Platform Privacy Policy

Last modified: April 22, 2025

‍

1. Introduction

Boulder Care, Inc. ("Boulder Care," "we," "our," or "us") respects your privacy, and we are committed to protecting it through our compliance with this policy. This Privacy Policy (our "Privacy Policy") describes the information we collect, how we collect, use, and disclose Personal Data (as defined below) about you when you visit the website www.boulder.care (our “Website”), install and use the Boulder Care application (our "Application") (collectively, our “Platform”), or communicate with us via email, text, and other electronic means. This Privacy Policy also describes our practices for collecting, using, maintaining, protecting, and disclosing that information and the choices you have regarding the information we collect, including how you can manage, update, or request that we delete your information.

This policy applies to information we collect:

• on or through our Platform;
• in email, text, and other electronic messages between you and Boulder Care via our Platform;
• when you talk to us by audio/video-chat or by telephone; and
• when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this Privacy Policy.

This Privacy Policy does not apply to information collected by us offline, by any third party, or through any other means, including through any application or content (including advertising) that may link to or be accessible from or on our Platform. 

Note, Boulder Care is not a medical group and does not provide medical services. Boulder Care contracts with a network of independent healthcare professionals (“Providers”) that provide psychological or medical services via the Boulder Care Application and online interfaces to their patients, and not through our Website. Any telemedicine consults obtained through our Application are provided by independent medical practitioners including Boulder Care Provider Group, P.A., a Florida professional medical services corporation ("Boulder Care Medical"), which is an independent medical group with a network of United States-based Providers. Boulder Care Medical (or your own medical provider if you do not use a Boulder Care Medical Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not Boulder Care. If you do not agree to be bound by this Privacy Policy or the Notice of Privacy Practices terms, you are not authorized to access or use our Platform, and you must promptly exit our Platform.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using our Platform, you agree to this Privacy Policy and (a) expressly consent to our collection, use, disclosure, and processing of your Personal Data in accordance with this Privacy Policy, and (b) expressly acknowledge that you have read and understood our Notice of Privacy Practices, which provides important information to you about how Boulder Care Medical may use and disclose health information about you. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Children Under the Age of 13

Providers may provide telemedicine consults to minors where permitted by, and in accordance with, applicable state laws regarding a minor's ability to consent to such care. However, our Platform is not intended for children under the age of 13 and children under the age of 13 are not permitted to use our Platform. We will remove any information about a child under the age of 13 if we become aware of it.

No one under age 13 may provide any information to or through the Platform. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on our Platform or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 14 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 13, please contact us at contact@boulder.care or call us at (503) 208-5061. 

3. Information We Collect About You and How We Collect It

Generally

We may collect the following types of information from and about users of our Platform (collectively, “Personal Data”):

• information by which you may be personally identified, such as name, postal address, billing address, e-mail address, home, work, and mobile telephone numbers, driver's license number (or other government identification number), date of birth, insurance information, images of you, video and audio of you, your medical and health history (including substance abuse information), debit or credit card information (for payment purposes only), racial and ethnic origin, religious beliefs, criminal history, and sexual orientation and gender identity;

• internet or other electronic network activity information, such as traffic data, logs, referring/exit pages, date and time of your visit to our Platform, location-identifying and logging, error information, clickstream data, and other communication data and the resources that you access and use through our Platform; information about your Internet connection, the equipment you use to access our Platform, and other usage details.

Boulder Care Medical may also collect protected health information (“PHI”) through your use of the Platform. PHI is individually identifiable information about you that relates to (a) your past, present, or future physical or mental health or condition, (b) the provision of healthcare to you, or (c) your past, present, or future payment for the provision of healthcare, which is created, received, transmitted, or maintained by us. This Privacy Policy describes how we protect your privacy as a visitor to or general user of the Platform. You have additional rights under federal and state law with respect to the access to, use, and disclosure of your PHI, and Boulder Care and Boulder Care Medical are committed to maintaining the privacy and integrity of your PHI. Your rights with respect to your PHI are explained further in our Notice of Privacy Practices, which provides important information to you about how we may use and disclose your PHI.

How Do We Collect Your Personal Data?

We collect most of this Personal Data directly from you. Additionally, we will collect information from you when you use our Platform. Specifically, we collect Personal Data:

• directly from you when you provide it to us;
• automatically as you navigate through our Platform. Information collected automatically may include location (with your consent through the Platform and your device), usage details, IP addresses, and information collected through cookies and other tracking technologies; and
• from third parties, for example, the Providers.

Information You Provide to Us

The information we collect on or through our Platform includes:

• information that you provide when using or filling out forms on the Platform. This includes information provided at the time of registering for the Platform, using our Provider consultation services, purchasing services, or requesting further services. We may also ask you for information when you report a problem with our Platform;
• records and copies of your correspondence (including email addresses), if you contact us; and
• details of transactions you carry out through our Platform and of the provision of our services. You may be required to provide insurance information before requesting services through our Platform.

You also may provide information to us and for Providers (hereinafter, “posted”) that are transmitted through our Website to us or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

• details of your visits to our Platform, such as location (with your consent through the Platform and your device), traffic data, logs, referring/exit pages, date and time of use of our Platform, error information, clickstream data, and other communication data and the resources that you access and use on the Platform; and
• information about your device and Internet connection, specifically your IP address, operating system, browser type, and Application version information.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Platform according to your individual interests;
• recognize you when you return to our Platform.

