binding contract. If you are not of legal age to form a binding contract, you may not register to use our Services.

Upon creation of an Account, you will choose a username and password. You alone are responsible for keeping that password and username confidential, and for any and all activity that occurs on the Platform under such password or username. You agree to immediately notify Greenspace of any unauthorized use of your Account or any other breach of security.

We reserve the right to deny your access to the Services or any part thereof, in order to maintain or restore security or performance to the Platform or any other Greenspace sites and systems. We may also do so if we reasonably believe you are in breach of these Terms of Use or your Account has been or may be being used or may be used by an unauthorized person(s).

9. Patient Profile

Your Patient profile will be established and maintained for you as a registered user of the Platform to enter, store, and access your personal information, including your personal health information (“Personal Information”) online, and for your Treatment Providers to communicate with you about your care. All of the Personal Information contained in your Patient profile will be maintained in accordance with the Terms of Use and Greenspace’s Privacy Policy (Authorized Users).

10. Privacy and Security of Information

By consenting to receive the Services using the Platform, you consent to the inherent material risks associated with the electronic uploading, transmission and storage of your Personal Information. By providing or uploading any of your Personal Information to the Platform, you are consenting to the collection, use and disclosure of your Personal Information for the purposes of providing the Services to you and for consistent purposes. Although Greenspace uses advanced encryption technology and other security protocols to protect your Personal Information, you acknowledge by using the Platform that there are inherent risks to any technology however remote that could cause security protocols to fail or be breached, which could result in the unauthorized collection, use or disclosure of your Personal Information. Greenspace will notify you to the extent required by law of any security protocol failure or breach that has resulted in in the unauthorized collection, use or disclosure of your Personal Information.

By consenting to receive the Services using the Greenspace Platform, you consent to receive assessments by email or sms, as selected by you. You should consider that email and sms are not secure means of communication. There is some risk that Personal Information contained in an email or sms may be disclosed to, or intercepted by, unauthorized third parties. Greenspace cannot ensure the security or confidentiality of messages sent by email or sms.

11. Responsibility for Your Care

Your medical care and your mental health care are solely the responsibility of you and your Treatment Provider(s).

Under the Services, mental health care services or social or psychotherapy services are provided exclusively by Treatment Providers. Greenspace provides Treatment Providers a license to use our intellectual property rights, including our patent pending inventions, trade secrets, copyrights, trademarks, service marks, trade dress and proprietary and confidential information and access to the Platform. However, exclusive control and responsibility for the delivery of mental health care services or social or psychotherapy services is reserved to Treatment Providers.

12. Verification of Treatment Providers

Greenspace does not conduct credential checks or other verifications of Treatment Providers and the information they have provided to Greenspace. Greenspace is not responsible for credentialing Treatment Providers, makes no representation regarding the accuracy of Treatment Providers’ credentials, and expressly disclaims any liability for fraudulent credentials or claims by Treatment Providers.

13. Privacy

When you use the Platform, Greenspace will collect certain Personal Information from you as set forth in more detail in our Privacy Policy (Authorized Users), which is hereby incorporated by reference. By registering on the Platform, you agree that Greenspace may collect, use, and disclose your Personal Information as set forth in our Privacy Policy (Authorized Users). Greenspace will process such Personal Information only on your behalf to deliver the Services and provide the Platform in accordance with applicable Privacy Laws, its Privacy Policy (Authorized Users) (incorporated herein by reference), the Terms of Use, or your other documented instructions, whether in written or electronic form. Greenspace will not disclose or transfer Personal Information to, or allow access to Personal Information (each, a “Disclosure”) by any third party (not including affiliates or subcontractors of Greenspace) without your express prior written consent, unless such Disclosure is required by applicable law. However, except in cases of gross negligence or willful misconduct, Greenspace will not be liable for any unauthorized disclosure of Personal Information despite the implementation of reasonable administrative, technical, and physical safeguards.

