Please note that we have updated terms relating to your text and email communications from Rethink.


  • 1.1. Rethink Autism, Inc. (“Rethink”) and its operating division, Rethink Benefits, operate the website www.rethinkbenefits.com (“Website”) and the Rethink Benefits mobile App (“App”). The Website and the App and related technologies, applications and communication media are referred to collectively as the “Service”.
  • 1.2. The mission of Rethink is to offer parents, caregivers and professionals access to effective and affordable treatment tools (“Tools”) and related content (“Content”) for individuals with special needs via the Service.


  • 2.1. This is a binding agreement. These terms are a binding agreement between you and us. We are willing to provide the Service to you only on the condition that you first accept these Terms. When you click through these terms (e.g. on the “I agree” or a similar button or check box), or when you otherwise access or use the service, you signify to us that you have read, understand and agree to be bound by the terms, whether or not you are a registered user. IF YOU DO NOT AGREE TO THESE TERMS, YOU MAY NOT ACCESS OR USE THE SERVICE.
  • 2.2. Use of defined terms. These terms of use (“Terms“) describe how you may access and use the Service. Certain words and phrases that are used in these Terms are defined and have specific meanings. You can identify them as they start with capital letters, they are included in quotation marks and often appear in parenthesis. In these Terms, when we refer to “we”, “us” or “our”, we mean Rethink; and when we refer to “you” or “your” we mean you, the person accessing or using the Service.
  • 2.3. The structure of these Terms. When we refer to the “Terms” we also include the Rethink Privacy Policy that explains how we use your personal information and the Rethink Copyright Policy that explains how we handle copyright issues. These documents together comprise the entire agreement between you and us, they are binding and supersede any prior agreements or understandings between you and us. In the event of a conflict between any of these documents, the Terms will prevail.
  • 2.4. We may modify these Terms. We reserve the right to change all or any part these Terms and will notify you if any material term is changed. Our changes will become effective when we notify you, or when we post the change. If you continue using the service following such change, you are indicating your agreement to it. IF YOU DO NOT AGREE TO SUCH CHANGE YOU MUST STOP USING THE SERVICE.
  • 2.5. Our agreement with your organization allows you to use the Service. Your access to the Service is made available through an organization (including its sub-organizations or affiliated organizations) that employs, engages you or is otherwise affiliated with you (collectively “Organization”) which is our customer and with which we have a separate agreement for your access and use (“Organization Agreement”). If there is any conflict between the Organization Agreement and these Terms, the Organization Agreement will prevail. Notwithstanding the Organization Agreement, you are required to comply with all obligations and standards described in these Terms. Note that your Organization may require us to establish general practices and limits applicable to your use of the Service.
  • 2.6. Supplemental terms that may apply to your use of the Service. Some Services, Tools or Content may have additional supplemental terms, conditions and restrictions associated with them, including terms imposed by third-party providers which are or will be posted on those pages from which they may be accessed (collectively “Supplemental Terms”). You agree that all such Supplemental Terms will apply to your access and use of the applicable Service, Tools and Content and that, if they conflict these Terms, the Supplemental Terms will control with respect to such Service, Tools or Content.
  • 2.7. We may change the Service. We may at any time and in our sole discretion change, modify, add, eliminate or discontinue the Service and any Tools and Content. Any material changes will be communicated to you and become effective following such communication.
  • 2.8. We may require additional written confirmation of these Terms. We may, from time to time, request that you confirm, including in writing, your agreement to and compliance with any part of the Terms as a condition to your continued access to and use of the Services.


  • 3.1. Non-Registered Users. You do not need to be a registered user to access the public portion of the Service and we do not require you to provide any personally identifying information.
  • 3.2. Registered Users. We offer a wealth of Tools and Content through the non-public, password-protected portion of the Service and require that you register and create a user ID and password as part of our security procedures (“User Account”). Such Content and Tools are available only to registered users who are 18 years of age or older, except with respect to the Activity Center (as detailed in Section 9).


