At Between Inc. ("Between", "we" or "us"), we are committed to protecting your privacy and we take great care with your personal information that we gather when you access or use www.hellobetween.com and related websites and services owned and operated by Between and that link to this Privacy Policy (collectively, the "Services"). This U.S. State Privacy Policy ("Policy") is meant to help (1) those that use our Services to discover, book and pay Birth Workers ("Users") and (2) doulas, lactation consultants, newborn care specialists and other birth workers (collectively, "Birth Workers" and collectively with Users, "you" or "your") that use our Services to manage User information and collect payments understand how we treat your personal information ("Personal Data").

This Policy applies to residents covered by laws in states with privacy laws ("Consumers"), including those in California, Colorado, Connecticut, Delaware, Florida, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia (collectively, the "U.S. State Privacy Laws"). This Policy provides you with notice of our data practices on the Services (from the Effective Date listed at the top of this Policy), wherever U.S. State Privacy Laws apply, as required under some U.S. State Privacy Laws. Additionally, this Policy also applies to our current data practices such that it is also meant to provide you with “notice at collection,” which is notice of personal information we collect, and the purposes for which we process personal information, among other things, as required by the U.S. State Privacy Laws.

Except as expressly provided below under “How We Use Information That is Not Personal Data”, this Policy does not apply to data that is not treated as Personal Data under U.S. State Privacy Laws or to the extent the data is subject to an exemption under the applicable laws. This Policy also does not apply to information collected by third-party content, websites, applications, platform, code (e.g., plug-ins, application programming interfaces, and software development kits), and certain third-party cookies and other tracking technologies ("Third-Party Services").

BY USING OR ACCESSING THE SERVICES IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION IN THE FOLLOWING WAYS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF. Any use of Between’s Services is at all times subject to the Agreement (as the term "Agreement" is defined in our Terms of Use, which incorporates this Privacy Policy). Thank you so much for choosing Between.

Between does not provide or facilitate any healthcare services. Some Birth Workers may also be healthcare professionals. However, Birth Workers do not act in the capacity of healthcare professionals on Between. Between and Birth Workers will not offer diagnosis, prescribing of medication, treatment or any other clinical services or services for which a healthcare professional license would be required. We urge you to see a licensed healthcare professional for diagnosis, prescribing of medication, treatment or any other clinical services or any other services that would constitute the practice of medicine or otherwise require a healthcare professional license.

PRIVACY POLICY TABLE OF CONTENTS

1. PERSONAL DATA

The following subsections detail the categories of Personal Data that we collect. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. For each category of Personal Data, these subsections also set out the source of that Personal Data, our commercial or business purpose for collecting that Personal Data and the categories of third parties with whom we share that Personal Data. More information regarding those sources and categories are set forth below.

1.1 USER PERSONAL DATA

THE FOLLOWING SUBSECTIONS APPLY ONLY TO USERS.

1.1.1 Categories of Personal Data We Collect

1.1.2 Categories of Sources of Personal Data

1.1.3 Commercial or Business Purposes for Collecting Data

● Providing, Customizing, and Improving the Services

• Providing you with the products, services and information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics, and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Marketing and selling the Services.
• Showing you advertisements, including interest-based or online behavioral advertising.

● Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, including to remind you of an upcoming appointment, and sending you information about Between or the Services.
• Sending emails and other communications that display content that we think will interest you and according to your preferences including notifying you about certain resources, Birth Workers or Services.

● Legal Requirements

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Between or another party.
• Enforcing any agreements with you.
• Resolving disputes

1.1.4 How We Share Your Personal Data

In certain circumstances, we may share your Personal Data with the following categories of service providers and other third parties for the indicated business purposes:

THE FOLLOWING SECTIONS APPLY TO BOTH USERS AND BIRTH WORKERS.

2. Business Transfers

All Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

3. Tracking Tools, Advertising and Opt-Out

The following sections provide additional information about how we collect your Personal Data.

Information Collected Automatically

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, mobile identifiers, and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser and tell us how and when you visit and use our Services. We do this to analyze trends, learn about and advertise to our user base, and operate and improve our Services. For example, we use Cookies to tailor the Services or customize advertisements by tracking navigation habits, measuring performance, customizing user experiences with the Services and for analytics and fraud prevention. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We may use the following types of Cookies:

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all Cookies that are already on your computer. Although you are not required to accept Between’s Cookies, if you block, reject, or delete them, you may have to manually adjust some preferences every time you access the Services as some functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Not all browsers offer a Do Not Track option and there is currently no industry consensus as to what constitutes a Do Not Track signal. Please note that, for these reasons and because of our use of Cookies, our Services, like many website operators, do not support “Do Not Track” requests sent from a browser at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Information about Interest-Based Advertisements:

