Therapist Privacy Policy
Breakthrough Health Labs, Inc.
Last updated September 30, 2026
Care Start fee eligibility follows the Therapist Agreement’s October 15, 2026 match-acceptance cutoff.
1. Introduction
Breakthrough Health Labs, Inc. ("Breakthrough," "we," "our," or "us") operates an administrative matching service that connects people seeking mental health support in Hawaiʻi with independent, licensed therapists. This Therapist Privacy Policy explains how we collect, use, disclose, retain, and protect information about therapists and other clinicians ("Therapists," "you," or "your") who apply to, join, or participate in our matching network (collectively, the "Therapist Services").
This policy applies to information we collect from and about you in your professional capacity. It does not govern information we collect from people seeking therapy – for that, see our consumer Privacy Policy . Your handling of any client information you receive through the network is addressed in our Therapist Terms of Service and remains subject to your own professional and legal obligations.
By applying to or participating in the Therapist Services, you acknowledge that you have read and understood this policy.
2. Information We Collect
2.1 Information You Provide Directly
We collect the information you provide when you apply to and participate in the network, including:
Identity and Contact Information
Name
Email address
Phone number
Mailing and practice address
Professional and Licensing Information
License type, number, and jurisdiction(s)
National Provider Identifier (NPI), where applicable
Education, credentials, certifications, and years in practice
Professional liability (malpractice) insurance information
Practice or group affiliation
Practice and Profile Details
Areas of focus, specialties, and populations served
Treatment modalities and therapeutic approach
Session formats (in-person, telehealth), languages, and availability
Fees, sliding-scale options, and insurance or payers accepted
Biography, headshot or profile photo, and other content you submit for your profile
Demographic or background details you choose to share to support matching
Communications
Messages, emails, and responses to onboarding or intake questionnaires you send to us
2.2 Information Collected Automatically
When you use our website or any therapist-facing tools, we may collect:
IP address
Device type and operating system
Browser type and version
Usage data (pages visited, time spent, interactions, referring URLs)
2.3 Information From Verification and Third-Party Sources
To confirm eligibility and standing, we may collect information about you from third parties and publicly available sources, including:
State licensing authorities, such as the Hawaiʻi Department of Commerce and Consumer Affairs (DCCA) Professional and Vocational Licensing search
Publicly available professional listings and directories
Any additional credential, background, or reference checks we choose to perform
2.4 Cookies and Tracking Technologies
We use cookies and similar technologies to operate and improve our website, analyze usage, and measure performance. You can control cookies through your browser settings; disabling them may affect functionality.
On our public website we use Microsoft Clarity, which records how visitors click, scroll and move through our pages, to improve them. Opting out on Your Privacy Choices stops it in your browser.
2.5 Agreement, Billing and Care Start Records
We keep the following agreement, practice-verification, Care Start and billing records when the relevant events occur, including during advance signing and verification, and only within the Agreement’s permitted data limits. Keeping these records does not itself authorize fees or match acceptance:
Separately identified individual participation party, purchasing Billing Account and Part B Practice Party, human signer and authorized capacity, completed signing components, delivered text versions and hashes, actual acceptance dates, optional fee election and its Therapist and practice scope with effective history, and applicable separate dispute elections.
Therapist affiliation confirmation and authorized-source practice verification, applicable coverage scope and effective history, and delivery of initial effective-coverage notice with dispute terms. Multiple affiliations and lawful practice changes are recorded by applicable match; they confer no cross-practice record access.
Breakthrough-sourced Match, its initial Billing Account, any period-level purchaser changes and relevant acceptance dates; Booking Date, scheduled first clinical session, source and Booking Confirmation; Activation, fixed Coverage Start, Window and four period dates; service mode and elections; permitted payer classification and support; supported ending route and date, receipt and billing-effective date; lawful resumption and final Stop Date evidence.
Necessary service, assistance, response and suspension evidence, including historical attended-coverage records where retained; statements, credits and restoration, payments, disputes, corrections, voids and refunds. General attendance is not collected for billing. Session-occurrence facts are limited to the first-session date, Non-Start and necessary ending, correction or resumption evidence permitted by Article 27.3 and Exhibit A-2. No session content is authorized.
Once a payment method is stored, limited processor references needed for authorized payment administration. We never receive or store a full card number; the billing record retains only brand and last four digits, with processor credentials subject to Article 15.2.
Payments and payment methods are handled by our payment processor (currently Stripe). Article 15.2 governs payment-method requirements, exceptions and changes; Article 15.6 governs purchaser responsibility and practice changes. Section 7 states the applicable retention rules.
3. How We Use Your Information
We use your information to operate the Therapist Services and the matching network. We process it based on your consent, our contract with you, our legitimate interests in operating and improving the network, and compliance with legal obligations.
Application and Verification
To evaluate your application, verify your licensure and standing, and confirm eligibility to participate.
Profiles and Matching
To build and display your professional profile and to identify potential matches between you and prospective clients based on stated needs, preferences, and logistics.
Communications
To send you proposed matches, coordinate introductions, respond to your inquiries, and send service-related updates.
Network Operations and Marketing
To operate, analyze, and improve the network, and to promote the network – which may include displaying your profile information as described in Sections 4 and 5.
Safety and Compliance
To detect fraud, prevent misuse, enforce our agreements, and comply with legal obligations.