  • 4.1.Your User Account credentials. The credentials of your User Account enable you to access and use the Service from any location worldwide. When creating a User Account you will be prompted to provide information, including personally identifiable information; please check the Rethink Privacy Policy to see how we collect, use and protect such information.You agree:
    • to provide accurate, current and complete information about you;
    • not to register on behalf of an individual other than yourself;
    • not to register on behalf of any group or entity unless you are authorized by them to do so;
    • not to use another user’s account;
    • to maintain the confidentiality and security of your password and user ID.
  • 4.2. You are responsible for the use of your User Account. You are fully responsible for any and all use of your User Account and for any and all activities that occur using your password or user ID, whether or not such use is authorized by you. If you know or suspect that anyone other than you knows your User Account login details, you must immediately notify us at privacy@rethinkfirst.com.
  • 4.3.Setting up a Child Profile. You may create a profile of your child or a child under your care or supervision (“Child Profile”). When creating a Child Profile you will be prompted to provide information, including personally identifiable information such information is not required, however, and it is solely up to your discretion to provide it. Please check the Rethink Privacy Policy to see how we collect, use and protect such information.
  • 4.4.Setting up and enabling text messaging features. The Service provides, or may in the future provide, certain Tools and delivery of Content via text messages (e.g. scheduling tools). If you would like to utilize such Tools and Content, you will need to expressly consent by checking a designated box in the User Account form when you sign up for the Service, to receive text messages communication (non-marketing and marketing). You represent that you are the account holder for the mobile telephone number(s) that you provide. You are responsible for notifying us immediately if you change your mobile telephone number. To stop text messages, you will need to change the setting of your User Account and opt-out from the text messaging feature. You further agree that:
    • We or any of our service providers may utilize an automatic telephone dialing system (“autodialer”) to deliver text messages to the mobile phone number associated with your Account that you designated for text messages. We may include marketing content in any such messages.
    • The number of text messages that you receive will vary depending on how many of Rethink’s text messaging programs for which you sign up to receive messages.
    • Message and data rates may apply to each text message sent or received in connection with our text messages, as provided in your mobile telephone service rate plan, in addition to any applicable roaming charges. We do not impose a separate fee for sending text messages.
    • The use of any of text message is limited to 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.


  • 5.1.Your use is conditioned on your compliance with these Terms. You may access and use the Service only subject to and in accordance with these Terms, including without limitation the prohibitions below.
  • 5.2.Misuse of the Services is prohibited. You must not misuse the Service or otherwise:
    • restrict, inhibit or otherwise interfere with the use of the Service, including, by means of “hacking” or defacing any portion of the Service or otherwise impairing or overburdening it;
    • modify, adapt, reverse engineer, decompile or disassemble any portion of the Service;
    • “frame” or “mirror” any part of the Service without our prior written authorization;
    • use any robot, spider, crawler, site search or retrieval application, or other manual process or automatic device or extraction tool or circumventing technology to access, monitor, copy, use, download, retrieve, index, extract, scrape, harvest, collect, data mine, disseminate, interact, overload, or in any way bypass any other protections of Rethink’s proprietary rights in the Service;
    • upload or transmit any materials that contain or embody a software virus, worm, cancelbot, Trojan horse or other harmful, contaminating or destructive feature, computer code, file or program; or
    • violate any local, state, national or international law, rule, regulation or order of any court.


