1. Introduction

This Privacy Policy describes how Mount North collects and uses Personal Data about you through the use of our Website, mobile applications, and through email, text, and other electronic communications between you and Mount North.

Mount North, LLC (“Mount North,” “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 www.mount-north.com and Mount North Base Camp or Boot Camps. Mount-north.com (collectively, our “Website”) and the Practice Better platform (the 3rd party “Platform and Application that we use”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• on our Website and Application;
• in email, text, and other electronic messages between you and our Website and Application; and
• 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 Mount North or any third party; and
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application.

Note, Mount North is not a medical group and Mount North does not provide medical advice or care.

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 and Applications, and you must promptly exit our Website or Application. By accessing or using our Website and/or Application, 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 or Application after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Children Under the Age of 18

Our Website and Application are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Website or our Application. We will remove any information about a child under the age of 18 if we become aware of it.

Our Website and Application are not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Website or Application. 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 in our Applications or on or through any of their 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 info@mount-north.com.

3. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally

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

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

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Website or use our Application. 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 or through our Application is:

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

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or Application or transmitted to other users of the Website or Application or third parties, such as through our therapist-led events and group “camps” and “bootcamp” forums. (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 and Application 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.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website and Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

• Usage Details. Details of your visits to our Website or Application, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Website or use of our Application, error information, clickstream data, and other communication data and the resources that you access and use on the Website or in the Application;
• Device Information. Information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and Application version information;
• Stored Information and Files. Where video files and photographs are submitted through the Application, the Application collects metadata and other information associated with those photographic and videographic images; and
• Location Data. The Application, depending on the version, may collect information about the location of your device. If you do not want us to collect this information do not download the Application or delete it from your device.

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

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

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 and Application 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 or use certain parts of our Application. 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 or use our Application.
• 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 here). 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,
• Facebook Advertising Services. We use Facebook Pixel, a web analytics and advertising service provided by Facebook Inc. (“Facebook”) and related Facebook advertising services on or in conjunction with our Website. With its help, we and our customers can keep track of what users do after they see or click on a Facebook or Instagram advertisement, keep track of users who access our Website or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel is also saved and processed by Facebook. Facebook can connect this data with your Facebook or Instagram account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found here. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel.

4. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

• provide our Website or Application to you;
• provide products and services to you;
• provide you with information you request from us;
• enforce our rights arising from contracts;

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 present our Application 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 Mount North 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, our Application, 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 Account Preferences page. For more information, see Choices About How We Use and Disclose Your Information.

We may de-identify your Personal Data so that it no longer reasonably identifies you. In this case, we may use this de-identified data without restriction and for any purpose, including to improve our Website, Application, and products and services.

5. 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. We disclose your Personal Data to a few third parties, including:

• our affiliates and third-party service providers that we use to support our business;
• to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
• to comply with our legal obligations; to affiliates and third parties for their own commercial purposes;

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 affiliates, 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, 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 Mount North about our Website and Application users are among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information;
• With your consent. For example, if you share an experience with us for the purposes of a group Camp or Bootcamp session, we may use a de-identified version of your submission for the purposes of a group discussion. Submissions are always voluntary and submissions with personally identifying information will not be shared without your consent.

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 Mount North, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our advertising to you. We do not control the collection and use of your information collected by third parties.

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:

• Promotional Offers from Mount North. If you do not wish to have your email address used by Mount North 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 Account page. This opt out does not apply to information provided to Mount North as a result of a product purchase, or your use of our services.

7. Your Rights Regarding Your Information and Accessing, Correcting and Erasing Your Information

You may review and change your Personal Data by logging into our Website or the Application and visiting your Account Settings page.

You can review and change your Personal Data by logging into our Website or Application and visiting the Account sections of our Application or 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 Data 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.

How long we retain your data and requesting data erasure:

Mount North is committed to ensuring that all applicable Personal Data is retained only for the amount of time required to provide relevant products and services and in accordance with relevant legal requirements.

Certain categories of data are retained for a period of time after you no longer use our services or your account becomes inactive. These categories of data are retained to allow for a seamless reactivation in the event you begin using our services again and allows Therapists to reference historical information. Retaining this data is also needed to ensure our products and services function.

In addition to the data retention schedule outlined below, Mount North maintains a process for all user accounts (regardless of where they live) to receive and process, without undue delay, requests by clients to erase or access their data.

The following sections describe both how long a client can expect their data to be retained for given specific account information as well as how to request data erasure and access. In this Policy, data erasure is defined as the permanent removal or obfuscation of identifiable data so that it is no longer accessible by anyone.

Retention Policy:

Mount North’s data retention policies are based upon what data is being Processed, whether or not the client has participated in therapy, and if the client proactively requested data erasure or if the erasure is triggered due to platform inactivity.

Exercising Your Data Protection Rights:

As stated, you have certain rights under data protection laws, including the right to request that we erase personal data we hold about you, and the right to request a copy of it. The following sections describe how you can exercise those rights.

Requesting Data Erasure:

To request data erasure, please visit the following link to request complete erasure of your account: https://mount-north.com/privacy-request-form/. Complete the form to begin the data erasure process. You will know if this is a success because you will receive a confirmation email from us within 24 hours of your request.

If you do not have access to your account or are having trouble with this method, you can directly contact Mount North at info@mount-north.com and we will assist you with the process. As with the first way, you can expect a confirmation email within 24 hours of your request.

You may reach out to us at info@mount-north.com if you need additional help. We will only comply with a request for the erasure of your data if we can verify your identity. There is usually no charge. In exceptional circumstances, we may charge a reasonable fee after discussing the fee with you.

If you reach out to Mount North by phone or at info@mount-north.com, we have specific requirements that must be met in order for us to process your data erasure request.

Requirements:

• Only you or your authorized representative may make a request on your behalf. You may also make a request on behalf of your minor child depending on the applicable laws.
• You must provide sufficient information that allows us to reasonably verify your identity or status as an authorized representative.
• You must provide details that allow us to understand, evaluate, and respond to your request.

In some circumstances, legal or regulatory requirements limit our ability to honor erasure requests. As such, we may decline requests for erasure if the information is:

• Subject to a litigation hold or legal request to preserve it.
• Necessary to comply with laws and regulations and to maintain business integrity.
  • Clinical Health Record (described above) falls under this exemption.

Additionally, compliance obligations require us to retain records documenting certain interactions you have with us related to your account. As such, we cannot honor erasure requests for information contained in records of:

• Communications about complaints and erasure or access requests.
• Disclosures of personal data to Third Parties.

If we don’t intend to comply with a request, then we will tell you why this is the case, and outline how we weighed your rights and freedoms against our legal obligations. In such instances, any information retained will only be used for purposes contemplated under the legally recognized exemption.

8. Do Not Track Signals

We currently do not honor do-not-track signals that may be sent by some browsers.

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. Because there is no standard for these signals at this time, we currently 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.

9. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Website confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website or Application, 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 or on or through our Application. 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, in your operating system, or in the Application.

10. Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

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 or the Application’s home screen. 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 or the Application’s home screen. 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 accessing the Application or visiting our Website and reviewing this Privacy Policy to check for any changes.

11. Contact Information

You may contact us through the contact information below.

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 or through the “Contact Us” page on our Website or in the Application.

How to Contact Us:

Mount North, LLC
PO Box 106

Grampian, PA 16838

Telephone: (833) MOUNTN1
Email: info@mount-north.com

Last modified: October 14 , 2023