Welcome to the Rethink Program for Chevron employees. You are one step away from learning how to practice behavior intervention techniques to help your child reach their full potential.
Developed by highly experienced clinicians, educators, and leaders in the field of developmental disabilities, the Rethink program includes:
  • A comprehensive video library with over 1,500 easy-to-follow teaching steps based on principles of ABA (Applied Behavior Analysis)
  • Assessments and learning plans that are customized for each child's specific needs, to help guide parents and caregivers on how to teach skills and decrease problem behaviors effectively.
  • A training center consisting of 11 video modules showing best practice, research-based teaching strategies. Created with parents and caregivers in mind, each step-by-step video module is concise, engaging and jargon free.
  • One on one virtual consultations with our team of behavioral therapists and special educators
  • No diagnosis or medical background documentation required – simply set up your account and start teaching your child immediately!
Employee Benefit

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Terms & Conditions

TERMS OF USE

Rethink Autism, Inc. is a company with its place of business at 19 West 21st Street, New York, NY 10010 (the “Company”). The Company operates the website: www.rethinkbenefits.com (the “Website”).

By agreeing to these Terms you will have access to the following services made available on the Website: the Company offers parents, caregivers and professionals access to effective and affordable web-based treatment tools and supports for individuals with special needs.

1. Understanding these Terms of Use

1.1 These terms of use (these "Terms") describe how you may access and use the Website.

1.2 When certain words and phrases are used in these Terms, they have specific meanings (these are known as "defined terms"). You can identify these defined terms because they start with capital letters (even if they are not at the start of a sentence). Where a defined term is used, it has the meaning given to it in the section of these Terms where it was defined (you can find these meanings by looking at the sentence where the defined term is included in brackets and speech marks).

1.3 In these Terms, when we refer to "we", "us" or "our", we mean the Company; and when we refer to "you" or "your" we mean you, the person accessing or using the Website.

1.4 Please note, however, that certain functions made available on the Website are governed by additional terms and conditions which will be made available to you prior to you having access to those functions.

1.5 In addition to clause 1.4 above, please note that:

1.5.1 we only use your personal information in accordance with our privacy policy (available here); and

1.5.2 any use of our intellectual property rights must be in accordance with our copyright policy (available here).

1.6 Please read these Terms carefully before using the Website. By using the Website, you signify your agreement to be bound by these Terms. You will be given the opportunity to review these Terms before agreeing to these Terms. If you accept these Terms, please click to confirm, where required, and you will then have access to the Website. The contract will not be filed. These Terms are only available in the English language.

1.7 We may from time to time request that you confirm, including in writing, your agreement to and compliance with any part of these Terms as a condition to your continued access to and use of the Website.

2. The Website

2.1 The Website is made available through your employer. We do not guarantee that the Website, or any content on it, will always be available or be uninterrupted. Access to the Website is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of the Website without notice. We will not be liable to you if for any reason the Website is unavailable at any time or for any period. We may update the Website and/or change the content on it at any time.

2.2 You are responsible for making all arrangements necessary for you to have access to the Website. You are also responsible for ensuring that all persons who access the Website through your internet connection are aware of these Terms and that they comply with them.

2.3 The Website and the content on it are provided for general information purposes only. They are not intended to amount to advice on which you should rely.

2.4 With the exception of the Activity Center (as detailed in clause 5 below), the Website is intended solely for users who are 18 years of age or older and who are not considered to be minors in their state or country of residence.

2.5 You may only use the Website for your own domestic, private and non-commercial use.

3. Your account and password

3.1 You will need to register an account with us on the Website in order to access certain services available on the Website ("Account"). If you register an Account, you will be asked to provide certain information (such as your email address) and to create a password, as part of our security procedures. You must treat such password as confidential and you must not disclose it to any third party.

3.2 We have the right to disable any Accounts and/or passwords, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these Terms.

3.3 If you know or suspect that anyone other than you knows your Account login details, you must immediately notify us at privacy@rethinkfirst.com.