14. Conduct

As a condition of your continued access to and use of the Platform and the Services, you agree to abide by all applicable federal, state, and other laws and regulations and the “Code of Conduct” set forth in the Website Terms of Use. Specifically, in addition, without limiting the foregoing, you agree not to:

upload, post, email or otherwise transmit any Content (as defined in the next section below) to which you do not have the lawful right to copy, transmit and display (including any Content that would violate any confidentiality or fiduciary obligations that you might have with respect to the Content);
use the Services to collect or store personal data about other users without their express permission;
knowingly include or use any false or inaccurate information in any profile;
circumvent, disable, or otherwise interfere with security-related features of the Services or features that prevent or restrict use or copying of any Content;
attempt to probe, scan or test the vulnerability of any Greenspace system or network or breach or impair or circumvent any security or authentication measures protecting the Services;
attempt to decipher, decompile, disassemble, reverse engineer, or otherwise attempt to discover or determine the source code of any software or any proprietary algorithm used to provide the Services;
use the Services in any way that competes with Greenspace, including, without limitation, misrepresenting one’s identity or posing as a current or prospective patient in order to solicit or recruit Treatment Providers, directly or indirectly; or
encourage or instruct any other person or entity to do any of the foregoing.

15. Intellectual Property Rights

We or our third party service providers retain all right, title and interest in and to the Platform and all content that you see or otherwise experience on the Platform (“Content”), including all copyrights, patents, trade secrets, trade-marks and other intellectual property rights. We reserve all rights not expressly granted in these Terms of Use. These Terms of Use do not grant or imply any rights to any of our Services or Content, including our trade-marks, trade names and logo designs, or those of our third party service providers. You may not use any of our Content, including names, trade-marks, logo designs or copyrights, in any manner without our prior written consent. All copies and reproductions of our Content that you make must retain all copyright and other notices that are on the Platform or any of our social media sites.

16. Your License to Use the Services

When you use the Platform and our Services you may access intellectual property rights that we or our licensors own or license. Subject to your compliance with the terms and conditions of these Terms of Use, Greenspace grants you a limited, non-exclusive, non-transferable and revocable license, without the right to sublicense, to access and use the Services and to download and print any Content provided by Greenspace solely for your personal and non-commercial purposes. You may not use, copy, adapt, modify, prepare derivative works based upon, distribute, license, sell, transfer, publicly display, publicly perform, transmit, stream, broadcast or otherwise exploit the Services or Content, except as expressly permitted in these Terms of Use, without Greenspace’s express prior written consent. No licenses or rights are granted to you by implication or otherwise under any intellectual property rights owned or controlled by Greenspace or its licensors, except for the licenses and rights expressly granted in these Terms of Use.

17. Warranty

Except as specifically set out in these Terms of Use, the Platform and Services, and all materials, information, products and services included therein, are provided “AS IS” and “AS AVAILABLE” and Greenspace expressly disclaims all warranties of any kind, express, implied, or statutory, including without limitation all implied warranties of title, merchantability, fitness for a particular purpose, non-infringement, and all warranties arising from course of dealing or performance, usage, and trade practice. You acknowledge that you are solely responsible for use of the Platform and Services. Greenspace makes no warranty of any kind that the, Services, Platform, Content or results of the use thereof, will meet your or any other person's requirements, operate without interruption, achieve any intended result, be compatible or work with any software, system, or other services, or be secure, accurate, complete, free of harmful code, or error free. Greenspace make no warranty that the content accessed by you on the Platform or using the Services satisfies the laws and regulations requiring the disclosure of information for prescription drugs.

In addition, Greenspace and its licensors and affiliates disclaim any warranties regarding accuracy, reliability, timeliness and performance of the Services, and the Services may experience service interruptions. No advice or information provided to you by Greenspace will create any warranty that is not expressly stated in these Terms of Use.

Greenspace makes no representations concerning, and does not guarantee, the accuracy of the Services, including, but not limited to, any information provided through the Services or their applicability to your individual circumstances. Greenspace’s services and website content are developed for use in the United States and Greenspace and its licensors and affiliates make no representation or warranty concerning the services or website content when they are used in any other country.

The laws of certain jurisdictions, including Quebec, do not allow the exclusion or limitation of legal warranties, liability or certain damages or limitations of representations made concerning goods or services. If these laws apply to you, some or all of the exclusions or limitations in these Terms of Use may not apply to you.

18. Indemnification

You agree to indemnify and hold harmless Greenspace, its affiliates, members, directors, officers, employees, agents, and licensors from and against any and all losses, expenses, damages, claims, fines, penalties, costs and liabilities (including reasonable legal and accounting fees), resulting from your (or anyone acting under your password or username) use of the Platform, connection thereto, or any alleged violation by you of these Terms of Use, including, without limitation, the Code of Conduct (as set out in the Website Terms of Use).