The technologies we use for this automatic data collection may include: 

• Cookies. We and our service providers may use cookies to receive and store certain types of information whenever you interact with our Platform through your computer or mobile device. A cookie is a small file placed on the hard drive of your computer or mobile device. On your computer, you may refuse to accept cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting, you may be unable to access certain parts of our Platform. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you use our Platform.
• Freshpaint. We use Freshpaint, a service that helps us analyze how visitors use our Platform while maintaining user privacy. We have a Business Associate Agreement (BAA) with Freshpaint, which enables us to share certain automatically collected information with third-party analytics providers, such as Google Analytics, in a manner that safeguards individual confidentiality. All data shared by Freshpaint with such third parties is de-identified, meaning it does not contain information that can be used to identify you. For more information on how Freshpaint handles data, please visit https://documentation.freshpaint.io/. 

4. How We Use Your Personal Data

We use Personal Data that we collect about you or that you provide us as follows:

• to present our Platform and its contents to you; 
• to operate, maintain, supervise, administer, and enhance our Platform, including monitoring and analyzing the effectiveness of content on the Platform, aggregate usage data, and other usage of the Platform and/or our services;
• with your consent through the Platform and your device, to confirm your geographical location to verify that our Providers are licensed to provide care to you, based on your location, and to enable you to join a patient visit through the Platform;
• to provide information and services to you, in a custom and user-friendly way;
• to process, fulfill, support, and administer transactions and service orders or purchases by you;
• to provide you with notices about your Boulder Care account;
• to communicate with you, including via email, phone, and/or text, and respond to your requests, such as to respond to your questions, contact you about changes to the services, and communicate about account-related matters; 
• to send you technical notices, security alerts, and other support and administrative messages, including notifications about changes to our Platform or any products or services we offer or provide;
• to carry out our legal and contractual obligations, and to enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to de-identify and aggregate information for analytics and reporting;
• to authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform;
• to manage our organization and its day-to-day operations; 
• for marketing and advertising purposes, including to market to you or offer you through email or direct mail, information and updates on products or services we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so);
• to enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• to maintain an accurate record of our users;
• to fulfill any other purpose for which you provide it;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

We may also use de-identified information, so that it cannot be reasonably used to identify any individual, to:

• market our services;
• improve our ability to care for you and others;
• improve our operational efficiency; 
• conduct data analytics and related assessments to understand and evaluate the use of our Platform; and
• any other purposes permitted by law.

You may permit the Application to send you push notifications. Push notifications may include alerts, sounds, and icon badges. Notifications can be configured in the settings for your device. Your Personal Data may be used to provide you with push notifications. Please refer to the user guide for your mobile device for more information on how to configure these notifications.

We may also use your information to contact you about surveys, promotional materials, or contests. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page. For more information, see Disclosure of Your Personal Data.

5. Disclosure of Your Personal Data

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, order fulfillment, marketing, analytics, and payment processing services, as well as professional services such as services provided by auditors, law firms, and accounting firms.

We may also disclose your Personal Data:

• for any other purpose disclosed by us when you provide the information, including all of what is expressed in How We Use Your Personal Data;
• to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
• to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes;
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Boulder Care, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; 
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our users are among the assets transferred; or
• with your consent, such as through the completion of an authorization or release of information (ROI) form.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

6. Choices About How We Use and Disclose Your Personal Data

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in “Disclosure Your Personal Data”. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Platform may then be inaccessible or not function properly
• Promotional Offers from Boulder Care. If you do not wish to have your email address used by Boulder Care and its service providers to promote Boulder Care products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or by emailing us support@boulder.care. This opt out does not apply to information provided to Boulder Care as a result of use of our services.
• Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites.

Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

7. Your Rights Regarding Your Information and Accessing and Correcting Your Personal Data

You may review and change your Personal Data by logging into our Website and visiting the “Contact” sections, or by messaging us through the Application.

You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

8. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Platform confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.

The safety and security of your information also depends on you. Where you have created an account and chosen a password for the use of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in your operating system or in the Platform.

9. Who May Use the Services?

Boulder Care operates subject to state and federal regulations, and the Platform and/or the services may not be available in your state. You represent that you are not a person barred from enrolling for or receiving the services under the laws of the United States or other applicable jurisdictions in which you may be located. Access to and use of the Platform and/or the services are limited exclusively to users located in states within the United States where the Platform and/or the services are available. The Platform and/or the services are not available to users located outside the United States. Accessing the Platform and/or obtaining the services from jurisdictions where such content is illegal, or where we do not offer the Platform and/or the services, is prohibited. To help Boulder Care ensure it is only providing services as legally permitted, Boulder Care will collect your location information, with your consent obtained through the Platform and your device.

10. Do Not Track Signals

Some devices and browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. These features are not yet uniform across browsers. At this time, our Platform does not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

11. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Platform. If we make material changes to how we treat our users' Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Platform. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically accessing and reviewing this Privacy Policy to check for any changes.

YOUR CONTINUED USE OF THE PLATFORM FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE TO SUCH CHANGES.

12. Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Website.

Boulder Care, Inc.

Attn: Legal

111 SW Naito St

Suite 200

Portland, OR 97204

Telephone: (866) 288-5885

Email: contact@boulder.care