3.4 You are responsible for any unauthorised use of your Account login details.

4. Acceptable use

General

4.1 You agree not to:

4.1.1 use the Website in any way that breaches these Terms or any applicable local, national or international law or regulation;

4.1.2 copy, or otherwise reproduce or re-sell any part of the Website unless expressly permitted to do so in these Terms;

4.1.3 do any act or thing that might damage, disrupt or otherwise interfere with the operation of the Website or any equipment, network or software used in operating the Website;

4.1.4 restrict, inhibit or otherwise interfere with any other user’s use, including, without limitation, by means of "hacking" or defacing any portion of the Website or otherwise impairing or overburdening it;

4.1.5 modify, adapt, sublicense, translate, sell, reverse engineer, decompile or disassemble any portion of the Website;

4.1.6 "frame" or "mirror" any part of the Website without our prior written authorization;

4.1.7 use any robot, spider, site search/retrieval application, or other manual process or automatic device or application or extraction tool to access, monitor, copy, use, download, retrieve, index, extract, scrape, data mine, interact, overload, or in any way reproduce or circumvent the navigational structure or presentation of the Website or otherwise defeat, bypass, or circumvent any other protections of our proprietary rights in the Website;

4.1.8 harvest or collect email addresses or other contact information of users without their express written consent;

4.1.9 send unsolicited or unauthorized advertisements, spam, chain letters, or other communications to other users of the Website; or

4.1.10 upload or transmit any User Generated Content (as defined in clause 4.3 below) that contains or embodies a software virus, worm, cancelbot, Trojan horse or other harmful, contaminating or destructive feature, computer code, file or program, or otherwise violates the restrictions on such User Generated Content set forth in these Terms.

4.2 You may input in or upload materials to the private portion of the Website in a designated “file cabinet” which is linked to your user profile and associated with the child profile(s) that you created (the “Private Submission”). We will provide access to such file cabinet solely to you, but will enable you to designate and permit others to access and share the “file cabinet”. While we will take all reasonable steps to protect the privacy of the materials related to the Private Submission stored in a “file cabinet”, any contents you input in or upload to your file cabinet and any sharing of such contents with others is at your own risk.

User Generated Content

4.3 If it is the case that you supply/upload any content to the Website – whether it be pictures, text, sound recordings or whatever – the content you supply ("User Generated Content") must comply with the following rules:

4.3.1 it must not be obscene, abusive, offensive or racist and it must not promote or propose hatred or physical harm against anyone;

4.3.2 it must not harass or bully another person;

4.3.3 it must be true and honest so far as you know;

4.3.4 it must not be defamatory of anyone;

4.3.5 it must not use the material or content or infringe the rights or privacy of anyone else; for example you should not use images of well-known characters, footage or music (unless it is your own);

4.3.6 it must not contain someone else’s personal details or confidential information relating to other people; and

4.3.7 it must not promote or condone terrorism, violence or illegal behaviour.

4.4 We reserve the right to refuse to accept or refuse or cease to use any User Generated Content supplied by any person that we think contravenes these rules.

4.5 When creating and posting User Generated Content, you agree to act in good faith to the best of your ability, and in accordance with these Terms and applicable law. You agree that your User Generated Content will, in both tone and content, contribute in a positive and high quality manner to the substantive exchange of information and the subject matter of the Website.

4.6 Notwithstanding any rules of conduct or provisions set forth in these Terms, we and our third party providers do not control and therefore are not responsible for the actions of users on or off the Website, including, without limitation, any misuse or misappropriation of User Generated Content or for any user generated content created by other users ("Other User Generated Content") that is offensive, inappropriate, obscene, unlawful, objectionable or is otherwise created or otherwise submitted in violation of these Terms. We do not and have no obligation to screen, edit, or review Other User Generated Content. You should be aware that other users may not be who they claim they are. We take no action to confirm any of our users’ profiles. Other User Generated Content may be misleading, deceptive, or erroneous, and you acknowledge and agree that any use by you of any such Other User Generated Content is at your own risk. We do not endorse, support, sanction, encourage, verify, or agree with facts, views, opinions, or statements contained in Other User Generated Content.

4.7 In addition, we may from time to time provide interactive services on the Website that shall enable you to upload User Generated Content, including, without limitation:

4.7.1 comment facilities;

4.7.2 chat rooms; and/or

4.7.3 bulletin boards,

(together "Interactive Services").

4.8 Where we provide an Interactive Service, we will use reasonable endeavours to provide information to you about the kind of service offered and if it is moderated. However, we are under no obligation to oversee, monitor or moderate any Interactive Service we provide.

4.9 The use of any of our Interactive Services by a minor is conditional upon the consent of their parent or guardian. We advise parents who permit their children to use an Interactive Service that it is important that they communicate with their children about their safety online. Minors who are using any Interactive Service should be made aware of the potential risks to them.

4.10 You can request us to remove your User Generated Content at any time. Please note that “removal” of User Generated Content means only that it will not be visible to other users via the Website, except for those User Generated Content that have already been viewed by other users and retained by them on their respective devices. All User Generated Content, whether removed or not, are retained by us and are subject to our data retention policies as they may be updated. Notwithstanding any removal of your User Generated Content from the Website, you agree that our license to your User Generated Content shall continue perpetually as specified above.