  • 6.1.Uploading your materials to the Service. You may upload and store materials that are relevant and necessary for your use of the Service e.g. information, text, graphics, audio, video, images etc. (collectively, “User Materials“) in the File Cabinet or share them with other via interactive sharing and collaborative features that are or may be included in the Service. You agree to follow the Content Standards described below when uploading, storing, posting and sharing User Materials and to ensure that you have all the necessary legal rights and authority to do so and that you would not violate any law or the rights of any person or entity. The Service is not designed or intended to be used as part of a disaster recovery facility or an emergency data storage and therefore you are responsible for keeping backup copies of any User Materials you post or store on the Service. We will not be liable for damage to, deletion of, or failure to store, your User Materials.
  • 6.2. Setting up your File Cabinet. You may set up a “File Cabinet” which is linked to your User Profile and associated with any Child Profile(s) that you created. The File Cabinet is accessible only by you and any User Materials you input or upload to your File Cabinet remains private (“User Private Materials”.) You have the right to designate and permit others to access the “File Cabinet” at your own risk.
  • 6.3. Your use of interactive sharing features and User Public Materials. Depending on your Organization, you may be able interact and collaborate with other users from your Organization through interactive sharing and collaborative features that are or may be included in the Service. You should be aware that any User Materials you include in such interactions may be made publicly available to others within your Organization (“User Public Materials”). Also, please be aware that certain User Materials that you make public might, reveal health, gender, ethnic origin, age, or other personal identifiable information about you or a child under your care or supervision. We are not responsible for any User Materials you choose to make public.
  • 6.4. Our rights with respect to User Materials. As between us and you, all intellectual property rights in the User Materials are owned by you or your licensors. You grant us permission, to use, store and process your content in accordance with applicable law and agree that we may collect and use User Materials (i) in connection with the Service, (ii) to enforce our rights, and (iii) together with information related to your use of the Service to test, develop, improve and enhance the Service and our other products and services as long as such information is not identifiable to you. We may also pass this information to our third-party providers for the same purposes. We may retain the User Materials for the same purposes after you have ceased using the Service.
  • 6.5.Removal of User Public Materials. You can request at any time that we remove your User Public Materials. However, “removal” means only that they will not be visible to other users of the Service, except for those that have already been viewed and retained by such users on their devices. All User Public Materials submitted, 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 User Public Materials from the Service, you agree that your license to us in Section 6.4 shall continue after you have ceased using the Service.
  • 6.6.Content Standards. You must comply with the following rules and you agree that none of your User Materials will constitute, include or result in any of the following:
    • promotion of or incitement to hatred toward groups based on race or ethnic origin, religion, disability, gender, age, veteran status, or sexual orientation or gender identity;
    • pornography or pedophilia materials;
    • direct or veiled threats against any person or group of people or content that is otherwise harmful, abusive, offensive, harassing, derisive, tortuous or objectionable, including profanity, obscenity or vulgarity;
    • invasion of privacy or violation or disclosure of the private and proprietary and confidential information of any third party;
    • violation of any right of publicity;
    • impersonation of others in a manner that is intended to or does mislead or confuse others;
    • use for unlawful purposes or for promotion of dangerous and illegal activities;
    • advertising, spamming, solicitations, including, without limitation, junk mail, “chain letters” or “pyramid” schemes of any sort or invitations to participate in any of them;
    • libel or defamation;
    • expression, suggestion or implication that any statements you make are endorsed by us, without our prior written consent;
    • content that you either know or should know is false, deceptive or misleading, or misrepresents or deceives others as to the source, accuracy, integrity or completeness;
    • infringement of any intellectual property or other proprietary rights of any individual or entity; or
    • transmission of content which is prohibited under any law, rule, regulation or order of any court, or prohibited as a result of any employment, contractual, fiduciary or other legal obligation or relationship.
  • 6.7. Good Citizenship. When creating, storing and sharing User Materials and whenever you collaborate with other users, you agree to act in good faith, to the best of your ability, and in accordance with the Terms and applicable law. You agree that any User Materials and collaboration efforts 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 Service.
  • 6.8.We have no obligations to monitor or edit User Materials. We have no obligation to pre-screen or monitor any User Materials or to make sure they are in compliance with the Terms. Notwithstanding, we reserve the right, in our sole discretion and without further notice to you, to monitor, investigate, censor, edit, modify, move, delete, or remove any User Materials if we believe, that such modification or removal is necessary to:
    • satisfy any applicable law, rule, regulation, legal process, subpoena or governmental request;
    • enforce the Terms;
    • protect the rights, property or safety of Rethink, its third-party providers, its users and/or the public; and
      to maintain an environment of courteous, credible, responsible and open exchange of information.
  • 6.9. Minors are not allowed to use interactive sharing features. The use of any of our interactive sharing features by a minor is strictly prohibited.


