Charlie Health COPPA Notice to Parents 

Last updated: 1/9/2024

Charlie Health, Inc. and our affiliates, subsidiaries, and co-branding partners (collectively “Charlie Health,” “We,” “Our,” or “Us”) provides personalized mental health treatment (“Services”) for teens, young adults & families (“Clients”), including teens under the age of 13.  The Service enables your child under the age of 13 (individually “Child” or collectively “Children”) to participate in individual or group treatment where they can express their ideas within a live video or audio group mental health treatment session. Individual sessions are only attended by that Client and the Charlie Health facilitator/provider, and group treatment sessions (“Group Sessions”) are attended by the Charlie Health facilitator/provider and other Clients who are assigned as part of a cohort similar to your Child. We caution that information that is shared by a Client in a Group Session is contemporaneously available to all users of the Client’s assigned Group Session. Charlie Health explicitly prohibits any Client from sharing personal information about other Clients in the Group Session, or recording (whether video or audio), taking screenshots or sharing personal information about any Client. These rules also apply to members of Charlie Health, except where needed to provide our Services.  

Use of the Service by Children may involve the collection of personal information as described below.  Before Children under age 13 may use the Service, Charlie Health needs a Parent’s or legal Guardian’s consent (collectively referred herein as “Parents”), to collect, use, or disclose personal information of Children under age 13. As such, Charlie Health will not collect, use, or share personal information from Children under age 13 until you have provided such consent on behalf of your Child. 

This Direct Notice provides important information about how Charlie Health may collect, use, and disclose personal information of Children under age 13 when they use the Service if you provide such consent. Additional information about how Charlie Health collects, uses, and discloses personal information can be obtained by reviewing the Charlie Health Privacy Policy. 

What personal information does Charlie Health collect from Children under age 13? 

If you provide consent as described below, we may collect the following personal information in connection with use of the Service by Children under age 13:

  • Any personal information obtained about your Child via the Service. This could include audio and images included within a video that include the Client’s image or voice, and other personal information the Child share in an individual or Group Session.
  • Any personal information provided by Children in joining the Service. This could include first and last name, user name, date of birth, health information, and contact information.
  • Any personal information contained in feedback or other communications provided by the Client to us, such as when they contact us via email or by submitting the contact form on our Service.
  • Persistent identifiers, such as device identifiers (UDIDs) and Internet Protocol (IP) addresses, may be collected to help us understand how the Service is being used and how to improve the Service. For example, we collect general location information based on IP address. We (and our service providers) also use tracking technologies, such as cookies and web beacons, to automatically collect information about our users, including Children under age 13, in order to analyze and track data and determine the popularity of certain content on our Service.  

How is personal information of Children under age 13 disclosed to others?   

If you provide consent as described below, we may disclose personal information of Children under age 13 in the following ways:

  • Personal information that your Child shares in Group Sessions will be heard by other users.  
  • With vendors, consultants, and other third-party service providers who need access to such information to perform services for us, such as companies that assist us with web hosting and customer service. 
  • With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • If we believe that disclosure is in accordance with, or required by, any applicable law or legal process. We may also share personal information if we believe that the actions of a Client are inconsistent with our agreements, policies, or terms of use or if we believe it is necessary to protect the rights, property, and safety of Charlie Health or others. 
  • In connection with, or during negotiations concerning, any sale, merger, bankruptcy, sale of assets, financing, acquisition, or reorganization, in whole or in part, of our company. 
  • Between and among Charlie Health and our current and future partners, affiliates, subsidiaries, and other companies under common control and ownership. 

By providing consent as set forth above, you represent and warrant to Charlie Health that you are authorized to consent on behalf of your Child.