Viruses

4.11 We do not guarantee that the Website will be totally secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programmes and platform in order to access the Website and we recommend that you use your own virus protection software.

4.12 You must not misuse the Website by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Website, the server on which the Website is stored or any server, computer or database connected to the Website. You must not attack the Website via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Website will cease immediately.

5. Activity Center

5.1 In addition to features and services that are designed for professionals, educators, parents and caregivers, the Website also offers certain features designed to be used by children of all ages, including children under the age of 13 (the “Activity Center”). The performance information of an individual child that is completing learning activities in the Activity Center will be retained and linked to that child’s profile to allow the tracking of his or her progress.

5.2 Children may access the Activity Center only if they are first registered and issued a unique ID and password either: (a) by a customer organization that has lawful authority to designate the child as a child-user of the Website, or (b) with the express, prior consent of the child's parent or guardian. At all times, you may request that we remove the child's access to the Activity Center.

5.3 Use of the Activity Center. Use of the Activity Center by anyone younger than 18 is permitted only under the supervision of a designated representative of a customer organization, a parent or legal guardian who agrees to be bound by the Terms.

6. Intellectual property

6.1 We are the owner or licensee of all intellectual property rights in the Website and its content, and the "Rethink", "Rethink First" and “Rethink Benefits” names and marks. Those works are protected by intellectual property laws and treaties around the world. All such rights are reserved.

6.2 You are not granted any right to use, and may not use, any of our intellectual property rights other than as set out in these Terms. You must not use the Website (or any part of it or its content) for commercial purposes; however, you may download material from the Website solely for non-commercial, personal use by you.

6.3 No part of the Website, including, without limitation, the text, designs, graphics, photographs and images contained in it, may be copied, reproduced, republished, uploaded, re-posted, modified, transmitted or distributed or otherwise used in any way for any non-personal, public or commercial purpose without our prior written consent.

6.4 Any communications or materials you send to us through the Website by electronic mail or other means will be treated as non-proprietary and non-confidential. We are free to publish, display, post, distribute and otherwise use any ideas, suggestions, concepts, designs, know-how and other information contained in such communications or material for any purpose, including, but not limited to, developing, manufacturing, advertising and marketing us and our services.

7. Our liability

7.1 Nothing in these Terms excludes or limits our liability for:

7.1.1 death or personal injury caused by our negligence;

7.1.2 fraud or fraudulent misrepresentation; and

7.1.3 any matter in respect of which it would be unlawful for us to exclude or restrict our liability.

7.2 If we fail to comply with these Terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breach of these Terms or our negligence, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if it was an obvious consequence of our breach or if it was contemplated by you and us at the time that you accessed the Website.

7.3 Nothing in these Terms affects your statutory rights. Advice about your statutory rights is available from your local Citizens' Advice Bureau or Trading Standards Office.

7.4 We only supply the Website for domestic and private use. You agree not to use the Website, or any content on the Website, for any commercial or business purposes and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

7.5 We assume no responsibility for the content of websites linked to from the Website (including links to partners). Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.

7.6 This Website does not provide medical advice. This Website is not intended to constitute: (a) the practice of medicine or the provision of health care diagnosis or treatment; (b) the creation of a physician patient or clinical relationship; or (c) an endorsement, recommendation or sponsorship of any medical product or service by us or any of its officers, directors, employees, agents, representatives, affiliates or providers. Additionally, this Website should not be used to attempt to diagnose a medical condition, or to attempt to assess the stage or other medical aspect of any person diagnosed with a medical condition. All content on this Website is provided for informational purposes only. This content is not intended to substitute medical professional advice. You should consult a medical professional with any questions you may have regarding a medical condition or treatment. Do not delay seeking advice from a medical professional because of content received from this Website. We provide this information on this Website for educational purposes only. Do not use the Website for emergency medical services. In an emergency, call 911, your local emergency assistance number and/or your personal doctor.

8. Suspension and termination

8.1 If you breach any of these Terms, we may immediately do any or all of the following (without limitation):

8.1.1 issue a warning to you;

8.1.2 temporarily or permanently remove any User Generated Content uploaded by you to the Website;

8.1.3 temporarily or permanently withdraw your right to use the Website;

8.1.4 suspend or terminate your Account;

8.1.5 issue legal proceedings against you for reimbursement of all costs resulting from the breach (including, but not limited to, reasonable administrative and legal costs);

8.1.6 take further legal action against you; and/or

8.1.7 disclose such information to law enforcement authorities as we reasonably feel is necessary to do so.

