Privacy Policy

Updated April 2024: Carefully read this Privacy Policy as it governs your access to and use of Path CCM, Inc.’s (“Path CCM,” “we,” “us,” and “our”) Platform. Your acceptance of, and compliance with, this Privacy Policy is a condition to your use of the following:

https://www.rula.com (our “Website”); and
The services (“Services”) made available through our Website.

The non-medical business support services and our Website are collectively referred to as our “Platform.”

Path CCM contracts with SUD Specialty Group – CA, Mental Health Specialty Group, P.A. and Mental Health Specialty Group NJ, PC (collectively, “Group”), which are independent medical groups with a network of United States based health care providers (each, a “Provider”) to provide online telehealth clinical consultations, services, and/or treatment.

This Privacy Policy describes how this Website may collect, use and disclose information from or about you, and explains how information may be collected. This Privacy Policy is incorporated in and is part of our Terms of Use. Any terms used in this Privacy Policy that are not defined have the same meaning as in our Terms of Use. By accessing and using our Website you affirm that you have read the Terms of Use and the Privacy Policy and that you understand, agree to, and acknowledge all the terms contained in both of them. If you do not agree to be bound to the Privacy Policy, you should stop using the Website.

Path CCM values and respects your privacy. This Privacy Policy applies to visitors to the Website, the Platform, including Providers who are individuals providing services to patients.

When you visit our Website or provide personal information to us through the Platform, we only use it as described in this policy.

Protected Health Information: For information on how Path CCM handles your Protected Health Information, please visit Rula’s Notice of Privacy Practices. We will only use and disclose your Protected Health Information in accordance with this Notice of Privacy Practices.

How We Collect and Use Personal Information

When you visit our Website, we may collect information about you that may personally identify you (i.e., your personal information such as name, mobile number, or email address) only when you voluntarily give it to us through the forms submission on our Website or when you initiate contact with us.

When you visit our Website, we may store or retrieve information from your browser, computer, or mobile device, mostly in the form of cookies in the form of small text files. This information might be about you, your preferences or your device, and is mostly used to remember your preferences and make the site work as you expect it to. The information does not usually directly identify you. You acknowledge and agree that we may use and store any such information about you in accordance with our Privacy Policy.

Information We Collect

Personally Identifiable Information: This includes but is not limited to, requesting an appointment online, chatting online with a Path CCM representative, or purchasing Services. The types of Personally Identifiable Information collected may include your name, address, phone number, birth date, race, veteran or military status, medical conditions, sexual orientation, marital status, billing and delivery information, email address, credit card, insurance information, or other financial account information.

Non-Personal Data: As you interact with our Website, we may also collect information about your browsing history or certain other information that is not Personally Identifiable Information through your use of and visits to the Platform and our use of a variety of technologies, including, but not limited to, cookies, tags, beacons, Internet Protocol (IP) address, and other tools. “Cookies” are pieces of code/text placed on your computer when you browse our Sites. Cookies may be placed by us or third party advertisers. “Tags” and web beacons refer to code scripts that are primarily used to track visitors’ activities on our website by web analytics software. The types of non-personal data collected on our Platform through the use of these, and other tools as Path CCM may add from time to time, may include: the search terms you used, new or returning user, browser information, computer type, operating system, internet service providers, Website usage, referring/exit pages, platform type, date/time stamp, number of clicks, ads viewed, etc. Additionally, cookies, tags and other tools placed by third parties may collect other information about you. Google Analytics and LinkedIn are third parties we use to analyze data on our Website. Those third parties will provide information about how and what information is collected and used. Third-party cookies and sites are not Path CCM’s responsibility.

Essential cookies will be stored on your device when you visit our site. You can’t turn these off. We are not using these cookies for any marketing or advertising purposes.

How to opt-out of cookies: You can refuse to accept these cookies and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. However, if you do not accept these cookies, you may experience some inconvenience in your use of the website and some online services. The site may not load or display properly. You also may not receive tailored messages from us that may be relevant to your interests and needs. To find out more about cookies, including how to see what cookies have been set and how to block and delete cookies, please visit http://www.aboutcookies.org/.

We may use a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this website. We use the information we get from Google Analytics only to improve this Website.

Google Analytics collects only the IP address assigned to you on the date you visit this website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this website by disabling cookies on your browser.