  • 7.1.Direct purchases by you. We provide, or may in the future provide, you with an option to directly purchase from us additional access to certain Tools and Content via the Service.
  • 7.2.How we bill you. We will bill your credit card or debit card (collectively “Credit Card”) for all applicable fees in advance of Service delivery.
    • You will provide us with accurate and complete billing information, including your name, address, telephone number, and valid Credit Card information, and will promptly notify us of any changes in that information.
    • You acknowledge that the agreement between you and the applicable credit card issuer governs use of your credit card for payment of amounts owed to Rethink, including your rights and obligations as a holder of that card.
    • We will disclose the applicable payment options at the time you place your Order. We or our billing agent may charge your payment method for all amounts due to us without additional notice or consent unless otherwise required by law.
    • We may, in our discretion: (i) post charges to your payment method individually, or (ii) aggregate your charges with other purchases you make within the Services and apply those charges to your next billing cycle.
    • If we do not receive payment from your credit card issuer, upon demand you will pay all overdue amounts by other means acceptable to us.
    • Service purchases are nonreturnable and cannot be exchanged. Until your Service is terminated, you will continue to accrue charges for which you remain liable, even if you do not use the Service.
  • 7.3. We may post limited special or short-term promotions. Any pricing designated as “promotional”, “special”, “limited time only” or other short-term offer will remain in effect for the designated duration only and will be adjusted automatically to regular pricing at the conclusion of the designated time period. We reserve the right to change our pricing at any time. Separate terms and conditions may apply to promotional offers and discounts.
  • 7.4. Purchases may be subject to taxes. Your purchase may be subject to foreign exchange fees or differences in prices based on location (e.g. exchange rates) or other applicable taxes. Taxes are calculated based on the billing information that you provide us at the time of purchase.
  • 7.5. You may incur text messages related charges. You expressly agree that when sending and receiving text messages you may incur message and data charges under your wireless device plan.


  • 8.1. Our Intellectual Property. We are the owners of all of the Service and all Content and Tools including, but not limited to all, software, data, graphics, images, logos, audio, video, design, and any and all other features and elements, in any media or format, that are or may in the future become available through the Service, all of which are protected by United States and international intellectual property laws and other applicable laws.
  • 8.2. No right to use our trademarks and logos. The Rethink, Rethink First, and other Rethink names and logos (e.g. Rethink Autism, Rethink Benefits, Rethink Behavioral Health, Rethink Education & Rethink Ed) are service marks of Rethink (“Rethink Marks”). Rethink Marks may not be used in connection with any product or service that is not Rethink’s, in any manner that is likely to cause confusion among consumers, or to disparage or discredit Rethink.
  • 8.3. You have a limited right to download. You may download or use any interactive sharing feature of the Service to share insubstantial amount of general information from the Service, provided however, that you do it solely for your personal non-commercial use and that you include all copyright and other proprietary rights notices and attribution.
  • 8.4. How to request permission to use our content. If you would like to use any content from the Service that isn’t expressly permitted in these Terms, please contact us by writing to Rethink Autism, Inc. Attn: Copyright Agent, 49 West 27th Street, 8th Floor, New York, NY 10001.
  • 8.5. Reservation of rights by us. You are granted the right to use the Service and our intellectual property only as expressly described in these Terms and all rights we do not expressly grant to you, are specifically reserved to us.
  • 8.6.Your feedback to us. You acknowledge and agree that any questions, comments, suggestions, ideas, feedback, or other information submitted to us relating to modifying or improving the Services (“Feedback”), whether solicited or unsolicited, are non-confidential. We may use Feedback for any purpose, commercial or otherwise, without acknowledgment or compensation to you. You grant to us a worldwide, non-exclusive, royalty-free, perpetual, irrevocable, transferable, sublicensable license to use Feedback, and in the event perpetual license terms are not allowed by law, the term shall be for the longest period as allowed by applicable law.


  • 9.1. Activity Center. The non-public portion of our Service offers, or may offer, 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 that is completing learning activities in the Activity Center will be retained and linked to the Child Profile of that student to allow the tracking of his or her progress.
  • 9.2. Access to Activity Center. Children may access the Activity Center only if they are added to the User Account with the express, prior consent of the child’s parent or caregiver. At all times, you may request that we remove the child’s access to the Activity Center.
  • 9.3. Use of the Activity Center. Use of the Activity Center by anyone younger than 18 is permitted only under the supervision a parent or a caregiver who agrees to be bound by the Terms.
  • 9.4. Personally Identifiable Information. We do not require or entice children to divulge any personally identifying information as part of the Activity Center or any other parts of the Service. If we become aware that a child under 18 has provided or attempted to provide us with personal information in a manner not expressly authorized by the Rethink Privacy Policy or these Terms, we will use our best efforts to remove the information permanently from our files.
  • 9.5.Questions. Please defer to the Rethink Privacy Policy to see how we collect, use and protect personally identifiable information. If you have any questions about children’s privacy protection please reach out to us at: Rethink Autism, Inc., Attn: Data Protection Officer, 49 West 27th Street, Floor 8, New York, NY 10001, P: (888) 808.5455 or (646) 257-2919 ext. 800, F: (646) 257.2926, privacy@rethinkfirst.com.