8.2 We make the Website available to you pursuant to an agreement between us and your employer. If that agreement expires or terminates for any reason, we will terminate your access to the Website.

9. Changes to these Terms

9.1 We may make changes to these Terms from time to time (if, for example, there is a change in the law that means we need to change these Terms). Please check these Terms regularly to ensure that you understand the Terms that apply at the time that you access and use the Website.

10. Other important information

10.1 Each of the clauses of these Terms operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining clauses will remain in full force and effect.

10.2 If we fail to insist that you perform any of your obligations under these Terms, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. If we do waive a default by you, we will only do so in writing, and that will not mean that we will automatically waive any later default by you.

10.3 If you wish to have more information on online dispute resolution, please follow this link to the website of the European Commission: http://ec.europa.eu/consumers/odr/. This link is provided as required by Regulation (EU) No 524/2013 of the European Parliament and of the Council, for information purposes only. We are not obliged to participate in online dispute resolution.

11. Governing law and jurisdiction

11.1 You can bring proceedings in respect of these Terms in the New York courts. However, as a consumer, if you live in a European Union member state then you can bring legal proceedings in respect of these Terms in either the New York courts or the courts of that Member State.

11.2 As a consumer, if you are resident in the European Union and we direct this Website to the member state in which you are resident, you will benefit from any mandatory provisions of the law of the country in which you are resident. Nothing in these Terms, including clause 11.1, affects your rights as a consumer to rely on such mandatory provisions of local law.

12. Contacting us

Should you have any reasons for a complaint, we will endeavour to resolve the issue and avoid any re-occurrence in the future. You can always contact us by using the following details:

Address: Rethink Autism Inc., 19 West 21st Street, Suite 403, New York, NY 10010

Email address: support@rethinkfirst.com

Thank you.

Terms last updated August 31, 2018

COPYRIGHT POLICY
Rethink , Inc. ("Rethink", “we”, “our” us”) respects intellectual property rights of others and desires to offer a Site that contains content that does not violate those rights. The Rethink TOU require that information posted by users be accurate, lawful and not in violation of the intellectual property rights of third parties. To promote these objectives, Rethink provides a process for submission of complaints concerning Submissions by users. Rethink’s policy and procedures are set forth in the sections that follow.

Rethink’s policy is to promptly respond to clear notices of alleged infringement that comply with the United States Digital Millennium Copyright Act (DMCA) (17 U.S.C. § 512) the text of which can be found at the U.S. Copyright Office Website (http://www.copyright.gov). This page sets forth the information that should be included in such notices. It is designed to make submission of notices and counter notices more straightforward while reducing the number of fraudulent notices or notices that are difficult to understand or verify.

Prior to serving either a notice of infringing material or counter notification, you may wish to contact a lawyer to better understand your rights and obligations under the DMCA and other applicable laws. The following notice requirements are intended to comply with Rethink’s rights and obligations under the DMCA, and do not constitute legal advice to you.

We expect our users to comply with applicable laws. If, however, we receive proper notification of claimed infringement, our response to such notices may include removing or disabling access to materials at issue and/or terminating users’ accounts, regardless of whether we may or may not be liable for such infringement under United States law or the laws of another jurisdiction.

If we remove or disable access in response to such a notice, we will make a good-faith attempt to contact the person who placed the materials at issue on our site so that they may make a counter notification under the DMCA.

INFRINGEMENT NOTIFICATION

Upon receipt of proper notification of claimed infringement, Rethink will follow the procedures outlined herein and in the DMCA.

To file a notice of infringement with Rethink, you must provide a written communication (by fax, regular mail or email) that sets forth the information specified below. Please note that you will be liable for damages (including costs and attorney's fees) if you misrepresent or provide fraudulent statements that the material or any activity is infringing your copyright(s). Accordingly, if you are not sure if you are the proper copyright holder or if copyright laws protect your materials, you may want to consult a lawyer.

To expedite our ability to process your request, please use the following format (including section numbers) and provide:

Title: Notice of Copyright Infringement

1. Reasonably sufficient detail to enable us to identify the copyrighted work claimed to be infringed. (For example, "The copyrighted work at issue is the "name of the work" by "name of the author");

2. Reasonably sufficient detail to enable us to identify and locate the material that is claimed to be infringing (e.g. a link to the page containing the material or the URL);

3. Information reasonably sufficient to permit Rethink to contact the complaining party, such as a name, an address, telephone number and an email address;

4. The following statement: "I have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law";

5. The following statement: "I swear, under penalty of perjury, that the information in the notification is accurate, and that I am the copyright owner or am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed"; and