You also agree to indemnify and hold harmless Greenspace, its affiliates, members, directors, officers, employees, agents, sponsors, and licensors for any injury, including but not limited to bodily harm or death, to you or any third party that may result from the use of or reliance on any Content.

19. Limitation of Liability

IN NO EVENT SHALL GREENSPACE OR GREENSPACE’S LICENSORS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL DAMAGES OR LOST PROFITS THAT RESULT FROM OR IN CONNECTION WITH THE USE OF, OR THE INABILITY TO USE, THE WEBSITE OR ANY CONTENT, OR SERVICES OBTAINED THROUGH THE WEBSITE, EVEN IF GREENSPACE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES IN ADVANCE. IF YOU ARE DISSATISFIED WITH THE WEBSITE, THE CONTENT, THE SERVICES OR THE TERMS OF USE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE WEBSITE.

NOTHING HEREIN SHALL LIMIT THE POTENTIAL PROFESSIONAL LIABILITY OF THE TREATMENT PROVIDERS OR OTHER LICENSED HEALTHCARE PROFESSIONALS ARISING FROM OR RELATED TO MEDICAL OR MENTAL HEALTH ADVICE, DIAGNOSIS, OR TREATMENT THEY PROVIDE TO YOU, EXCEPT AS PROVIDED UNDER APPLICABLE STATE LAWS. IN MANY JURISDICTIONS, TREATMENT PROVIDERS ARE REQUIRED TO REPORT CONFIDENTIAL INFORMATION IF THEY HAVE REASON TO BELIEVE THAT A PATIENT IS LIKELY TO HARM OTHERS OR HIMSELF/HERSELF. IN NO EVENT SHALL GREENSPACE BE LIABLE FOR THE DISCLOSURE OF YOUR CONFIDENTIAL INFORMATION BY A TREATMENT PROVIDER FROM WHOM YOU RECEIVE MENTAL HEALTH SERVICES OR SOCIAL OR PSYCHOTHERAPY SERVICES. GREENSPACE IS NOT LIABLE TO ANY PERSON OR USER FOR ANY HARM CAUSED BY THE NEGLIGENCE OR MISCONDUCT OF A TREATMENT PROVIDER PROVIDING MENTAL HEALTH SERVICES. IN NO EVENT WILL THE CUMULATIVE LIABILITY OF GREENSPACE OR GREENSPACE’S LICENSORS OR AFFILIATES TO YOU, WHETHER IN CONTRACT, TORT, OR OTHERWISE, EXCEED $1,000.

If your non-identifiable data are used for research purposes, then the limitation of liability and indemnity clauses contained within the Terms of Use are waived with respect to any harms suffered or liabilities incurred as a result of any research activities.

20. Errors and Inaccuracies.

The information on the Platform may contain typographical errors or other errors or inaccuracies, and may not be complete or current. Greenspace reserves the right to correct any errors, inaccuracies, or omissions and to change or update information at any time without prior notice to you. Greenspace will not, however, guarantee that any such errors, inaccuracies, or omissions will be corrected. Greenspace reserves the right to refuse to fill any orders or provide Services that are based on inaccurate or erroneous information on the Platform, including, without limitation, incorrect or out-of-date information regarding pricing, payment terms, or for any other lawful reason.

21. Changes and Interruptions in Service

Greenspace reserves the right at any time and from time to time to modify or discontinue, temporarily or permanently, the Platform (or any part thereof) with or without notice. Further, Greenspace reserves the right to change these Terms of Use at any time and to notify you by posting an updated version of the Terms of Use on this Platform. You are responsible for regularly reviewing the Terms of Use, including, without limitation, by checking the date of “Last Update” at the bottom of this document. Continued use of the Platform after any such changes shall constitute your consent to be bound by such changes, with continued provision of the use of the Platform constituting consideration from Greenspace to you for so being bound. Your only right with respect to any dissatisfaction with (i) these Terms of Use, (ii) any policy or practice of ours in operating the Platform, or (iii) any content available through the Platform, is to stop using the Platform.

22. Termination.

You may terminate your Account or use of the Services at any time and for any reason by providing written notice to Greenspace. Upon any termination by you, your Account will no longer be accessible. Any cancellation request will be handled within 30 days of receipt of such a request by Greenspace.

