Last Updated: November 24, 2025

Introduction

Places to Thrive ("we," "us," "our," or "Company") operates the Unbroken mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the App. We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the App after the date such revised Privacy Policy is posted.

Collection of Your Information

We may collect information about you in a variety of ways. The information we may collect via the App includes personal data that you voluntarily provide to us when you register with the App, express an interest in obtaining information about us or our services, participate in activities on the App, or otherwise contact us. The personal information we collect may include your name, email address, phone number, demographic information, employment history, career goals, and any other information you choose to provide. We also collect health and wellness information that you voluntarily provide through the App, including emotional check-in data, breathing exercise usage, participation in coaching sessions, community chat interactions, and responses to program curriculum. This information is necessary to provide you with personalized coaching support and trauma-informed care.

The App may automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you navigate through and interact with the App, we may collect information about the individual web pages or screens you view, what websites or search terms referred you to the App, and information about how you interact with the App. This information is primarily needed to maintain the security and operation of our App, for troubleshooting, and for our internal analytics and reporting purposes.

Use of Your Information

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the App to create and manage your account, deliver targeted content and coaching services based on your interests and career goals, facilitate coaching sessions and community interactions, monitor and analyze usage and trends to improve your experience with the App, notify you of updates to the App and our services, respond to your comments and questions and provide customer service, and send you administrative information such as updates to our terms and policies. We use the health and wellness data you provide to deliver personalized trauma-informed support, track your progress through our curriculum, connect you with appropriate coaching resources, and help you achieve nervous system regulation and career transition goals. We may also use your information to compile aggregate data for internal research purposes to improve our services and develop new features and offerings.

Disclosure of Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows: we may share your information with third-party service providers that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and coaching services delivery. These service providers are contractually obligated to use your information only as necessary to provide these services to us and are prohibited from using or disclosing your information for any other purpose. We may share your information with our business partners to offer you certain products, services, or promotions, but only with your explicit consent. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction. In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, we may share your information. With your consent or at your direction, we may disclose your information for any other purpose.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you. Such information is not considered personal information and may be used and shared without restriction for research, marketing, or other purposes.

Security of Your Information

We use administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, use, or disclosure. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information. Given the sensitive nature of health and mental health information collected through the App, we implement enhanced security protocols including encrypted data transmission, secure data storage, access controls limiting who can view your information, and regular security audits and updates.

Your Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information. You may have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise these rights, please contact us using the contact information provided below. You may also have the right to object to or restrict certain processing of your personal information, request portability of your personal information, and where we have collected and processed your personal information with your consent, withdraw your consent at any time. Please note that if you withdraw your consent or object to processing, we may not be able to provide you with certain services, and you may lose access to some or all App functionality.

You may opt out of receiving promotional communications from us at any time by following the instructions in those communications or by contacting us directly. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. You also have the right to complain to a data protection authority about our collection and use of your personal information.

Data Retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies. When you request deletion of your account, we will delete or de-identify your personal information within a reasonable timeframe, except where we are required to retain certain information for legal, regulatory, or legitimate business purposes. Anonymous or aggregated data derived from your usage may be retained indefinitely for research and service improvement purposes.

Third-Party Services

The App may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the App, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services, or applications that may be linked to or from the App.

Children's Privacy

The App is not intended for use by children under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 18, please contact us at the contact information provided below.

California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's "Shine the Light" law permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the information below. Additionally, if you are a California resident, you may have rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, use, disclose, and sell, the right to request deletion of your personal information, the right to opt-out of the sale of your personal information, and the right to non-discrimination for exercising your CCPA rights. We do not sell personal information as defined under the CCPA.

International Users

The App is hosted in the United States. If you are accessing the App from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the App, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

Contact Us

If you have questions or comments about this Privacy Policy or our privacy practices, please contact us at:

Places to Thrive
PO Box 113
Rehoboth, MA 02769

https://www.placestothrive.org

For specific inquiries related to the Unbroken App, please email: unbrokenpathways@placestothrive.com.

Acknowledgment

By using the Unbroken App, you acknowledge that you have read this Privacy Policy and agree to its terms and conditions. This Privacy Policy applies solely to information collected by the Unbroken App and does not apply to information collected offline or through any other means.