6. Sign the document.

7. Send the written communication to:

Rethink , Inc. Attn: Copyright Agent 19 West 21st Street, Suite 403 New York, NY 10010 OR fax to: (646) 257.2926 Attn: Rethink , Inc. Copyright Agent OR email to support@rethinkfirst.com

COUNTER NOTIFICATION

The provider of an allegedly infringing content, whose material has been taken down or has been notified that an infringement claim has been made against such material, may make a counter notification pursuant to the DMCA. To file a counter notification with Rethink, you must provide a written communication (by fax, regular mail or email) that sets forth the information specified below. Please note that you will be liable for damages (including costs and attorneys' fees) if you misrepresent or provide fraudulent statements that the material or any activity is not infringing the rights of others. Accordingly, if you are not sure that you are the proper copyright holder or if copyright laws protect your materials, you may want to consult a lawyer. When we receive a counter notification, we may reinstate the material in question.

To expedite our ability to process your request, please use the following format (including section numbers) and provide:

Title: Counter-Notice regarding Claim of Copyright Infringement

1. Reasonably sufficient detail to enable us to identify the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled;

2. Information reasonably sufficient to contact you including your name, an address, telephone number and an email address;

3. The following statement: "I consent to the jurisdiction of Federal District Court for the [insert the federal judicial district in which your address is located]" (or The Southern District of New York if your address is outside of the United States);

4. The following statement: "I will accept service of process from [insert the name of the person who submitted the infringement notification] or his/her agent";

5. The following statement: "I swear, under penalty of perjury, that I have a good faith belief that the affected material was removed or disabled as a result of a mistake or misidentification of the material to be removed or disabled"; and

6. Sign the document.

7. Send the written communication to:

Rethink , Inc. Attn: Copyright Agent 19 West 21st Street, Suite 403 New York, NY 10010 OR fax to: (646) 257.2926 Attn: Rethink , Inc. Copyright Agent OR email to support@rethinkfirst.com

CLAIMS REGARDING CONTENT AND INTELLECTUAL PROPERTY VIOLATIONS (OTHER THAN COPYRIGHT INFRINGEMENT)

To notify Rethink that you in good faith believe that content posted by a user on the Site infringes your intellectual property rights (other than copyright) or is inaccurate or unlawful please follow the process set forth above for copyright infringement, and modify the title of your notice to Rethink to read: “Notice of Content/Intellectual Property Violations.”

If you believe the Notice Of Content/Intellectual Property Violations was submitted in error, or if you contest the removal of the allegedly infringing, inaccurate or unlawful content, you may follow the process set forth above for copyright infringement counter claims and modify the title of you notice to Rethink to read: “Counter-Notice Regarding Claim of Content/Intellectual Property Violations.”

REPEAT INFRINGERS

Rethink may, in appropriate circumstances, disable and/or terminate the accounts of users who are repeat infringers.

Effective Date

This version of the Copyright Policy is effective as of December 1, 2014.

PRIVACY POLICY

The mission of Rethink Autism, Inc. and its current or future affiliates (“Rethink”, “Rethink First”, “Rethink Benefits”, “Rethink Ed”, “Rethink Behavioral Health”, “we”, “our”, “us”) is to offer parents and professionals immediate access to effective and affordable treatment tools for individuals with special needs.

Taking part in our program, utilizing our assessment and training modules and data gathering, tracking and reporting services as well as other activities and services means sharing information about yourself, your child, your family or about individuals under your treatment or supervision (“you”, “your”).

Your privacy is important to us. This Privacy Policy explains how Rethink collects, uses, shares and protects any personally identifiable information you may provide to us via our websites.

Residents of the European Union. For residents within the European Union, by using this Site and/or the Services and providing us your personally identifiable information, you explicitly acknowledge and agree to the transfer of your personally identifiable information to the United States. Please see Rethink’s General Data Protection Regulation (GDPR) Privacy Policy. Rethink GDPR Privacy Policy

I. COLLECTION OF PERSONAL INFORMATION

Access. Currently, you are not required to provide any personally identifiable information in order to gain access to the public, non-password protected portion of the Site. To obtain access to the private portion of the Site and to use certain features provided by Rethink via such private portion of the Site, you are required to register as a user and create a user profile. Access to the private portion of the Site requires use of valid ID and password.

User Profile. Your Rethink Site account may be created directly by you, or at your request, initially set up by a Rethink administrator (“User Profile”). During registration you will be prompted to provide information such as your name, address and email address. A Rethink administrator may set up the account, pursuant to a contract with its customers who are organizations including but not limited to schools, school districts, or any of their providers, in which case, your User Profile may include information provided to Rethink by the applicable organization.