We may suspend or terminate your right to use our Services or the Platform at any time, in the event that you breach these Terms of Use, for any reason, or for no reason at all, in our sole discretion, and without prior notice to you. After such termination, Greenspace will have no further obligation to provide the Services, except to the extent we are obligated to provide you access to your health records or Treatment Providers are required to provide you with continuing care under their applicable legal, ethical and professional obligations to you.

Upon termination of your right to use our Services or the Platform or our termination of the Services or Platform, all licenses and other rights granted to you by these Terms of Use will immediately terminate.

Despite anything to the contrary, all of your covenants, agreements, representations and warranties made in these Terms of Use will survive the termination, suspension or cancellation of your access to the Platform and remain in full force and effect.

23. Area of Service

Unless otherwise agreed by Greenspace, the Services described in these Terms of Use are solely offered within the United States.

24. Governing Law

The construction, interpretation and performance of these Terms of Use and all transactions under this Agreement shall be governed and enforced pursuant to the laws of the State of New York, without giving effect to its conflicts of laws provisions, except to the extent New York law is pre-empted by any provision of federal law, including HIPAA. The Parties agree that all disputes arising out of or relating to this Agreement will be subject to mandatory binding arbitration under the rules of Judicial Administration and Arbitration Services (“JAMS”) in effect at the time of submission, as modified by this section. The arbitration will be heard and determined by a single arbitrator selected by mutual agreement of the Parties, or, failing agreement within thirty (30) days following the date of receipt by the respondent of the claim, by JAMS. Such arbitration will take place in New York County, New York. The arbitration award so given will be a final and binding determination of the dispute, and will be fully enforceable in any court of competent jurisdiction. Except in a proceeding to enforce the results of the arbitration or as otherwise required by law, neither Party nor any arbitrator may disclose the existence, content or results of any arbitration hereunder without the prior written agreement of both Parties

25. Entire Agreement

These Terms of Use and any and all other legal notices or statements posted on the Platform constitute the entire agreement between you and Greenspace with respect to the use of the Platform and Services.

26. Notice

Notices to you may be made via email, or in cases of changes to these Terms of Use or to the Services offered by the Platform, by posting notices or links to such notices on the Platform. Your continued use of the Platform after notice of any changes constitutes acceptance of the updated Terms of Use.

27. Language

You agree that it is the express wish of the parties that this agreement and all related documents be drawn up in English.

If you have any questions or comments regarding these Terms of Use please contact us at support@greenspacehealth.com.

Last Update: July 22, 2025

Greenspace Mental Health Ltd. (“Greenspace”, “we” or “our”) provides a digital platform that facilitates: (i) the measurement of patient progress and outcomes; (ii) the display of measurement information to patients and their health care provider(s); and (iii) other functions, tools and resources for the purpose of supporting the delivery of mental health care services (collectively, the “Services”). We know that the users of our Services are entrusting us with personal and sensitive information and the privacy of our users is extremely important to us. We are committed to protecting privacy and safeguarding personal information.

Table of Contents

Plain Language Summary of Our Privacy Practices
Scope of this Privacy Policy
Who Has Access to Our Services
Definitions
How We Collect and Use Your Personal Information
How We Use Cookies and Other Similar Tracking Technologies
How We Use Third Party Analytics Tool
How We Use Anonymized Information
How We Use De-Identified Information
How We Use Artificial Intelligence and Machine Learning
How We Share or Disclose Your Personal Information
How We Safeguard and Retain Your Personal Information
Where We Store and Process Your Personal Information
Your Privacy Rights
Third Party Links
Changes to this Privacy Policy
Contact Us

1. Plain Language Summary of Our Privacy Practices

While this summary is not exhaustive, here are some of the key provisions in this Privacy Policy that you should be aware of:

