Privacy Policy

Last modified April, 2023

Introduction

Plume, Inc. (“Plume,” or“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 types of information we may collect from you or that you may provide when you visit the website https://getplume.co/ (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

on our Website;
through our online group therapy sessions;
in email, text, and other electronic messages between you and our Website;
when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by Plume or any third party;
any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Note, Plume is not a medical group. Any telemedicine consults obtained through our Website are provided by independent medical practitioners including, but not limited to, Plume Health Medical Group and Plume Health Medical Group of California (collectively, “Plume Health Medical”), independent medical groups with a network of United States based health care providers (each, a “Provider”). Plume Medical (or your own medical provider if you do not use a Plume Medical Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not Plume. If you do not agree to be bound by those terms, you are not authorized to access or use our Website, and you must promptly exit our Website. 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 Website. By accessing or using our Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Children Under the Age of 18

Our Website are not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on 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 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at help@getplume.co or call us at 720-897-3749

Information We Collect About You and How We Collect It

Generally We collect several types of information from and about users of our Website (collectively, “Personal Data”), specifically information:

by which you may be personally identified, such as name, address, e-mail address, telephone numbers, driver’s license number (or other government identification number), date of birth, credit or debit card number (for payment purposes only), images and video of you, your medical history, race or ethnicity, sexual orientation and sexual preferences, and health information;
about your Internet connection, the equipment you use to access our Website and usage details such as traffic data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website.

We collect this information:

directly from you when you provide it to us;
automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and
From third parties, for example, our business partners.

Information You Provide to Us The information we collect on or through our Website is:

information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, using our Provider consultation services or gender care navigation services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Website;
records and copies of your correspondence (including email addresses), if you contact us; and
details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties, such as through our therapist-led online group sessions and events (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. We reserve the right to remove you from a group therapy session or other event, and cancel your subscription, if you engage in inappropriate conduct during a group therapy session or event, such as using unlawful, offensive, harassing or inappropriate language, or engage in any other unlawful, offensive, harassing or inappropriate conduct. During a group discussion, please do not share personally identifying information of others. Information We Collect Through Automatic Data Collection Technologies As you navigate through and interact with our Website, 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 Website, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and
information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, and browser type.

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 Website and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
provide, improve, and develop our products and services;
store information about your preferences, allowing us to customize our Website according to your individual interests;
recognize you when you return to our Website.

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

Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Website through your computer or mobile device. A “cookie” is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. On your computer, you may refuse to accept browser 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 Website. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

to present our Website and its contents to you;
to provide our products and services to you;
to provide you with information, products, or services that you request from us or that may be of interest to you;
to process, fulfill, support, and administer transactions and orders for products and services ordered by you;
to provide you with notices about your Plume account;
to contact you in response to a request;
to administer quizzes, surveys, and sweepstakes;
to fulfill any other purpose for which you provide it;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to notify you about changes to our Website or any products or services we offer or provide though them;
in any other way we may describe when you provide the information; and
for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. 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 Patient Portal page. For more information, see Choices About How We Use and Disclose Your Information. Some information Plume collects constitutes protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). As set forth above, Plume Medical (or your own medical provider if you do not use a Plume Medical Provider) will provide you with a Notice of Privacy Practices describing its collection, use, and disclosure of your health information, not Plume, Inc. Plume will use and disclose PHI only as permitted in Plume’s agreements with Plume Medical (or your own medical provider if you do not use a Plume Medical Provider) and we only collect the PHI we need to fully perform our services and to respond to you or your Provider. We may use your PHI to contact you to the extent permitted by law, to provide requested services, to provide information to your Providers and insurers, to obtain payment for our services, to respond to your inquiries and requests, and to respond to inquiries and requests from your Providers and benefits program. We may combine your information with other information about you that is available to us, including information from other sources, such as from your Providers, insurers or benefits program, in order to maintain an accurate record of our participants. PHI will not be used for any other purpose, including marketing, without your consent.

Disclosure of Your Information

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. 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, and ordering, product fulfilment, marketing, and payment processing services;
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 bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Plume about our Website users are among the assets transferred;
to fulfill the purpose for which you provide it. For example, we may disclose your personal information to a Provider or to a pharmacy to fulfill a prescription, or to a social worker to assist you in navigating gender transition services;
for any other purpose disclosed by us when you provide the information;
with your consent. For example, where you share an experience for discussion during a group therapy session. Submissions are always voluntary.

We may also disclose your Personal Data:

to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Plume, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. 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 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 Website may then be inaccessible or not function properly.
Promotional Offers from Plume. If you do not wish to have your email address used by Plume to promote our own 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 logging onto your Patient Portal page. This opt out does not apply to information provided to Plume as a result of a product purchase, or your 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 (aboutads.info and www.networkadvertising.org). 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.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

You can review and change your Personal Data by logging into our Website and visiting either the Settings or Patient Portal sections of our Website. 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 cannot delete your personal information except by also deleting your account with us. We may also 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. With respect to any PHI Plume may obtain, you have certain rights under HIPAA to access your data, to restrict use and disclosure of it, to request communication methods, to request corrections to your data, to receive an accounting of disclosures and to receive notice of any breach. See the Notice of Privacy Practices provided to you by your Provider for more information.

Do Not Track Signals

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do 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.

Data Security

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, and we require that all users create password encrypted accounts with two factor authentication enabled. The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website, 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 work diligently to try and protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or in your operating system.

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 Website’s home page. 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 Website’s home page. 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 visiting our Website and reviewing this Privacy Policy to check for any changes.

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.

How to Contact Us:
Plume, Inc.
303 S. Broadway #200-357
Denver, CO 80209
Telephone: (720)-897-3749