Child Profile. The Site allows you to create a profile of your child or a child you are treating or supervising (“Child Profile”). You will be prompted to provide information related to such child such as name, date of birth, and gender. In addition, you will be required to choose an educational classification (e.g. Autism, Asperger’s Syndrome, Childhood Disintegrative Disorder, Rett’s Disorder, Pervasive Development Disorder, etc.), to assess the overall language ability of the child and to identify areas of concern. At your choice, you can also upload a photo of the child.

Communications with Rethink. Whenever you communicate with us, whether via initial registration on the Site, or for any other reason via email or via features of the Site, the information we collect from you (e.g. your name, address, email) is added to our electronic mailing list.

II. METHODS OF DATA COLLECTION

Cookies. Like most websites, we utilize “cookies” to, among other things, track usage and trends, allow you to navigate quickly through our Site, facilitate the login processes, allow you to personalize your experience, store your settings and improve the quality of our Site. We also use cookies to collect Site usage information, which helps us improve our Site experiences by measuring which areas are of greatest interest to users. We do not store unencrypted personally identifiable information in the cookies.

Cookies are small strings of data that are sent by the Site to your browser and then stored by your browser on your computer’s hard drive, mobile phone, or other device, and allow us to recognize you as a user when you return to the Site using the same device and web browser. Most web browsers automatically accept cookies, but it is possible to change your browser setup or apply other means so that it does not accept cookies. However, rejecting cookies may prevent you from taking advantage of certain portions or functionality of the Site.

We use “session” cookies. Session cookies are used to identify a particular visit to the Site and expire after the elapse of a set period or when you close your web browser. We may use different technologies to place such cookies.

Log files, Java Script, Analytics and other Tracking Information. Adoption of communications standards on the internet and use of standard analytical tools results in or may lead to the automatic receipt and tracking of (i) the URL of the website from which you came and the website to which you are going when you leave the Site; (ii) your computer operating system and type of web browser you are using; (iii) email patterns; (iv) your mobile device (including your UDID) and mobile operating system (if you are accessing the Site using a mobile device).

We may also include web beacons and cookies and other tracking technologies in our e-mail messages, including newsletters, to, among other things, determine how many e-mail messages have been opened.

III. USE OF PERSONAL INFORMATION

HIPAA and FERPA Compliance. Rethink is committed to full and complete compliance with the rules and regulations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g and its promulgating regulations, 34 CFR Part 99 (collectively, “FERPA”) as applicable. Accordingly, we will use Protected Health Information (PHI) and Student/(Child) Personally identifiable information (Student/Child PII) that we are granted access to only for the purposes for which we have been contracted. As necessary, we will adjust our policies to adhere to our customers' needs and to adjust to any changes in the HIPAA and FERPA rules.

Your Use of Personal Information. The features available on the private portion of the Site are designed specifically to collect data that is linked to the personally identifiable information. For example, certain features may collect information about a child’s performance of assigned tasks and link such information to the Child Profile to allow the tracking of the child’s progress. Other features may collect data on individual teachers and whom they teach or on trainee teachers and the milestones they achieve in their certification process. Rethink’s individual and organization customers may use this information in any manner they choose to accomplish their own goals and missions.

Sharing of Information by You. You may store information in the private portion of the Site in a designated “file cabinet” which is linked to your User Profile and associated with the Child Profile(s) that you created. Rethink will provide access to such file cabinet solely to you, but will enable you to designate and permit others to access and share the “file cabinet”. While Rethink will take all reasonable steps to protect the privacy of information stored in a “file cabinet”, any content you upload to your file cabinet and any sharing of such information with others is at your own risk.

Your Interactions with Other Users. Certain features on the Site provide you with an opportunity to interact with other users. Such interactive features may include discussions and comments on topics of interest. When you use such features you should be aware that any information you include, is made publicly available to others. We are not responsible for any information you choose to communicate or submit through these interactive features.

Rethink Use of Personal Information. We collect, retain and use personally identifiable information or other information you provide to us via the Site for legitimate business purposes only, including without limitation in the following ways: (a) to qualify you as a registered user with access to the password-protected portion of the Site; (b) to provide services to registered users and to otherwise operate the Site; (c) to respond to an inquiry from you or address a request submitted by you (including contacting you directly to request additional information to process your inquiry or request; (d) to contact you and provide you information regarding Rethink and/or our business partners and affiliates; (e) to notify you about your accounts or transactions with us and to otherwise contact you with information we believe is of interest to you; (f) to correspond with you about our features or services or special offers related thereto; (g) to facilitate the payment of any fees necessary to access the services; (h) to enhance or develop the Site, and the features and services; (i) to monitor the usage of the Site and any services and features offered; (j) to provide third parties with aggregate anonymous non-personal information about our user base and usage patterns; (k) to personalize the features and services; (l) to comply with applicable laws, regulations and rules, and requests of relevant regulatory and law enforcement and/or other governmental agencies; (m) to enforce our TOU; and/or (n) to protect the rights, property, or safety of Rethink, our personnel, users, and others.