We are a service provider to our Customer: In providing our Services, Greenspace acts as a service provider or business associate to healthcare organizations or individual therapists, who are our Customers (as defined below under section 3 (Who Has Access to Our Services) of this Privacy Policy). This means that as a matter of law, Greenspace collects, uses or discloses personal information in accordance with our agreement with our Customer. This Privacy Policy is intended to provide you with information about those practices.
You must be an Authorized User of our Customer: In order to use the Services, you must be an Authorized User (Administrator, Treatment Provider or Patient, each defined below under section 3 (Who Has Access to Our Services) of this Privacy Policy) of our Customer.
We only collect and use what is needed: We only collect and use personal information that is required to provide our Services on behalf of our Customer. This personal information is provided: (i) directly by you; (ii) indirectly by your Treatment Provider or an Administrator; or (iii) indirectly by your parent, legal guardian or substitute decision-maker if you are a minor Patient.
We do not trade, rent or sell personal information: Under no circumstances will Greenspace trade, rent or sell your personal information.
We do not disclose your personal information, except as described in this Privacy Policy: We do not disclose or otherwise transfer your personal information without your consent, except as otherwise set out in this Privacy Policy.
We safeguard your information: We have implemented reasonable administrative, technical and physical measures to safeguard your personal information that are appropriate to the sensitivity of the information. All protected health information is stored in the United States.
Contact us: You can contact us at any time to exercise your privacy rights, as described below under section 16 (Your Privacy Rights) of this Privacy Policy. Since we are processing your personal information in our capacity as a service provider, certain requests will be forwarded to our Customer for response.

Please read this Privacy Policy carefully. If you have any questions or concerns regarding this Privacy Policy, please contact us at privacy@greenspacehealth.com.

2. Scope of this Privacy Policy

This Privacy Policy describes how we collect, use and disclose your personal information, (which, when used in this Privacy Policy includes your protected health information) when you use our Services in your capacity as an Authorized User (as defined below under section 3 (Who Has Access to Our Services) of this Privacy Policy). It applies whether such information is collected electronically at https://app.greenspacehealth.com or any website or other platform on which this Privacy Policy appears (the “Platform”), in person, over the telephone, in writing, via email messages or text messages. We may provide additional “just-in-time” disclosures or additional information about our data collection, use and disclosure practices. These notices may supplement or clarify our Privacy Policy or may provide you with additional choices about how we will process your personal information. This Privacy Policy does not apply to information which we may receive from you through your access and/or use of the general Greenspace website at https://greenspacehealth.com/ (the “Website”). If you are visiting the Website, please refer to the Website Privacy Policy to learn more about Greenspace’s privacy practices in relation to the Website.

Please note that privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. While the Platform can be accessed from different countries around the world, the Platform and our Services are only intended for users in the United States. As such, this Privacy Policy is designed in accordance with applicable privacy laws in the United States. Please note that unless stated otherwise, any reference to personal information in this Privacy Policy includes protected health information.

3. Who Has Access to Our Services

In providing our Services, we act as a service provider or business associate to our customers, such as healthcare clinics or individual therapists (“Customers”), who may be classified as covered entities under applicable privacy statutes.

As a service provider, we supply our Services for the purpose of enabling our Customers to use our platform to collect, use, disclose, modify, retain, dispose or otherwise process personal information. Our collection, use, disclosure and other processing of your personal information is subject to our agreement with our Customer, which is described in this Privacy Policy.

You are entitled to use our Services if you fall within one of the following categories of authorized users of our Customer:

supervisors, managers or administrators of the Customer that do not provide direct clinical treatment for Patients (each, an “Administrator”);
treatment providers, therapists or clinicians of the Customer, including, but not limited to, psychiatrists, psychologists, social workers, occupational therapists, and psychotherapists (each a “Treatment Provider”); and
individuals with whom the Customer or its Treatment Provider(s) have a clinical health care relationship for whom a file has been created on the Platform, whether such file has been opened by: (i) that individual; (ii) the Treatment Provider or Administrator for that individual; or (iii) a parent, legal guardian or substitute decision maker of that individual for that individual or themselves) (each, a “Patient” and collectively, with Administrators and Treatment Providers, the “Authorized Users”).

Patients receiving services from a Treatment Provider will receive a Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) Notice of Privacy Practices (“NPP”) from their Treatment Provider or Administrator, with additional information regarding their Treatment Provider or Administrator’s access, use and disclosure of their personal information.

4. Definitions

For the purpose of this Privacy Policy:

“Personal information” means any information that could reasonably be used on its own, or in combination with other information, to identify an individual or as otherwise defined under applicable privacy statutes. Personal information includes protected health information.
“Protected health information” means personal information that is collected by your therapist or clinic and relates to your past, present, or future physical or mental health or condition; the provision of health care; or your past, present, or future payment for the provision of health care.
“De-Identified Information” is information that has been de-identified to remove all direct personal identifiers but retaining some indirect identifiers such as a unique system-generated profile identification.
“Anonymized Information” is information that has been aggregated and anonymized to permanently remove all direct and indirect personal identifiers in accordance with applicable law, our internal policies and industry best practices in a manner that no longer allows a person to reasonably be identified, directly or indirectly.