IP Address: Your IP Address is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the website, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating website usage levels, helping diagnose server problems, for compliance and security purposes and administering the Website.

Aggregated and De-identified Data: Aggregated and De-identified Data are data that we may create or compile from various sources, including, but not limited to, accounts and transactions. This information, which does not identify individual account holders, may be used for our business purposes, which may include offering products or services, research, or analyzing market trends, and other purposes consistent with applicable laws.

How We Collect Your Personal Information

You directly provide Path CCM with most of the Personal Information we collect. We collect personal information and process personal information when you, for example:

Register online or call or text our customer service center.
Voluntarily complete a customer survey or provide feedback on any of our message boards, apps, text messages, or via email.
Use or view our Website via your browser’s cookies.
Provide us information to schedule you an appointment with a Group provider.

How We Use Your Personal Information

We collect personal information in the normal course of business in order to serve you better, including as follows:

To communicate with you: to contact you or provide you with information that is related to the website.
To deliver services to you: to create your account and use the website, to complete an activity you specifically asked for, to manage your account, or provide with you with customer support.
To operate, maintain, supervise, administer, and enhance the website, including monitoring and analyzing the effectiveness of content on the Platform and aggregate usage data.
To provide you with a tailored and user-friendly experience as you navigate our website.
To gather information on users’ demographics, interests, and behavior based upon information provided during use of our website.
Anonymize and aggregate information for analytics and reporting.
To develop, test, improve, and demonstrate the Website.
In compliance with applicable law: to respond to law enforcement requests, court order or government regulations, and to comply with protecting patient and public health and safety.
Any other purpose with your consent.

We may also use personal information:

To respond to your inquiries and fulfill your requests;
To inform you about important information regarding the website or services which may interest you or changes to terms, conditions, and policies and/or other administrative information;
To deliver marketing communications that we believe may be of interest to you;
To personalize your experience on the website;
To verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your services, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of your personal information;
To allow you to participate in surveys and other forms of market research;
To send you emails regarding system downtime and/or changes to this Privacy Policy or the Terms of Use;
For business purposes, including data analysis, audits, developing and improving services, enhancing the website, identifying usage trends and determining the effectiveness of web pages; and
For risk control, for fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements.

How We Share Personal Information

We do not sell or rent your personal information to third parties. We only disclose your information with third parties in the following ways:

Affiliates: We may disclose your personal information with any of our affiliates and/or subsidiaries for the purposes of providing services to you.

Providers: We disclose your personal information with our service providers. These service providers have access to the personal information necessary to provide services to you and may not use it for purposes other than to provide services to you.

Compliance with applicable laws or with law enforcement: We may disclose your personal information in response to law enforcement requests, court orders or subpoenas, and other legal processes in compliance with applicable laws, regulations, and contractual obligations. We may disclose your information to law enforcement agencies or other governmental bodies if we suspect improper use of our Platform.

Business Operations: In the event of a sale, merger, or other business operation function we may transfer your personal information we have collected to relevant third parties involved in the business transaction or operations.

Other Disclosures: We may disclose your personal information to enforce any applicable Terms of Use and to ensure the safety and/or security of the Website, users, and providers.

Social Networks

Features of Path CCM’s Website permit you to initiate interaction between Path CCM’s Website and third-party services or platforms, such as social networks. Clicking those links will allow you to access Path CCM’s pages on certain third-party platforms such as Facebook, Instagram, and LinkedIn as applicable. Clicking on those links may entail that third-party to collect and/or use your data and information. If you “like”, “share” or “repost” information onto those sites your personal information may be publicly displayed by the third party.

Links to Other Sites

Our website may contain links to external websites or services. Path CCM does not maintain these sites and is not responsible for the privacy practices of those external sites or services for which it does not operate. You may consult the privacy policies of external sites to understand more about how your information is used by them.

Security

In order to prevent unauthorized access to your personal information, we have suitable physical, technical, and administrative safeguards in place to protect it. While these safeguards are not 100% guaranteed to protect against unauthorized access, use, and disclosure of your personal information, we comply with all applicable laws and regulations regarding data privacy. While we follow accepted industry standards to protect the personal information submitted to us (both during and once we receive it), no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. If you have any questions about security on our website, you can email us at privacy@pathccm.com.

Privacy Notice for California Residents

We include this section for residents of California in order to comply with the California Consumer Privacy Act of 2018, and its amendment, the California Privacy Rights Act of 2020 (together, the “CCPA”). This section is intended to comply with the CCPA by supplementing the information provided elsewhere in the Privacy Policy.