We may use the email address you provide to us to send you notifications, updates, newsletters or information regarding our Site and any features or services.

Sharing of Information by Rethink. We do not sell or rent your personally identifiable information to third parties. We may share your information only with our affiliates, business partners or third party service providers to provide you with the features and services on the Site. For example, we may hire or collaborate with a third party company to help manage emails, and for that purpose we may provide them with your email address and certain other information in order for them to send you an email messages on our behalf. Similarly, we may hire companies to host or operate some of our websites and related computers and software applications. Each third party service provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved in order to protect your personally identifiable from unauthorized access, use, or disclosure. Service providers are prohibited from using personally identifiable information other than as specified by us.

Pursuant to our contracts with certain customers that are organizations, such as schools and school districts, Rethink may collect data from designated student users and their teachers, school administrators and parents. Such data will be linked to personally identifiable information of the User Profiles and the Child Profiles that relate to such organization and pursuant to the contracts, will be made available to the customer organization. If you are accessing our Site pursuant to an authorization or approval by one of our customer organizations and you have questions about how such customer uses your personally identifiable information, you should contact that customer organization directly.

Further, pursuant to our contracts with certain customers that are organizations, such as schools and school districts, we may transmit and reformat personally identifiable information including User Profiles and Child Profiles and other related data collected via the Site, to Individual Education Plan (IEP) providers that are identified by the applicable organization as its service providers. The transmission of such data will be performed via an API or other secure technology.

We may share aggregate, anonymous statistical, non-personal information regarding the users of the Site, traffic patterns, and Site usage with our affiliates or business partners.

We will disclose information we maintain, including personally identifiable information, when required to do so by law, or may disclose such information in response to a request from a law enforcement agency or authority.

Payment Information. If you choose to subscribe to the Services through the Site you will be required to provide a mailing address, billing address, credit card number, and/or other payment information necessary to facilitate the payment, all of which will remain private and not become visible to other users. Credit cards processing is performed by a third party service provider and Rethink does not retain your financial information.

Links to Other Sites. The Site may contain links to third party websites that allow users the ability to download or access software or content. Rethink neither controls nor endorses such third party websites, and has not reviewed or approved any content that appears thereon or the privacy practices of such third parties. Rethink shall not be held responsible for such third parties’ privacy practices. You should review the privacy policies posted on such third party sites.

Testimonials and Endorsements. If you provide any testimonials about or endorsements of the Rethink products or services we may post those testimonials and examples of endorsements you place in connection with our promotion of these features or services to others. Testimonials and advertisements may include your name and other personal information that you have provided.

Polls and Surveys. We may conduct polls and surveys either directly or through third parties. Your selection may be random, or it may be based on your non-personally identifiable information, such as geographic location, school district, etc. Your participation in a poll or survey is voluntary. Rethink or its third party service providers may target some advertisements or incentives to you based on polls or survey results. If the delivery of incentives requires your contact information, you may be asked to provide personally identifiable information to the third party provider fulfilling the incentive offer, which will only be used for the purpose of delivering incentives and/or verifying your contact information. Taking advantage of such incentives and providing such information is voluntary and at your sole discretion.

IV. PERSONAL INFORMATION OF CHILDREN

Age of Users. The public portion of the Site is open to non-registered users, for which we neither require nor ask for personally identifying information. With the exception of the Activity Center (as detailed below), the private portion of the Site and any features and services offered as part of it, are intended solely for users who are eighteen (18) years of age or older and who are not considered to be minors in their state or country of residence. We do not intend to collect personally identifiable information from anyone we know to be under 18 years of age.

Activity Center. In addition to features and services that are designed for educators and parents, the private portion of our Site also offers certain features designed to be used by children of all ages, including children under the age of 13 (“Activity Center”). The performance information of an individual student/child that is completing learning activities in the Activity Center will be retained and linked to the Child Profile of that student/child to allow the tracking his or her progress.

Access to Activity Center. Children may access the Activity Center only if they are first registered and issued a unique ID and password either (i) by a customer organization that has lawful authority to designate the child as a student-user of our Site, or (ii) with the express, prior consent of the child's parent or guardian. At all times, you may request that we remove the child's access to the Activity Center.