5. How We Collect and Use Your Personal Information

We only collect personal information that is necessary to operate our Platform and Services. Below is a summary of the ways we collect and use your personal information:

Registering for Our Services:
- Patients can obtain access and use our Services in a number of ways once a file is created by the Patient or for the Patient by an Administrator or Treatment Provider (whether directly on the Platform, through an integration or the browser extension): (i) offline, where your participation is directly facilitated by the Treatment Provider or Administrator; (ii) by invitation, sent to you via an email and/or text message with a request to complete personalized assessments; (iii) by creating a Patient user account, to allow you to complete personalized assessments and view assessment results (a “Patient Account”); or (iv) via a participant account created by a parent, legal guardian or substitute decision-maker if you are a minor.
- The information required to create a Patient Account includes: first and last name, email address, phone number and password, as well as additional personal information set by our Customer.
Delivering Assessments: In order to remotely deliver assessments to Patients:
- For Patients with a Patient Account, we use the Patient's name, email address and/or telephone number, as set by the Patient to send a link to the personalized assessment(s).
- For Patients without a Patient Account, we use the Patient's name, email address and/or telephone number, as set by their Treatment Provider or Administrator, to send a link to the personalized assessment(s).
Completing Personalized Assessments: We collect personal information from Patients such as responses to assessment questions and quantitative assessment scores when Patients respond to a personalized assessment delivered by the Platform. We use this information to provide Patients, their Treatment Provider(s) and any appropriately permissioned Administrators, with a presentation of assessment results and progress.
Assessing Results of Personalized Assessments: We use personal information collected from Patients’ responses to personalized assessments to enable Treatment Providers and Administrators to evaluate results and analyze Patients’ progress. This information is provided to the Patient’s Treatment Provider(s) and any appropriately permissioned Administrators to enhance their delivery of health services to their Patients, inform their care decisions and provide metrics about their practice in accordance with the Customer agreement.
Improving Our Platform and Services: We use De-Identified Information for internal purposes only to improve our Platform and Services, for example to analyze the usage of our Platform and Services to help inform our product and/or user experience decisions, and train data for machine learning development. We only use data for artificial intelligence and machine learning with permission as further described in section 11 (How We Use Artificial Intelligence and Machine Learning) below.
Providing Technical Support: We may use the personal information of an Authorized User in order to provide them the necessary technical support when using our Services.
Interacting With You: When any Authorized User contacts us with a comment, question or complaint, you may be asked for personal information that identifies you such as your name, address, email address and a telephone number along with any additional information we may need to promptly answer your question or respond to your comment or complaint. We use this personal information to respond to your inquiry and improve our Services’ offerings.
Information Received as a Business Associate: Some Treatment Providers, (such as psychiatrists, psychologists, clinical social workers, registered psychotherapists, professional counselors and marriage and family therapists) may be subject to laws and regulations governing the use and disclosure of the health information they create or receive, including the HIPAA and the regulations adopted thereunder. Greenspace will only use or disclose such information as permitted by the controlling business associate agreement or as otherwise permitted by law. Greenspace limits access to protected health information in accordance with HIPAA. Greenspace’s workforce members are trained on the privacy and security requirements applicable to protected health information, and Greenspace’s “business associates” are required, pursuant to the terms of their agreements with us, to implement required safeguards.
Sharing our Newsletter and Other Updates: If you are an Administrator or Treatment Provider, we may use your name and email address, in accordance with applicable law, to provide you with copies of our newsletter or other updates about our products and Services that we believe may be of interest to you. You can unsubscribe at any time by clicking on the unsubscribe link included in every email or by contacting us as set out below at section 17 (Contact Us) of this Privacy Policy. We do not send newsletters or Services updates to Patients.

6. How We Use Cookies and Other Similar Tracking Technologies

Greenspace uses cookies, log files, web beacons and similar tracking technologies to remember user preferences and collect information about visitors to the Platform. Some cookies are required for the operation of the Platform and are not optional.

Cookies are small text files that our Platform can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our Platform where you are prompted to log in or that are customizable. If you have registered with our Platform, these cookies (i) may let us know who you are in order to authenticate and confirm your authorization to use the Platform and our Services, (ii) may be necessary to access your account information (stored on our servers) in order to deliver products and personalized services, and (iii) will provide us and our service providers with information that we will use to personalize our Platform and Services in accordance with your preferences.