These general professional-information uses do not authorize marketing, analytics, AI processing, matching or other reuse of Part B information. B.3.2 classifies each record, copy and transmission by actual function, including protected billing; signing and Booking Confirmation alone do not classify all information.
4. How We Share Your Information
4.1 With Prospective Clients
The core purpose of the network is to introduce you to prospective clients. We display and share your profile information – such as your name, photo, biography, specialties, modalities, general availability, fees, and accepted insurance – with prospective clients to facilitate potential matches.
4.2 With Service Providers
We use third-party providers for functions such as:
Cloud hosting and storage
Form, survey, and scheduling tools
Communication delivery
Analytics
Identity, license, or credential verification
Payment processing when you set up a payment method or authorize payments (currently Stripe)
These providers are contractually restricted from using your information for their own purposes.
4.3 Marketing and Analytics Partners
We may share limited information with analytics and advertising providers to measure and improve our marketing, and we may feature profile information you provide in materials that promote the network. We do not sell your personal information.
4.4 Legal Requirements
We may disclose information to comply with law or legal process, respond to government requests, protect rights, safety, or property, or prevent fraud or security issues.
4.5 Business Transfers
If Breakthrough undergoes a merger, acquisition, or asset sale, your information may be transferred. You will be notified of material changes.
4.6 No Sale of Personal Information
We do not sell your personal information.
Part B controls its information and allowed recipients. Its authority, minimum-necessary, prohibited-use, contractual-assurance, assignment and access safeguards apply to protected billing and all other Part B records. These general sharing statements do not enlarge those permissions.
5. The Public Nature of Your Profile
Your profile is intended to be shown to prospective clients and may be used to promote the network. Information you include in your profile – including your name, photo, and biography – may be visible to people outside Breakthrough and may be cached or indexed by third parties.
Please do not include information in your profile that you do not want shared. You are responsible for the accuracy of the information you provide, and you can ask us to update or remove profile content as described in Section 9.
6. Professional Information and Client Health Information
Collecting your professional and business contact information does not by itself make Breakthrough your business associate. Work performed for the applicable Practice Party and information handled in that capacity are governed by Part B. B.3.2 determines the capacity for each record, copy or transmission by its actual function, including protected billing information; independent consumer matching remains distinct.
Any information you receive about prospective or actual clients through the network is separate. Your handling of that information is governed by the Therapist Terms of Service, our consumer Privacy Policy, and your own obligations under applicable law – including, where applicable, the Health Insurance Portability and Accountability Act (HIPAA) and Hawaiʻi law. Once you engage a client, you are the treating provider and are independently responsible for that information.
7. Data Retention
We retain your information for as long as reasonably necessary to operate the Therapist Services, maintain the network, communicate with you, and comply with legal obligations.
If you leave the network, we will remove or stop displaying your profile within a reasonable period, though we may retain certain information as required for legal, operational, dispute-resolution, or recordkeeping purposes. Information drawn from public licensing records may remain publicly available independently of Breakthrough. General retention of de-identified or aggregated professional information does not authorize retention or use of Part B information beyond Part B’s express permissions.
Agreement, acceptance, disclosure, Ledger and minimum billing records follow Article 29: seven years from creation or, for an agreement or other continuing document, when it stopped applying if later, subject to earlier deletion requirements and continuing retention duties. Part B governs its information, including return, deletion and limited later safety routing. General retention or de-identification statements in this policy do not enlarge Part B's permissions.
8. Data Security
We implement reasonable safeguards, including:
Encryption in transit and at rest
Access controls
Internal data-handling restrictions and contractual protections with service providers
No system is completely secure, and we cannot guarantee absolute security. Applicable legal notice duties remain. For confirmed unauthorized access to, acquisition of, or disclosure of Independent-Capacity information about a person introduced or matched to you, Article 27.5 requires written notice promptly after confirmation, whether legally required or not, with its specified content and B.8.4 supplementation and closure rules. Notice and updates under Article 27.5 may be delayed only to the extent and for the period required by law, and must be given promptly when that restriction ends. PHI incidents follow Part B’s separate discovery-based clocks, notification, approval and cost rules, including B.8.2’s limited legally required delay. These general statements do not reduce Part B’s safeguards or notices.
9. Your Rights and Choices
Depending on your location, you may have rights to access, correct, update, or delete your personal information, and to opt out of non-essential communications.
You may also ask us to update or remove your profile content at any time. Some information may be retained where permitted or required by law, or because it is drawn from public licensing records.
To make a request, contact us at support@breakthrough.me . We may verify your identity before responding and will respond within the timeframe required by applicable law.
Article 29.5 supplies, on request within 14 HST dates, a readable and retainable copy of your match’s Ledger, billing record and supporting coverage evidence still lawfully held, excluding other Therapists’ information and subject to lawful record authority. This qualified copy right does not excuse failures to retain records required by Article 29 or Part B.
10. Children's Privacy
The Therapist Services are intended for licensed professionals and are not directed to anyone under 18. We do not knowingly collect information from minors through the Therapist Services.
11. International Users
Our Services are operated in the United States. If you access them from outside the U.S., your information may be transferred to and processed in the U.S.
12. Changes to This Policy
We may update this policy prospectively. Material changes require Article 31.2’s email notice under Article 35; posting alone is insufficient. No policy update changes either Part of the Therapist Agreement except through that Part’s amendment process.
13. Contact Us
Breakthrough Health Labs, Inc., a Delaware corporation
Honolulu, HI
Email: support@breakthrough.me