Use of the Activity Center. Use of the Activity Center by anyone younger than 18 is permitted only under the supervision of a designated representative of a customer organization, a parent or legal guardian who agrees to be bound by the TOU.

Personally Identifiable Information. We do not require or ask children to divulge any personally identifying information as part of the Activity Center or any other parts of the Site. If we become aware that a child under 18 has provided or attempted to provide us with personal information, we will use our best efforts to remove the information permanently from our files.

Questions. If you have any questions about children privacy protection please reach out to us at: Rethink Autism, Inc., 19 West 21st Street, Suite 403 New York, NY 10010, P: (877) 988.8871, F: (646) 257.2926,  privacy@rethinkfirst.com

V. RETENTION OF PERSONAL INFORMATION

Storage. Your personally identifiable information may be stored and processed in the United States or any other country where Rethink may have facilities and/or servers. By using the Site or any of our features and services, you consent to the transfer of your personally identifiable information outside of your country of residence. We will endeavor to adhere to the principles set forth in this Privacy Policy, regardless of whether information is collected, transferred or retained in countries or jurisdictions that do not require a similar level of protection of your personally identifiable information. We will retain your personally identifiable information for as long as necessary to: (i) permit us to use it for the purposes that we have communicated to you; (ii) comply with our legal obligations, resolve disputes and enforce the TOU; and (iii) comply with applicable laws, rules or regulations.

Security. Rethink employs reasonable security systems, procedures, and practices appropriate to the nature of the covered information to protect the personally identifiable information we receive from you from unauthorized access, destruction, use or disclosure. Access to your data on the Site is password-protected, and sensitive data (such as credit card information) is protected by TLS encryption when it is exchanged between your web browser and the Site. Please be aware that Internet data transmission is not always secure and we cannot warrant that information you transmit utilizing the Site may not be intercepted, accessed, disclosed, altered, or destroyed by breach of any of our safeguards. Because security is important to both Rethink and you, we will always make reasonable efforts to ensure the security of our systems, however it is your responsibility to protect the security of your login information. If you suspect unauthorized access to your information, it is your responsibility to contact Rethink immediately. Please note that emails, messaging features, and similar means of communication with other users are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

VI. YOUR INFORMATION CHOICES

Modification. We strive to maintain the accuracy of any personally identifiable information that may have been collected from you, and will use our commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is inaccurate. It is your responsibility to ensure that such information is accurate, complete, and up-to-date. You may review and update personally identifiable information that you have provided to us at any time by signing in and visiting your User Profile.

Termination. You may withdraw your consent to the collection and processing of your information at any time, by terminating the TOU in accordance with its terms, but please note that your withdrawal of consent will not be retroactive such that information that you publicly posted, or that you shared with others, or that others have downloaded or copied onto their computer or devices may be not be eliminated. Upon termination of the TOU we will eliminate the information you supplied to us, provided that we may keep a copy of it in our archives for uses documented in this Privacy Policy and the TOU or for regulatory and compliance purposes.

Opt Out/Unsubscribe. You may opt out of or unsubscribe from receiving certain communications from us and our affiliates by following the opt-out/unsubscribe link provided in any email received from us or by emailing us at support@rethinkfirst.com. Please be aware that we will process your request as quickly as we reasonably can, but it may not be possible to update our systems immediately.

VII. MISCELLANEOUS

Use Signifies Assent. By providing information for the purpose of creating your User Profile and Child Profile and other data you input via the Site, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy that allow Rethink to collect, process and control information about you and use and share it as set forth herein.

Changes to Privacy Policy. We may, at our sole discretion, change, modify, add, or delete portions of this Privacy Policy at any time. If any material term of this Privacy Policy is changed, we will revise this Privacy Policy to reflect such change and provide you with appropriate notice and choices. You may always visit this policy to learn of any changes and updates. In the event we modify this Privacy Policy, such modified version shall be effective upon posting. We will indicate at the bottom of this Privacy Policy the date this Privacy Policy was last revised.

Business Transfer. Rethink may, in the future, disclose or otherwise transfer some or all of its assets including your personal information and other information you provide to another third party as part of a sale (actual or negotiated) of the assets of Rethink, its affiliates, a subsidiary or division or as the result of a change of control (actual or negotiated) of Rethink or its affiliate. Any third party to which Rethink transfers or sells the assets as set forth in the foregoing sentence, will have the right to continue to use the personal and other information that you provide to Rethink.

Questions, Comments and Concerns  Please address any questions, comments or concerns about our Privacy Policy to privacy@rethinkfirst.com

Effective Date This version of the Privacy Policy is effective as of June 3, 2018.

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