  • 10.1.We have the right to terminate or suspend your User Account. If you breach any of these Terms we may, in our discretion. immediately do any or all of the following (without limitation):
    • issue a warning to you;
    • temporarily or permanently remove any User Generated Content uploaded by you to the Service;
    • temporarily or permanently withdraw your right to use the Service;
    • suspend or terminate your User Account;
    • issue legal proceedings against you for reimbursement of all costs resulting from the breach (including, but not limited to, reasonable administrative and legal costs);
    • take further legal action against you; and/or
    • disclose such information to law enforcement authorities as we reasonably feel is necessary to do so.
  • 10.2. Termination or expiration of the Organization agreement. We make the Service available to you pursuant to an Organization Agreement with your Organization. If that agreement expires or terminates for any reason, we will terminate your access to the Service.
  • 10.3. Violation of laws by you. Any unauthorized use of the Service, whether or not resulting in termination or suspension of your User Account, may also violate criminal laws and intellectual property laws in the United States and other countries, and we may cooperate with the applicable authorities by disclosing your identity to them.


  • 11.1. Liabilities that we cannot Limit. Nothing in these Terms excludes or limits our liability where it would be unlawful to do so, and nothing in these Terms affects any of your statutory rights.
  • 11.3. We do not offer medical advice. This Service does not provide medical advice. The service 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 Rethink or any of its officers, directors, employees, agents, representatives, affiliates or providers. Additionally, this Service 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 Service 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 Service. Rethink provides this information and content on this Service for educational purposes only. Do not use the Service for emergency medical services. In an emergency, call 911, your local emergency assistance number and/or your personal physician.
  • 11.4. We are not liable for user’s actions. We and our providers do not control and therefore, we do not assume responsibility for the actions of users on or off the Service. Rethink does not endorse, support, sanction, encourage, verify, or agree with facts, views, opinions, or statements contained in User Materials.
  • 11.5. We are not liable for third party websites and apps. The Service may contain links to third-party websites, products or services from other providers that may offer you the ability to download or access software, content, products or services. We and our providers do not control, endorse or sponsor and therefore are not responsible for such websites, content, products or services or any links or advertisements contained in such third-party websites.
  • 11.6. We make no additional promises. No opinion, advice or statement by us (including our officers, directors, employees, agents and affiliates) or by our providers or by any users, whether made on the Service, or related to it or otherwise, will create any representation or warranty or obligation under these Terms.
  • 11.7. Limitations on our liability. In no event shall we (including our officers, directors, employees, agents, representatives, affiliates and providers) be liable (jointly or severally) to you or any third party for damages of any kind, including, but not limited to, any indirect, special, incidental, exemplary, punitive or consequential damages, loss of profits, or damages for lost time or goodwill, business interruption, or loss of data, even if advised of the possibility of such damages, and regardless of the form of action, whether in contract, tort, strict liability or otherwise, arising out of or relating in any way to the availability or functionality of, use of, access to, reliance on the service, content, tools or any other information or materials offered via the service. Our liability (including its officers, directors, employees, agents, representatives, affiliates and providers) will not exceed, in the aggregate for all claims, the lesser of the: (i) annual amount, paid or payable by your organization pro-rated for your use of the service, and (ii) $1,000. These limitations do not apply when we are grossly negligent, act willfully or where we cause bodily injury. Some laws do not allow the limitation or exclusion of liability, so these limits may not apply to you.
  • 11.8. Your remedy is to stop using the Service. YOUR REMEDY FOR DISSATISFACTION WITH THE SERVICE IS TO STOP USING IT. Due to the unique mission of Rethink and the strong public interest in its continued operation, you agree that you will not seek any remedy designed to enjoin or restrain in any way Rethink or its operations, products or services.


