Last Updated: February 2020

This privacy notice applies to any Comfort Recovery (the “Company”), Website, service, or portal (collectively “Services”) where this privacy notice is referenced, regardless of how you access or use them. This policy along with the Terms of service govern your use of the Company’s Website. This Notice is provided to you under the Health Insurance Portability and Accountability Act (HIPAA) and applies to all records received and created about your physical and mental condition and treatment (together “PHI”).

This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person (“Personal Data”) that is collected from Users on or through the Services.

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

PLEASE CONSULT YOUR HEALTH CARE PROVIDER BEFORE MAKING ANY HEALTHCARE DECISIONS OR FOR GUIDANCE ABOUT A SPECIFIC MEDICAL CONDITION. THE STATEMENTS MADE ON THIS WEBSITE ARE FOR EDUCATIONAL USE ONLY AND SHOULD NOT BE CONSTRUED AS ADVICE. BY ACCESSING OR USING THE WEB BROWSER, YOU AGREE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY OUR TERMS AND PRIVACY POLICY. IF YOU DO NOT AGREE, YOU MAY NOT USE THE WEBSITE.

Changes. We may amend this privacy notice at any time by posting the amended version on this site including the effective date of the amended version.

Information We Collect

  1. “Non-Personal Data” as used in this Privacy Policy is therefore any information that does not relate to a person and/or cannot be used to identify a person. When you interact with the Services, we may collect Non-Personal Data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data
  2. When you use or interact with us through the Services, we may collect Personal Data, including information that may be deemed Personal Health Information.
  3. Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  4. Sometimes this will be on our own behalf and other times this will be on behalf of an Servicer using our Services.
  5. You may provide identifying information such as your name, addresses, telephone numbers, email addresses, business seller information, or tax identification number when registering for an account with the Company. Other Information you may provide the Company when creating a profile include, but is not limited to: a. A profile picture and access to your camera and/or photo library (if you choose to enable this service on your device);
  6. Additional information we are required or authorized by applicable local, state and national laws to collect and process in order to authenticate or identify you or to verify the information we have collected.
  7. Treatment. The Company may receive PHI from you and share PHI with health care providers involved in your treatment before, during, and after your stay with the Company.

Take note, that we will not share your information unless you give us written authorization for: 1) Marketing purposes; 2) Sale of your information; 3) Most sharing of psychotherapy notes. CMIA Compliance. CMIA establishes standards to protect Medical Information of the individuals that use the Service. We have appropriate safeguards to protect the privacy of your Medical Information and have established limits and conditions on the uses and disclosures that may be made of such information without patient authorization. However, we may use your Medical Information in our sole discretion for various purposes, including but not limited to: treatment; processing of payment; enabling users to participate in the Service’s features; providing customer support; contacting users regarding any updates or changes to this policy or Terms and Conditions; and for other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy or permitted by applicable laws.

HIPAA Compliance. The HIPAA Privacy Rule establishes standards to protect users of the Service individuals’ medical records and other personal health information. The Service has appropriate safeguards to protect the privacy of personal health information and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. However, we may use your Personal Information, Demographic Information or Usage Information at the Company’s sole discretion for various purposes, including but not limited to processing of transactions; providing special offers catered to users’ needs; enabling users to participate in the Service’s features; providing users with a customized experience; providing customer support; contacting user regarding any updates or changes to this policy or Terms and Conditions; and for other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Cookies. We use cookies, web beacons, unique identifiers, and similar technologies to collect information about the pages you view, the links you click, and other actions you take when using our Services, within our advertising or email content.  You have the ability to enable or disable cookies from presenting themselves in your browser.  If enabled, cookies allow the Company’s website to provide systems to recognize your browser and remember certain information.

We may use cookies to compile and store certain data about website traffic and behaviors in order to offer our visitors a better and more enhanced experience.  The Company may collect information from cookies, including URLs visited during your browsing experience, location, and other behaviors.  We do not allow other parties to collect personal information about your online activities when you visit our website or use our services.

Information We Use or Disclose

We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth in this Privacy Policy.

The Company may make certain disclosures of your PHI as and when required or otherwise authorized by law, and will limit the use or disclosure to the amount of PHI necessary to comply with and/or serve the purposes of the relevant federal, state, or local laws or ordinances, or the legitimate needs of responsible, authorized agencies in fulfilling their purposes, including, for example:

  1. To the United States Department of Health and Human Services as part of an investigation or determination of compliance with relevant laws;
  2. To a state agency for activities such as audits and inspections;
  3. To a court or administrative law judge or other tribunal for judicial or administrative proceedings and/or as required by court or administrative orders, subpoenas, and/or other lawful process unless the state has more restrictive laws;1
  4. To a public health authority which is permitted by law to collect or receive such information for the purpose of preventing or controlling disease, injury, vital events such as death, child abuse or neglect; of conducting public health surveillance, investigation and/or intervention; and reporting adverse reactions to medications or problems with regulated products;
  5. To a health oversight agency for oversight activities authorized by law, such as audits, investigations, and inspections.
  6. To coroners, medical examiners or funeral directors consistent with applicable law to carry out their duties.
  7. To organ or tissue procurement organizations to facilitate the donation of organs, eyes or tissues after your death; and
  8. For specialized governmental functions, such as national security, intelligence activities, and for the provision of protective services to the President to the extent required by Federal and State laws.
  9. Emergency. In the event of your incapacity or an emergency, the Company may also disclose your medical information based on our professional judgment of whether the disclosure would be in your best interests.
  10. Health Care Operations. The Company may use or disclose PHI in connection with managing and operating the organization. We may also disclose your health information to business associates with whom we contract to provide services where such business associates agree to appropriately safeguard your PHI.
  11. We also automatically collect certain technical data that is sent to us from the mobile device and/or browser through which you access the Services (“Automatic Data”). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Services, information about how you came to the Services and data collected through Cookies, Pixel Tags, Local Shared Objects, Web Storage and other similar technologies. You can find out more information about how we use Cookies and other similar tracking technologies in our Cookie Policy.
  12. If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
  13. We use your personal information to provide and improve our Services, provide you with a personalized experience on our sites, contact you about your account and our Services, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities.
  14. We use the personal information we collect from you for a range of different business purposes and according to different legal bases of processing.

Access and Use. If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.

Aggregated Personal Data. In an ongoing effort to understand and serve our Users better, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.

Staying Signed in. When you sign in to your account on our Services, we give you the option to stay signed in to your account for a certain amount of time. If you are using a public or shared cellular device, we encourage you not to choose to stay signed in. You or any other user of the cellular device/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorization. If you are using a public or shared cellular device, you should sign out and/or clear your cookies when you are done using our Services to protect your account and your personal information.

Service Providers. We may share your Personal Data with Medical service providers who process Personal Data on the Company to perform certain business-related functions. We are not responsible for the actions of these Servicers, or their Third Party Servicers (or other downstream recipients of your Personal Data), with respect to your Personal Data. It is important that you review the applicable policies of the Servicers, and if applicable and available, their appointed Third Party Servicers, before providing Personal Data or other information in connection with that service.

Similarly, if you are a member of a Servicer’s organization within the Company, your Personal Data will be available to the Servicer and shared with those Third Party Servicers granted permission by the Servicer to view all members of the Servicer’s organization.

Google, Social Media and Other Third Party Connections. Connecting your account to Social Media Services. If you connect your social media account on the Company’s account, or third party services like Google, we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy.

Legal Requirements. We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.

How We Store Your Personal Data. We take all commercially reasonable steps to protect the Personal Data collected via the Services from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.

Your Rights

You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data that we process about them.

If a Patient initiates a data deletion request, the Company is authorized to delete or anonymize Personal Data of the requesting Patient from the Services even if that means removing its availability to the Servicer through the Services. However, if you are a Patient, you understand that even if the Company deletes or anonymizes your Personal Data upon your request or pursuant to this Policy, your Personal Data may still be available in the Servicer’s own databases if transmitted to the Servicer prior to the Company receiving or taking action on any deletion or anonymization activity.

We will consider and respond to all requests in accordance with applicable law.

Access, correction, and deletion of your personal information. Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable national laws.

If you believe that the information, we have about you is incorrect or incomplete, you may request an amendment to your PHI in a designated record set. You may submit a request for amendment in writing to the Privacy Officer, with a reason you wish to make the amendment. We may deny your request if you ask us to amend information that was not created by us, is not part of your designated record set, or if the information is determined to be accurate and complete as it is.

If you provide us with an authorization to use or disclose your PHI, you may revoke that authorization, in writing, at any time, and we will honor your request(s), except as required, prohibited, or permitted by law.

You have the right to request an “accounting of disclosures.” This is a list of disclosures that we have made of your PHI. We are not required to list certain disclosures, including (1) disclosures made for treatment, payment, and health care operations purposes, (2) disclosures made with your authorization, (3) disclosures made to create a limited data set, (4) disclosures made directly to you, (5) disclosures permitted or required by the Federal HIPAA Privacy Rule, and/or (6) disclosures occurring prior to April 14, 2003.

How Long We Retain Your Personal Data. We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

Limit the Personal Data You Provide. You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services.

Do Not Track. We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Data.

Personal Data Provided to Others. This Privacy Policy does not apply to any Personal Data that you provide to another User or visitor through the Services or through any other means.

Third Party Links. This Privacy Policy applies only to the Services. The Services may contain links to other Websites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Third Party Privacy Practices. This privacy notice addresses only our use and handling of personal information we collect from you in connection with providing you our Services. If you disclose your information to a third party or visit a third party Website via a link from our Services, their privacy notices and practices will apply to any personal information you provide to them or they collect from you. We cannot guarantee the privacy or security of your personal information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your personal information. This is true even where the third parties to whom you disclose personal information are bidders, buyers or sellers on our site.

Children – Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect Personal Data from children under the age of eighteen (18). If you are under the age of eighteen (18), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to us through the Services, please contact us and we will endeavor to delete that information from our databases.

Google Analytics. We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. We use this data to analyze trends, gather demographic information, and cooperate with law enforcement activities.