California Privacy Disclosure

This disclosure supplements the information contained in our Privacy Policy by providing additional information about our personal information processing practices relating to individual residents of California.

For the purposes of this disclosure, personal information does not include publicly available information or deidentified, aggregated, or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Personal information under CCPA does not include health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data. Additionally, this disclosure does not describe our practices when we process customer data as a service provider on behalf of our clients in accordance with our contractual agreements with our customers or when we process customer data on behalf of Providers who are individuals providing services to patients.

Your California Privacy Rights

Subject to applicable law, consumers have the following rights:

Right to Know: You have the right to submit a verifiable request up to twice in a 12-month period for specific pieces of your personal information and for information about Company’s collection, use, and disclosure of your personal information.

Please note that the CCPA’s right to obtain “specific pieces” does not grant a right to the whole of any document that contains personal information, but only to discrete items of personal information. Moreover, consumers have a right to know categories of sources of personal information and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients.

Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Company.
Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information.

How to Exercise Your Rights

Company will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:

Contact our Support Contact Center at (323) 205-7088
Complete our California Privacy Rights Request Form
Email us at privacy@rula.com

We match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.

You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity.

In the alternative, you can provide a power of attorney compliant with the California Probate Code.

Company will not unlawfully discriminate or retaliate against you for exercising your rights under the California Privacy Rights Act.

Disclosure of Personal Information

Company does not sell or “disclose” (disclose for cross-context behavioral advertising) your personal information. In addition, we have no actual knowledge that we sell or disclose the personal information of individuals of any age, including the personal information of children under 16. To learn more about the disclosure of your personal information, please refer to the “How We Share Personal Information” section of our Privacy Policy.

Disclosures for Business Purposes

Company may disclose each of the categories of personal information listed in the “Categories of Personal Information We Collect About You” section for the following business purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
Debugging to identify and repair errors that impair existing intended functionality.
Short–term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.”

Cal. Civ. Code § 1798.140(e).

Company may disclose each of the categories of personal information to the third parties listed below:.

Service providers: Company may disclose to service providers any of the categories of personal information listed in the “Categories of Personal Information We Collect About You” section, for the business purpose of performing services on Company’s behalf and, in particular, for the specific purposes described in the “Disclosures for Business Purposes” section, above.
Auditors, lawyers, consultants, and accountants engaged by Company: Company may disclose the categories of personal information listed in the “Categories of Personal Information We Collect About You” section, to these service providers or contractors for the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on the Company’s behalf.
Affiliated companies: Company may disclose any of the categories of personal information listed in the “Categories of Personal Information We Collect About You” sectionto other companies within its managed services organization (MSO) group, presently including SUD Specialty Group – CA; Mental Health Specialty Group, P.A.; Mental Health Specialty Group NJ, PC; and Mental Health Specialty Group KS, P.A., and also including any future medical professional corporations that may become a part of Company’s MSO group, for the business purposes of (a) auditing compliance with policies and applicable laws, (b) helping to ensure security and integrity, (c) debugging, (d) short-term transient use, (e) internal research, and (f) activities to maintain or improve the quality or safety of a service or device.

Additional Information for Applicants or HR Individuals

To review supplemental information that describes the additional personal information we collect when you apply for a position with us, please refer to California Applicant Privacy Notice. To review supplemental information that describes the additional personal information we collect from (a) employees, (b) independent contractors, interns, volunteers, owners, board members, and other individuals who perform work for Company (collectively “Non-Employee Workers”), or (c) employees’ and Non-Employee Workers’ dependents, emergency contacts, and beneficiaries (“Related Contacts”), (all collectively, “HR Individuals”), please refer to California HR Individuals Privacy Notice.

International Users

Our website is not intended for use by and is not directed to users outside the United States, including any users located in the European Union. By using and accessing our website, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Updates

Path CCM reserves the right to update this Privacy Policy from time to time. Non-material changes to this Privacy Policy become effective when the revisions are posted on the website. For material changes, Rula will email users and post on the website. We suggest you review the Privacy Policy on our website to stay informed about how we may collect, store, use and disclose your personal information.

Contact Us

If you have any questions about our Privacy Policy, you may contact us via email at privacy@pathccm.com or at (323) 205-7088.