You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Platform, you may not be able to take advantage of all of the features of our Platform.

Log files are records of all visits to the Platform, which are automatically generated. These files make a record of each visit to the Platform and log a number of details, that may include: the user’s operating system; IP address; the date, time and duration of the visit; the pages and documents accessed; and the previous site accessed by the user (such as, the search engine that referred the user to the Platform).

We may also use pixel tags, web beacons, clear GIFs or similar technologies in connection with some of our Platform pages and HTML-formatted email messages to track the actions of users and email recipients, measure the success of our marketing campaigns, and compile statistics about Platform usage and email response rates. These technologies usually work in conjunction with cookies.

7. How We Use Third Party Analytics Tools

Greenspace uses Mixpanel as an analytics tool (“Mixpanel”) to provide statistics about visitors to the Platform. For more information about Mixpanel, please follow the provided hyperlink. Mixpanel uses cookies and other identifiers to collect certain information such as user device or browser type, and user activity on our Platform such as click rates and bounce rates to measure and report statistics about user interactions on the Platform. Mixpanel is used for analysis, to create reports and to identify Platform trends.

Please refer to section 11 (How We Share or Disclose Your Personal Information) of this Privacy Policy for more detail on our analytics service provider (Mixpanel).

8. How We Use Anonymized Information

We fully anonymize and aggregate data based on responses to assessments, feedback on our Services, and the frequency and way users use our Services (a) to publish fully anonymized and aggregated data, metrics or insights regarding our Services on our Platform and through various communication channels; and (b) to share fully anonymized and aggregated data, metrics or insights with current and prospective Customers, to better understand assessment outcomes and benchmark our Services. The data we may publish or share using Anonymized Information includes high level aggregated statistics such as the number and types of assessments completed on our Platform, or the number of Patients that have used our Platform.

None of this Anonymized Information, directly or indirectly, identifies or can be linked back to any Patients or other Authorized Users or Customers.

9. How We Use De-Identified Information

In accordance with our Customer agreement, we may use automated systems to analyze De-Identified Information of Authorized Users collected via user input, cookies, analytics tools and other technologies (as described above) in order to: (i) improve the Platform and Services; (ii) personalize Authorized User’s experience; (iii) automate certain aspects of the Platform; and (vi) protect the safety and security of the Platform. Notwithstanding the foregoing, De-Identified Information may also be used in accordance with section 10 (How We Use Artificial Intelligence and Machine Learning) of this Privacy Policy.

10. How We Use Data for Artificial Intelligence and Machine Learning

In accordance with our Customer agreement (and provided such Authorized Users have not opted out of such features), we may use automated systems to analyze De-Identified Information of Authorized Users collected via user input, cookies, analytics tools and other technologies (as described above) in order to: (i) use such data for machine learning training; and (ii) provide Authorized Users with certain artificial intelligence and machine learning features, such as predictive analytics.

11. How We Share or Disclose Your Personal Information

Under no circumstances will Greenspace trade, rent or sell your personal information. We will not disclose your personal information, without your consent, except as otherwise set out in this Privacy Policy.

Authorized Service Providers: In order to provide our Services, we have arrangements with certain necessary service providers that are subject to contractual agreements that include appropriate privacy standards in accordance with applicable privacy laws. We may transfer (or otherwise make available) your personal information to such affiliates and other third party service providers for the purpose of enabling such parties to provide certain services on our behalf that are directly related to the provision of our Services to you. To the extent that any personal information is provided to our affiliates and service providers, we require that they be bound by legally enforceable written obligations consistent with this Privacy Policy and that they are given only the information they need and solely for the purpose of performing their designated functions. Our affiliates and service providers are not authorized to use or disclose personal information for their own marketing or other purposes. Our authorized affiliates and service providers with whom we share personal information fall into the following categories:
- service providers that authorize and process payments on our behalf;
- service providers that host our Platform, enable certain of its features, deliver assessments, and manage and analyze data;
- service providers that send email and other communications;
- service providers that are used to monitor our systems for reliability, security or compliance; and
- service providers that are used to enable integration with other systems used by our Customers, including clinical systems, administrative systems and identity providers.
Analytics Service Provider (Mixpanel). We do not share personal information with Mixpanel except for IP addresses, which are sometimes required for the operation of the Mixpanel analytics service. Mixpanel either does not store or anonymizes IP addresses, and does not use them for any purpose besides providing its analytics service. Personal health information is not shared with Mixpanel at any time.
Business Transactions: Personal information (but not protected health information) may be disclosed in connection with a prospective or completed business transaction, as permitted in accordance with applicable privacy laws. In such cases, your personal information may only be used or disclosed by the recipient in order to assess and complete the transaction. After the transaction is closed, your personal information may only be used or disclosed by the recipient in accordance with this Privacy Policy, any existing agreements with the Customer, or as otherwise permitted by applicable privacy laws, unless subsequent consent is obtained from you for an additional purpose.
Legal, Compliance and Loss Prevention: Greenspace, our affiliates and our service providers may be required to provide your personal information in response to a lawful request such as: (i) a court order, search warrant or subpoena; (ii) for the purposes of investigating a breach of an agreement, contravention of law, or actual or suspected harm to persons or loss of property; or (iv) as otherwise required or permitted by applicable law. Under no circumstances, will Greenspace disclose your personal information (including any protected health information) unless such disclosure is permitted or required by applicable laws.