  • 12.1. Your indemnification obligation to us. You agree to indemnify and hold us harmless (including our officers, directors, employees, agents, representatives and affiliates) and our providers, from and against any and all claims, damages, losses, costs (including reasonable attorneys’ fees), or other expenses that arise directly or indirectly out of or from: (a) your violation of the Terms, (b) unauthorized use of the by you or by any other person accessing it under your authorized access methods, (c) your violation of the rights, including without limitation, intellectual property and privacy rights of any third party, or (d) your Materials and Public Submissions. You agree to cooperate fully in any Rethink inquiry concerning actual, alleged, or potential violations of the Terms.


  • 13.1. Our copyright policy. It is our policy to respond to notices of alleged infringement that comply with the Digital Millennium Copyright Act. For more information about our policy, please see the Rethink Copyright Policy.


  • 14.1.What happens if we have a legal dispute.
    • We are based in New York State and therefore, the Terms are governed by and interpreted in accordance with the laws of the State of New York. These Terms are not governed by the United Nations Convention on Contracts for the International Sale of Goods or by the Uniform Computer Information Transactions Act, and both are expressly disclaimed.
    • In connection with any dispute or litigation arising out of or relating to the Terms, you consent to the exclusive jurisdiction and venue in New York State courts located in the County of New York, in the borough of Manhattan and in the federal courts located in the Southern District of New York.
    • If you are a consumer residing in a European Union member state, then you can bring legal proceedings in respect of these Terms, either in the New York courts or in the courts of the applicable member state. We will be allowed to bring action against you in any jurisdiction.
    • In addition, if you are a consumer residing in a European Union member state, you can obtain information on online dispute resolution at the following link of 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 any online dispute resolution.
  • 14.2. Circumstances outside our control. While we will endeavor to provide the Service to you, you understand and agree that delivery of Services may fail due to a variety of circumstances or conditions outside our control. For example, network services, including but not limited to mobile network services, are outside of our control, and therefore we are not responsible or liable for issues arising from them.
  • 14.3. Sections that survive termination of these Terms. All sections of the Terms which by their nature survive termination shall continue in full force and effect beyond any termination of the Terms, including, without limitation, all provisions which relate to disclaimers, limitation of liability, waiver and indemnification.
  • 14.4. Severability of terms. If one or more of the provisions of these Terms shall be held unenforceable by a court in any applicable jurisdiction respect, then such provision shall be deleted from the Terms to the minimum extent, and the remaining provisions will continue in full force and effect. Any such judicial interpretation requiring limitation or deletion of a provision shall be valid only in the jurisdiction in which such interpretation is made.
  • 14.5. Conduct does not waive rights. No waiver by us of any term or condition set out in these Terms shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition, and any failure by us to assert a right or provision under these Terms shall not constitute a waiver of such right or provision.


  • 15.1. How we will notify you of changes. Rethink may place a notice across its pages to alert you to certain changes such as material modifications to the Terms or the Service. Alternatively, notice may be in the form of an email, telephone or via postal services.
  • 15.2.Our Contact Information.
    • If you have any questions relating to the Terms, Service, Content, Tools or any products and services, please contact: info@rethinkfirst.com or write to our address below.
    • If you have any reason for a complaint, please contact support@rethinkfirst.com or write to our address below and we will endeavor to resolve the issue.
    • Our address is: Rethink First, 49 West 27th Street, Floor 8, New York, NY 10001. You agree that the only way to provide us legal notice is at the addresses provided above.
  • 15.3. Effective Date. This version of the Terms is effective as of May 28, 2019.


The mission of Rethink Autism, Inc. and its operating division Rethink Benefits (“we”, “our”, “us”) is to offer parents, caregivers and professionals access to effective and affordable treatment tools (“Tools”) related content (“Content”) for individuals with special needs.

Rethink Benefits, operates the website www.rethinkbenefits.com (“Website”) and the Rethink Benefits mobile App (“App”). The Website and the App, or any successor websites and apps, are referred to, collectively as the “Service”.

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 Service.

Capitalized terms used in this Privacy Policy that are not defined, shall have the meaning assigned to them in the Terms of Use.


The following supplemental disclosures apply to you if you reside and work, or if your employer is based, in a Member State of the European Economic Area or Switzerland:

  1. Data Controller Details. We are an independent data controller: Rethink Benefits, 49 West 27th Street, Floor 8, New York, NY 10001, USA. You can reach our Data Protection Officer at privacy@rethinkfirst.com and +1 646 257 2919 ext 800 or (888) 808-5455. Our representative in the EEA is MyEDPO Ltd, Unit 3d North Point House, North Point Business Park, New Mallow Road, Cork, Ireland, info@myedpo.com and +44 203 870 3376.
  2. Legal Bases for Processing. Legal bases for the processing of your Personal Data are your consent (Art. 6(1)(a) GDPR) and—when we use your data to improve and develop our services—our legitimate interests (Art. 6(1)(f) GDPR).
  3. Recipients in Third Countries. We are based in the United States, a country with respect to which the European Commission has not issued an unlimited adequacy decision. You have consented to the transfer of your Personal Data to us in the United States. You can request from us or from your Organization copies of the data protection-related terms in the applicable contracts, which contain appropriate safeguards for your Personal Data.
  4. Period of Data Storage. We will process your Personal Data only as is necessary to implement, administer and manage your participation in our programs or receive our services, plus a time period required to be stored for tax, audit and legal compliance for a legally prescribed time period thereafter, which is a minimum of 3 years after you stop using our services or terminate our direct relationship.
  5. Data Subject Rights. You have a right to request from us access to and rectification or erasure of your Personal Data, restriction of processing, data portability, and to lodge a complaint with a supervisory authority.

For complete information on our processing of your Personal Data, please consult the Rethink EEA-EU PRIVACY NOTICE


  • 1.1. Information collected to grant access to the Service. You are not required to provide any personally identifiable information in order to access the public portion of the Service. To obtain access to the non-public portion of the Service and to use Content and Tools provided by Rethink via such non-public portion of the Service, you are required to register as a user and create a user profile. Access to the non-public portion of the Service requires use of valid ID and password.
  • 1.2. Setting up a User account. During registration you will be prompted to provide information such as your name, address, email address and telephone number. Depending on our agreement with your Organization (“Organization Agreement”), a User Profile may also include information provided to us by the applicable Organization.
  • 1.3. Our Communications. Whenever you communicate with us, whether via initial registration via the Service, or via email, phone, text or other features of the Service, the information we collect from you (e.g. your name, address, email, telephone number) is added to our electronic communications list.


  • 2.1. Cookies.
    • We utilize “cookies” to, among other things, track usage and trends, allow you to navigate quickly through our Service, facilitate the login processes, allow you to personalize your experience, store your settings and improve the quality of our Service. We also use cookies to collect Service usage information, which helps us improve our Service 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 Service 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 Service 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 Service.
    • We use “session” cookies. Session cookies are used to identify a particular visit to the Service 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 Service; (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 Service 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.


  • 3.1. HIPAA and FERPA Compliance. We are 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.
  • 3.2. Your use of personal information. The features available on the non-public portion of the Service 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. You may use this information in any manner you choose to accomplish your own goals and missions.
  • 3.3. How you share your personal information. You may store information 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.
  • 3.4. Your interactions with other users. Depending on your Organization, you may be able interact with other users from your Organization through interactive sharing and collaborative features that are or may be included in the Service. 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 sharing and collaborative features.
  • 3.5. How we use your personal information. We collect, retain and use personally identifiable information or other information you provide to us via the Service for legitimate business purposes only, including without limitation, in the following ways to:
    • qualify you as a registered user with access to the password-protected portion of the Service;
    • provide Tools and Content to registered users and to otherwise operate the Service;
    • 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;
    • contact you and provide you information regarding Rethink and/or our business partners and affiliates and our and their respective products and services;
    • notify you about your accounts or transactions with us and to otherwise contact you with information we believe is of interest to you;
    • correspond with you about our features or services or special offers related thereto;
    • facilitate and streamline communications (e.g. email, text) taking place via the Service or as they pertain the Service;
    • facilitate the payment of any fees necessary to access certain aspects of the Service;
    • enhance or develop the Service, Tools and Content;
    • monitor the usage of the Service and any services and features offered;
    • to provide third parties with aggregate anonymous non-personal information about our user base and usage patterns;
    • personalize the features and services;
    • comply with applicable laws, regulations and rules, and requests of relevant regulatory and law enforcement and/or other governmental agencies;
    • to enforce our Terms; and/or
    • protect the rights, property, or safety of Rethink, our personnel, users, and others.
  • 3.6. How we share your personal information. We do not sell or license 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 of the Service. For example, we may hire or collaborate with a third party company to help manage emails or text messages, and for that purpose we may provide them with your email address and telephone number and certain other information, in order for them to send you email messages or texts on our behalf. Similarly, we may hire companies to host or operate some of our websites, mobile apps 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.
  • 3.7. We aggregate anonymous information. We may share, aggregate, anonymous statistical, non-personal information regarding the users of the Service, traffic patterns, and Service usage with our affiliates or business partners and with your Organization.
  • 3.8. Payment Information. We provide, or may in the future provide, you with an option to directly purchase from us additional access to certain Tools and Content via the Service. In order to purchase such additional access 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 we do not retain your financial information.
  • 3.9. We may share your personal information to comply with Laws. 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.
  • 3.10. We are not responsible for privacy practices of third-party websites. The Service may contain links to third party websites, products or services that may offer the ability to download or access software, content, products and services. We and our providers do not control, endorse or sponsor and therefore are not responsible for such websites and any content, products, services or any links or advertisement contained therein. We do not review or approve such third-party privacy policies and practices and will not be held responsible for them. You should review the privacy policies posted on such third-party websites.
  • 3.11. Your testimonials and endorsements of Rethink. If you provide any testimonials about or endorsements of our products or services we may post them 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.
  • 3.12. How we utilize 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, 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.


  • 4.1. Eligibility age of users. The public portion of the Service 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 non-public portion of the Service 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.
  • 4.2. Setting up a Child Profile. The Service 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 have the option to choose an educational classification (e.g. Autism, ADHD, Down syndrome, etc.), to identify areas of concern. At your choice, you can also upload a photo of the child. The Child Profile is linked to your “File Cabinet” which is accessible only by and others you have granted access to. You have the right to designate and permit others to access the “File Cabinet” at your own risk understanding they would have access to the child’s personally identifiable information.
  • 4.3. Activity Center.
    • The non-public portion of our Service offers, or may in the future offer, 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.
    • Children may access the Activity Center only if they are added to the User Account with the express, prior consent of the child’s parent or caregiver. At all times, you may request that we remove the child’s access to the Activity Center.
    • Use of the Activity Center by anyone younger than 18 is permitted only under the supervision a parent or a caregiver who agrees to be bound by the Terms.
    • 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 Service. 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., Atten: Data Protection Officer, 49 West 27th Street, 8th Floor, New York, NY 10001, P: (888) 808.9455 or (646) 257-2919 ext. 800, F: (646) 257.2926, privacy@rethinkfirst.com


  • 5.1. Storage of your personal information.
    • 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 Service 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 Terms; and (iii) comply with applicable laws, rules or regulations.
  • 5.2. Security measures we employ to protect your personal information.
    • We employ 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 Service is password-protected, and sensitive data (such as credit card information and health information) is protected by TLS encryption when it is exchanged between your web browser and the Service.
    • Please be aware that Internet data transmission is not always secure and we cannot warrant that information you transmit utilizing the Service may not be intercepted, accessed, disclosed, altered, or destroyed by breach of any of our safeguards.
    • Because security is important to both you and us, 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 us immediately. Please note that emails, messaging features, texting 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.


  • 6.1. 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.
  • 6.2. Termination. You may withdraw your consent to the collection and processing of your information at any time, by terminating your use in accordance with the 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, 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 Terms or for regulatory and compliance purposes.
  • 6.3. Opt out/unsubscribe. You may opt out of or unsubscribe from receiving certain communications from us and our affiliates and providers by following the opt-out/unsubscribe link provided in emails received from us or the opt-out method indicated in text messages received from us, or otherwise 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.


  • 7.1. Your use signifies your consent to this privacy policy. By providing information for the purpose of creating your User Profile and Child Profile and other data you input via the Service, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy that allow us to collect, process and control information about you and use and share it as set forth herein.
  • 7.2. How we may change this 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.
  • 7.3. Business Transfer. We may, in the future, disclose or otherwise transfer some or all of our 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.
  • 7.4. Questions, Comments And Concerns Please address any questions, comments or concerns about our Privacy Policy to privacy@rethinkfirst.com
  • 7.5. Effective Date This version of the Privacy Policy is effective as of May 28, 2019.