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who display certain preferences or behaviors "Interest-Based Ads". Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived or inferred from the online activity or usage patterns of particular users on the Services and/or services of third parties. Such information may include IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including Web Beacons, from an ad network to you through the Services. Web Beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. This information helps Between learn more about our Users’ demographics and internet behaviors. Web Beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web Beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

We comply with the Digital Advertising Alliance "DAA" Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative "NAI", several media and marketing associations have developed an industry self-regulatory program to give users a better understanding of, and greater control over, ads that are customized based on a user’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s User opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices, or install the DAA’s AppChoice app (for iOS; for Android) on your mobile computing device. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive Interest-Based Ads from NAI or DAA member companies. If you delete Cookies on your computer, tablet or mobile computing device, you may need to opt out again. For information about how to opt out of Interest-Based Ads on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device. You will need to opt out of each browser and device for which you desire to apply these opt-out features.

Please note that even after opting out of Interest-Based Ads, you may still see Between advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that Between is no longer using tracking tools — Between may still collect information about your use of the Services even after you have opted out of Interest-Based Ads and may still serve advertisements to you via the Services based on information collected via the Services.

Data Security and Retention

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. Children’s Privacy

The Services are not directed to or intended for use by children under 13 years of age. If you are a child under the age of 13, please do not attempt to use the Services or send us any Personal Data. By accessing, using and/or submitting information to or through the Services, you represent that you are not under the age of 13. As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under the age of 13. If we learn that we have received any Personal Data directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that Personal Data only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s Personal Data. If you believe that a child under 13 may have provided us with Personal Data, please contact us at info@hellobetween.com.
If you are between age thirteen (13) and the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. If you are a parent or legal guardian of a minor child, you may, in compliance with the Agreement, use the Services on behalf of such minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Data as otherwise provided herein. Some of the U.S. State Privacy Laws also require us to state that we do not knowingly Sell or Share the Personal Data of Consumers under 16.

If you use the Services on behalf of another person, regardless of age, you agree that Between may contact you for any communication made in connection with providing the Services or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Services on behalf.

6. How We Use Information That is Not Personal Data

Certain information that Between collects may not be Personal Data, including information that does not include any identifiable information at collection or which we have de-identified and/or aggregated from Personal Data. We may use this information for any purpose permitted by applicable law, including but not limited to for purposes of better understanding who uses Between and how we can deliver a better digital experience.

7. Rights Under U.S. State Privacy Laws

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Your Rights

Your rights include:

Depending upon the state where you live, you may also have the following rights:

How to Exercise Your Rights

As permitted by U.S. State Privacy Laws, any request you submit to us is subject to an identity verification process ("Verifiable Consumer Request") as described in the Verifying Your Request section below. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected Personal Data. Certain information may be exempt from such requests under applicable law, such as information we retain for legal compliance and to secure our services.

To make a request, other than a Do Not Sell/Share/Target request, please submit your request to us by one of the methods below. For instructions on how to submit a Do Not Sell/Share/Target request, please go to the Do Not Sell/Share/Target section below.

∙ Email us at info@hellobetween.com
∙ Visit our website: www.hellobetween.com

When you make a request, we will respond to the request with respect to information we have associated with your email address. We may have other Personal Data about you that we are unable to associate that information with you.

Verifying Your Request

When you make a request, we will verify that you are the person you say you are, or, if you are seeking information on behalf of another person, that you are authorized to make the request on their behalf (see our “Authorizing an Agent” section immediately below). In addition, we will compare the information you have provided to us to ensure that we maintain personal information about you in our systems. As an initial matter, we ask that you provide us with, at a minimum, your name and email address. Depending on the nature of the request and whether we have the email address you have provided in our systems, we may request further information from you to verify that you are the Consumer making the request. We will review the information provided as part of your request and may ask you to provide additional information via e-mail or other means to complete the verification process. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), Right to Delete, or Right to Correction request unless you have provided sufficient information for us to reasonably verify you are the Consumer that is the subject of the request. The same verification process does not apply to opt-outs of Sale or Sharing, or limitation of Sensitive Personal Data requests, but we may apply authentication measures if we suspect fraud (such as verifying access to the email provided when making the request).

If we cannot verify you in respect of certain requests, such as if you do not provide the requested information, we will still take certain actions as required by certain U.S. State Privacy Laws. For example, if you are a California Consumer:

∙ If we cannot verify your deletion request, we will refer you to this U.S. State Privacy Notice for a general description of our data practices.
∙ If we cannot verify your specific pieces request, we will treat it as a categories request.