12. How We Safeguard and Retain Your Personal Information

We have implemented reasonable physical, organizational and technological measures appropriate to the sensitivity of the personal information in an effort to safeguard the personal information in our custody and control or that we process on behalf of our Customers to protect against theft, loss and unauthorized access, use, modification and disclosure. Such measures, which may necessarily evolve over time as the availability and effectiveness of methods vary, include the following:

restricting access to personal information to employees, contractors and third-party service providers who require access to fulfill their job or services, are bound by confidentiality and/or non-disclosure requirements and who are required to abide by this Privacy Policy and Greenspace’s privacy and security policies;
restricting access to our systems, accounts and electronic databases or other electronic formats that may contain personal information through password protection and internal security policies; and
implementing technical security measures such as firewall technology, anti-malware screening and data encryption technology.

While Greenspace employs advanced data encryption technology when interfacing with our users, third party service providers and other partners, you should be aware that there is a residual risk in transmitting any data electronically. Despite our efforts, no security measure is perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. This risk is inherent in all Internet dealings.

You should exercise discretion when providing any personal information via email or text messages as such communications may not be encrypted. In particular, you should not include any protected health information or other sensitive information in your email or text messages sent to us.

If you suspect your personal information has been improperly accessed, used, or disclosed, please contact us immediately as set out under section 17 (Contact Us) of this Privacy Policy.

We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above, as provided in our Customer agreements, or to otherwise meet legal requirements. We securely dispose of or anonymize personal information of Authorized Users once it has served such purposes, in accordance with applicable law and our agreement with the Customer.

13. Where We Store and Process Your Personal Information

All protected health information is stored in the United States.

Other types of personal information may be stored or processed by Greenspace or our authorized service providers in a foreign jurisdiction outside of the United States. When this occurs, your personal information may be subject to the laws of such jurisdiction and accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction. You can obtain more information about our policies and practices with respect to the use of third-party service providers outside of the United States by contacting us as described below, under section 17 (Contact Us) of this Privacy Policy.

14. Your Privacy Rights

Under privacy laws, you have the right to access, update and correct inaccuracies in your personal information, subject to certain exceptions. Since Greenspace is acting as a service provider to clinics or healthcare professionals, we will forward requests for the exercise of user rights under privacy laws to our Customer, who will respond to you.

15. Third Party Links

The Platform may contain links to third party platforms. While we try to link only to platforms that share our high standards and respect for privacy, please understand that we are not responsible for the content of, or the privacy practices employed by, other platforms and this Privacy Policy does not apply to those platforms. We encourage you to review the privacy policies of each platform you visit.

16. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, products or services.

When we make changes to this Privacy Policy we will revise the “Last Update” date at the bottom of this page. You should check back here periodically to find out if any changes have been made to this Privacy Policy. If we make substantial changes we will, as appropriate, prominently post these changes to our Platform and/or notify registered users of our Services.

17. Contact Us

Please contact our Privacy Officer at privacy@greenspacehealth.com if:

you have any questions or comments about this Privacy Policy;
you wish to access, update or correct inaccuracies in your personal information;
you wish to withdraw your consent to our collection, use or disclosure of your personal information as described in this Privacy Policy; or
you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.

Since email communications are not always secure, please do not include protected health information or other confidential or sensitive information in your emails to us.

Last Update: July 22, 2025

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