Public Forums. This Website, now or in the future, may include public forums such as message boards, bulletin boards, chat rooms, or similar activities through which users of the Website can communicate with one another. THIS PRIVACY POLICY DOES NOT PROTECT YOU WHEN YOU USE PUBLIC FORUMS OR PROVIDE INFORMATION (INCLUDING PERSONALLY IDENTIFIABLE INFORMATION) ABOUT YOURSELF. You should be aware that any information shared in a public forum such as a message board, bulletin board, chat room, or other forum is public information and may be seen by third parties that do not adhere to our Privacy Policy. You should think carefully before disclosing any information in any public forum, including the forums on our Website.

GDPR, FRANCE, CANSPAM, and Other International Privacy Laws. THIS SERVICE IS ONLY PROVIDED TO US CITIZENS. If you are visiting the Services from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy.

Change of Ownership. If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.

Modifications. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, “Modifications”). Modifications to this Privacy Policy will be posted to the Site with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances Comfort Recovery may, but need not, provide you with additional notice of such Modifications, such as via email or with in-Service notifications.

Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.

Dispute Resolution.

At any time, if you feel that your rights have been violated or mistreated by Comfort Recovery, you have the right to file a grievance or a complaint.  A grievance can be made by filing a complaint with the US Department of Health and Human Services, Office of Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling toll free 877-696-6775 or visiting their website at https://www.hhs.gov/hipaa/filing-a-complaint/index.html and following the instructions to submit an online complaint.  It is important to understand that there will be no retaliation for a complaint filed, and you reserve this right not only during your treatment, but for any duration after the time in which you received services.

If you have any questions about the Company, this website, our service, this Privacy Policy, Disclaimer or Terms and Conditions, you may contact us at:

optout@comfortrecovery.com or by mail

Comfort Recovery, Inc.

Address:  1545 NE 123rd St. North Miami, FL 33161

Phone:     1-833-845-3853

If your personally-identifiable information changes, or if you no longer desire our service, you may correct, update, delete or deactivate it by emailing our Customer Support at optout@comfortrecovery.com or by contacting us by telephone or postal mail at the contact information listed above. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Comfort Recovery, Inc.
 (the “Company”) uses automatic text message and automatic dialing programs (the “Programs”) to facilitate communications with Clients and Potential Clients. Clients and Potential Clients may consent to being enrolled in the Programs by entering their name and phone number on any of the Company’s websites and clicking the “Contact Me*” button, or some other similar button, to consent being to contacted by the Company, may consent by email by consenting to the terms and conditions of this agreement and the Privacy Policy, or may consent via text message following a conversation with a representative. Following any of the forms of aforementioned consent, you will be able to be contacted using the Programs, unless you consent via a telephone conversation with a representative, in which case you will have an opportunity to confirm or decline your consent to being contacted through the Programs via a reply to an initial text message. By replying YES to this message received from the Company, you are confirming your consent to the Company’s use of the Programs to contact you, including these Terms and Conditions and the Privacy Policy. Message frequency varies.

The Company is committed to building user trust and confidence by promoting and complying with the use of business practices that help protect the privacy of the customer and their data. For more information you can view a copy of our Privacy Policy online.

The Company does not charge for this service; however, message and data rates may apply from your mobile carrier. Subject to the terms and conditions of your mobile carrier, you may receive text messages sent to your mobile phone. Participation in the programs on this short code is standard rated (no premium content).

By providing your consent to participate in the Programs, you approve any such charges from your mobile carrier. Charges for text messages may appear on your mobile phone bill or be deducted from your prepaid balance. Clients and Potential Clients can text message the Company short code of 855-993-6311 with a keyword to receive these services. The Company reserves the right to terminate this SMS service, in whole or in part, at any time without notice. The information in any message may be subject to certain time lags and/or delays. You are responsible for managing the types of SMS texts you receive. If you have any questions or need help, text HELP as a reply to any text message received from the Company, or call 855-993-6311.

To stop receiving text messages, text STOP, STOP ALL, END, QUIT, CANCEL, or UNSUBSCRIBE, in reply to any text message received from the Company. By consenting the use of the Programs, you consent that following such a request to unsubscribe, you will receive one (1) final message from the Company confirming that you have been inactivated in our system. Following such confirmation message, no additional text messages or automatically dialed phone calls will be sent unless you re-submit your consent.

The Company may use an automatic dialing system to make telephone calls or to deliver text messages to you. The Federal Communications Commission defines an “automatic telephone dialing system” or auto dialer as equipment that has the capacity to store or produce telephone numbers to be called and to call such numbers. 47 C.F.R. § 64.1200. By your consent to be contacted through the Company’s Programs you give your consent to Company to use an automatic dialing system to make telephone calls or deliver text messages to the telephone or cell phone number to which you have directed the Company to transmit these text messages.

United States Participating Carriers Included

Contact Us. If you have a question or a complaint about this privacy notice, our global privacy standards, or our information handling practices, you can reach us by calling the office of Chief Legal Officer, at 786-923-3369, or by sending an email to info@Comfort Recovery.com