Authorizing an Agent You may designate an authorized agent to submit a request on your behalf by submitting a request in the manner described above. If you are an authorized agent who would like to make a request, the U.S. State Privacy Laws require that we ensure that a request made by an agent is a Verifiable Consumer Request and allow us to request further information to ensure that the Consumer has authorized the agent to make the request on their behalf. Generally, we will request that an agent provide proof that the Consumer gave the agent signed permission to submit the request, and, as permitted under the U.S. State Privacy Laws, we also may require the Consumer to either verify their own identity or directly confirm with us that they provided the agent permission to submit the request.

Your Consumer Privacy Rights

Appeal Rights

Residents of Colorado, Connecticut, Florida, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas and Virginia have the right to appeal a decision regarding a privacy request. You can exercise this right by responding to the email we send containing our response to your request, and following the instructions in such email.

California "Shine The Light" Law and Your Right to Know/Access

Right to Know – Categories/Confirmation of Processing

If you are a California resident, you have the right to request that we provide you with certain information about our collection, use and disclosure of your Personal Data over the 12- 14 month period prior to the request date, related to categories of Personal Data. You can request that we confirm whether we are processing your personal information, and disclose to you: (1) the categories of Personal Data we collected about you; (2) the categories of sources for the Personal Data; (3) our business or commercial purpose for collecting or selling that Personal Data; (4) a list of the categories of Personal Data disclosed for a business purpose in the prior 12 months and, for each category of Personal Data, the categories of recipients; and (5) a list of the categories of Personal Data sold or shared about you in the prior 12 months and, for each, the categories of recipients.

Right to Know - Specific Pieces

You have the right to request a transportable copy of the specific pieces of Personal Data we collected about you. Based on your state of residence, we may apply a limit on the number of “Right to Know” requests you make over a particular time period, as permitted under U.S. State Privacy Laws.

Right to Delete

You have the right to request that we delete any of your Personal Data that we have collected directly from you, subject to certain exceptions which we will explain if they apply. We may need certain information in order to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services.

Right to Correct

You have the right to request that we correct inaccuracies that you find in your personal information maintained by us. Your request to correct is subject to our verification (discussed above) and the response standards in the applicable U.S. State Privacy Laws.

If you are a California resident and would like to exercise any of the above rights, please submit your request in writing to us by using the contact details provided in this Privacy Policy.

Do Not Sell/Share/Target

Under the various U.S. State Privacy Laws, Consumers have the right to opt-out of certain processing activities. Residents of those states may opt out of the Sale of their Personal Data or processing or Sharing of their Personal Data for Targeted Advertising. We Sell or Share certain of your information to certain third parties, such as Third Party Business Partners, that may directly provide you with offers and promotions and opportunities that may be of interest to you. We also provide or allow third-party digital businesses, including social media platforms, analytics companies, data brokers, third-party advertisers, and other tech companies that offer digital advertising services ("Third Party Digital Businesses") to receive or collect from the Services certain information, such as cookies and web beacons (e.g., pixel tags), IP address and/or browsing behavior ("cookie Personal Data") and information about your potential interests or characteristics, to deliver Targeted Advertising to you on the Services or other services. We may also make available to Third Party Digital Businesses information otherwise collected from or about you, such as your email address (which we refer to below as "non-cookie Personal Data"). This activity may also be considered a Sale under applicable law.

For information regarding other categories of third parties to which we may Sell/Share your Personal Data, see the tables above in this Privacy Policy.

When you opt-out pursuant to the instructions below, it will have the effect of opting you out of Sale, Sharing, and Targeted Advertising, as applicable, under all of the various applicable state laws. Instructions for opting out are below. Please note that there are distinct instructions for opting out of cookie Personal Data and non-cookie Personal Data, which we explain further, below.

Opt-out for non-cookie Personal Data: If you would like to submit a request to opt-out of our processing of your non-cookie Personal Data (e.g., your email address) for Targeted Advertising, or opt-out of the Sale or Sharing of such data, make an opt-out request by email to info@hellobetween.com.

Opt-out for cookie Personal Data: If you would like to submit a request to opt-out of our processing of your cookie-related Personal Data for Targeted Advertising, or opt-out of the Sale/Sharing of such Personal Data, you can exercise an opt-out request by emailing us at info@hellobetween.com or as directed in the section above titled Tracking Tools, Advertising and Opt-Out.

You must exercise your preferences on each of our websites and apps you visit, from each browser you use, and on each device that you use. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences will no longer be effective and you will need to enable them again by contacting us at info@hellobetween.com.

Automated Decision-Making and Profiling
We do not believe we carry out profiling in furtherance of decisions that produce legal or similarly significant effects. If we change our practices, we will change this policy and provide you with the right to opt-out of such activities as required by the applicable U.S. State Privacy Laws, subject to any applicable exceptions.

8. Changes to this Privacy Policy

We reserve the right to amend our Privacy Policy at our discretion and at any time. When we make changes to the Privacy Policy, we will notify you through a notice on our website. Use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

9. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to contact us at: