Privacy Policy

Dr. Matthew Polacheck Therapeutic Services , LLC (“Dr. Matt Polacheck”, also referred to as “we,” “us,” and “our”) understands the importance of protecting your personal information. This privacy policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide when you use this website or other online services we provide (collectively, the “Platform”), our practices regarding collection of your personal information, and how we will treat it.  We may change this Privacy Policy at any time or from time to time.  If we make any material changes to this Privacy Policy, we will notify you by posting an announcement on the Platform, emailing or texting you a notice, or by other appropriate means of communication.  Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates. 

This Privacy Policy does not apply to the collection and use of certain employment-related information. If you are a current or former LeashSpace job applicant, employee, owner, director, officer, or contractor, please contact us for the appropriate policy.

Table of Contents

Types of Personal Information We Collect

Collection of Personal Information

Information We Collect Through Automatic Data Collection Technologies

Use of Personal Information

Disclosure of Personal Information

Retention of Personal Information

Manage Your Personal Information

Your California Privacy Rights

Children’s Privacy

Data Security

Links to Other Websites

How We Use Cookies and Similar Technologies

Contact Us

Types of Personal Information We Collect

We may collect several types of personally identifiable information from and about you including information that falls within the below categories:

Category	Examples	Collected
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers	Yes
Categories of personal information described in the California Customer Records Act	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial, medical or health insurance information	Yes
Characteristics of protected classifications	Race, color, religion, sex (including pregnancy, childbirth and other related medical conditions), gender, gender identity, gender expression, sexual orientation, marital status, medical condition, military or veteran status, national origin, ancestry, physical or mental disability, genetic information, age (over 40)	Yes
Commercial information	Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies	[Yes]
Biometric information	Physiological, biological or behavioral characteristics that can be used to establish individual identity, including imagery of the iris or retina, fingerprint, faceprint, handprint, palmprint, vein patterns, voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information	[No]
Internet or other electronic network activity	Browsing history, search history and information regarding a consumer’s interaction with a website, application or advertisement	Yes
Geolocation data	Physical location or movements	Yes
Sensory data	Audio, electronic, visual, thermal, olfactory or similar information	[No]
Professional or employment-related information	Current or past job history or performance evaluations	Yes
Education information	Education information including, to the extent not publicly available, the consumer’s name, the name of the consumer’s parent or other family members, the address of the consumer or the consumer’s family, personal identifiers (such as social security numbers, student numbers or biometric records), and indirect identifiers (such as the consumer’s date of birth, place of birth and mother’s maiden name)	[No]
Inferences drawn from personal information	Inferences drawn from any of the aforementioned types of personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes	[Yes/No]

Category	Examples	Collected
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers	Yes
Categories of personal information described in the California Customer Records Act	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial, medical or health insurance information	Yes
Characteristics of protected classifications	Race, color, religion, sex (including pregnancy, childbirth and other related medical conditions), gender, gender identity, gender expression, sexual orientation, marital status, medical condition, military or veteran status, national origin, ancestry, physical or mental disability, genetic information, age (over 40)	Yes
Commercial information	Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies	[Yes]
Biometric information	Physiological, biological or behavioral characteristics that can be used to establish individual identity, including imagery of the iris or retina, fingerprint, faceprint, handprint, palmprint, vein patterns, voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information	[No]
Internet or other electronic network activity	Browsing history, search history and information regarding a consumer’s interaction with a website, application or advertisement	Yes
Geolocation data	Physical location or movements	Yes
Sensory data	Audio, electronic, visual, thermal, olfactory or similar information	[No]
Professional or employment-related information	Current or past job history or performance evaluations	Yes
Education information	Education information including, to the extent not publicly available, the consumer’s name, the name of the consumer’s parent or other family members, the address of the consumer or the consumer’s family, personal identifiers (such as social security numbers, student numbers or biometric records), and indirect identifiers (such as the consumer’s date of birth, place of birth and mother’s maiden name)	[No]
Inferences drawn from personal information	Inferences drawn from any of the aforementioned types of personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes	[Yes/No]

Collectively, the information described above and any other personally identifying information we may collect from you shall be referred to as “Personal Information.” We ask that you do not send us or disclose any sensitive Personal Information on or through the Platform or otherwise.  Such sensitive information includes racial or ethnic origin, religion or other beliefs, political opinions, health, criminal background or trade union membership. 

Collection of Personal Information

We may collect Personal Information using the following methods:

• Directly from you when you provide it to us, including through the contact page on the Platform, if you create an account with us, when you register or interact with the Platform, through e-mail and subscription services, if you order a product from us, or if you submit content to the Platform.
• Through your participation in surveys, promotions, and contests.
• From third parties, such as analytics and email marketing service providers.
• Researching or scraping public websites where permitted by the [Terms and Conditions] [DRPOLACHECK.COM], including on public websites, search engines and social media. 
• Automatically through tracking technologies, such as cookies, web beacons, log files, and Pixel, including over time and across third-party websites or other online services.

For more information about how we use Personal Information collected through tracking technologies and the ways you may be able to manage it, see Use of Personal Information, our [Cookie Policy] [DRPOLACHECK.COM], and Manage Your Personal Information.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including: 

• Details of your visits to the Platform, including traffic data, logs and other communication data and the resources that you access and use on the Platform.
• Information about your computer, mobile device and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is intended to be statistical data and may include Personal Information. It helps us improve the Platform, deliver a better and more personalized service, and ensure the Platform is secure and safe to use.

The technologies we use for this automatic data collection may include cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Cookies can be used to store a unique identification number tied to your device so you can be recognized as the same user across multiple browsing sessions and multiple websites.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access certain parts of the Platform.  Unless you have adjusted your browser setting so that it will refuse cookies, we will issue cookies when you direct your browser to the Platform. You can opt out of receiving targeted advertising by visiting either of these outside websites www.aboutads.info or www.networkadvertising.org/choices. For more information on how we use cookies, please see our [Cookie Policy] [insert hyperlink]. [Note: Do you use any other automatic forms of data collection that should be disclosed here?]

California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings or signals. We do not currently take actions to respond to “Do Not Track” signals. It is our view that a uniform technological standard has not yet been developed.  We may adopt a standard once one is created. 

Use of Personal Information

We may use your Personal Information for the following purposes:

• To present the Platform and its content to you;
• To communicate with you;
• To provide you with information, products or services that you request from us;
• To notify you about changes to the Platform or any products or services we offer or provide through it;
• To maintain and manage your account;
• To allow you to participate in interactive features on the Platform;
• To authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Platform;
• To develop, test, improve, and demonstrate the Platform;
• To create and maintain a customer relationship management system, member directories, and invitation lists for our events;
• To publish our own marketing and promotional materials;
• To carry out our legal and contractual obligations and enforce our rights;
• To process your requests, subscriptions, purchases, transactions and payments and prevent transactional fraud;
• To anonymize and aggregate information for analytics and reporting;
• To advertise, market, and sell our products and services, including by linking together or merging certain Personal Information with other Personal Information so that we may better understand your needs and inform you about our products and services and those of our partners;
• For short-term transient use; 
• In any other way we may describe when you provide the information; 
• To fulfill any other purpose for which you provide the information; and
• For any other purpose with your consent

We may also use your information to contact you, via your e-mail address or phone numbers, about our services that may be of interest to you.  If you do not want us to use your information in this way, please do not sign up for our subscription services.  If you have already received e-mails, phone calls or text messages through our subscription services, and you wish to discontinue the services, you may opt-out by sending us an e-mail at DRMPTHERAPY@GMAIL.COM, DRPOLACHECK@AOL.COM stating your request or calling us at 562-225-4093

Disclosure of Personal Information

We may disclose Personal Information:

• To affiliates and other entities within our group of companies, distribution partners, and other Dr. Polacheck therapeutic service customers;
• To contractors, service providers and other third parties we use to support the Platform and our services and who are bound by contractual obligations to keep your Personal Information confidential;
• To third parties when you use a third-party feature on our Platform; 
• To third parties that provide advertising, content or functionality, or who analyze ad performance, on the Platform or other websites or platforms;
• To enforce or apply our [Terms and Conditions] drpolacheck.com and other agreements or comply with any court order, law, or legal process, including government or regulatory requests;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about users is among the assets transferred;
• To social media services if you log into the Platform with a social media service or if you connect a social media account with the Platform;
• If we believe it is necessary or appropriate to protect our rights, property or safety and that of our customers or others;
• For any other purpose disclosed by us when you provide Personal Information;
• To fulfill the purpose for which you provide it;
• To publish our own marketing and promotional materials; and
• With your consent, such as when you choose to provide your information to third parties.

We may also disclose de-identified information without restriction. Note that if you make any Personal Information publicly available on the Platform, anyone may see and use such information.

We may disclose your Personal Information to a third party for business purposes. In the last 12 months, we have disclosed the following categories of Personal Information:

• [Insert categories from personal information chart above]

We have disclosed this information to the following categories of third parties:

• [Insert category from chart above and category of third party. For example “Identifiers: data analytics providers”]

When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

You have the right to opt-out of sales of your Personal Information. Although we do not expressly sell your Personal Information, we share your Personal Information with third party cookie providers through the use of cookies. In exchange, we (i) are able to provide more targeted marketing and advertising, which results in increased sales of our products and services; (ii) understand if the Platform is functioning as intended, enabling us to refine the Platform accordingly, potentially resulting in creased sales of products and services; and (iii) better understand the effectiveness of our marketing and advertising campaigns. For more information on how we use cookies, please see our [Cookie Policy] [insert hyperlink]. [Due to ambiguities in the language of the CCPA, the use of cookies may constitute “selling” information, even though no monetary consideration is received. Do you use third party cookies or only strictly necessary cookies? Other than through the use of cookies, do you sell the personal information of consumers, for example, to third party advertisers?]

While we have not “sold” Personal Information as that term is commonly used, in the last 12 months, we have transferred the following categories of Personal Information as disclosed above:

• [Insert categories from personal information chart above]

We have transferred this information to the following categories of third parties:

• [Insert category from chart above and category of third party. For example “Identifiers: data analytics providers”]

We do not knowingly sell the Personal Information of consumers under the age of 16. [Please confirm. The CCPA Regs require the Privacy Policy to state whether the business has actual knowledge that it sells the personal information of consumers under 16. I think we can safely say we do not knowingly sell such information, as presumably anybody looking for property is over the age of 16. We also have a rep in the Terms and Conditions that users are at least 16. There are further disclosures and rules for companies that have actual knowledge that they sell the information of consumers under 16]

The California Consumer Privacy Act of 2018 (the “CCPA”) prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

Any third party with whom we are allowed to share your Personal Information is authorized to use your Personal Information in accordance with our contractual obligations with such third parties and in accordance with their own privacy policies, over which we have no control.  You agree that we are not responsible or liable for any of their actions or omissions.

If you provide Personal Information about another person to us, you will be representing, and we will believe, that you have the consent of that individual to enable us to collect, use or disclose their information as described in this notice, and will rely on our belief and your representation.

[Note: Do you, alone or in combination, buy, receive for commercial purposes, sell, or share for commercial purposes the personal information of 10,000,000 or more consumers in a calendar year? If so, certain metrics must be disclosed annually]

Retention of Personal Information

We generally retain records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements.

Manage Your Personal Information

If you believe that any Personal Information you have provided to us is out-of-date or inaccurate, you may review and correct such information by logging in at any time if such information is within your online account or by contacting us at drmptherapy@gmail.com , drpolacheck@aol.com. As a security precaution, we may need to request information from you to help us confirm your identity when exercising a right related to your Personal Information.

Even after you cancel your account or ask us to delete your Personal Information, copies of some information from your account may still be viewable if, for example, you have shared information with other services such as social media. Your account may not be instantly inaccessible to others due to the nature of caching technology.  Additionally, we may retain information related to your account after cancellation or your request for deletion to comply with legal requirements, for our internal security or recordkeeping, or for fraud detection.  We may not be able to completely delete all of your Personal Information due to financial, contractual or legal requirements, or technical constraints. 

Your California Privacy Rights

Shine the Light Protection

California Civil Code Section §1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, if applicable.  To make such a request, please contact us at drmptherapy@gmail.com, drpolacheck@aol.com If you believe any of the information we possess about you is incorrect, please contact us at the same webpage listed above.

California Consumer Privacy Act of 2018

Consumers protected by the CCPA have specific rights regarding their Personal Information. 

Access to Specific Information

You have the right to request that we disclose to you the following about our collection and use of your Personal Information over the last 12 months:

• The specific pieces of Personal Information we collected about you
• The categories of Personal Information we have collected about you in the last 12 months
• The categories of sources from which the Personal Information was collected
• The business or commercial purpose for collecting or selling Personal Information 
• The categories of third parties with whom we share the Personal Information 
• The categories of Personal Information that we disclosed about you for a business purpose in the last 12 months and, for each category identified, the categories of third parties to whom that particular category of Personal Information was disclosed for a business purpose
• The categories of Personal Information that we sold about you in the last 12 months and, for each category identified, the categories of third parties to whom that particular category of Personal Information was sold

We are not required to provide you with these disclosures more than twice within a 12-month period.  

For requests seeking disclosure of specific pieces of information, we will not disclose any such information if we cannot verify the identity of the requestor.  Similarly, for requests seeking categories of Personal Information , we may deny the request if we cannot verify the identity of the requestor. In either case, we will inform the requestor that we cannot verify their identity, and direct them to the general business practices regarding collection, maintenance and sale of Personal Information in this Policy.

If we deny your request for specific pieces of Personal Information, in whole or in part, because of a conflict with applicable laws or an exception to the CCPA, we will inform you and explain the basis for the denial. 

At no point will we ever disclose pursuant to a verifiable consumer request a consumer’s social security number, driver’s license number, other government-issued identification number, financial account number, health insurance or medical identification number, account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. If applicable, we will notify you in response to a request for information that we have collected such information from you.

Right to Request Deletion

You have the right to request that we delete any Personal Information about you which we have collected from you. Upon receipt of a verifiable consumer request to delete your Personal Information, we will delete such information and direct our service providers to delete your information from their records, subject to certain exceptions provided in the CCPA including, but not limited to, if it is necessary for us or our service providers to maintain the Personal Information in order to: 

(1) complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us; 

(2) detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for that activity; 

(3) debug to identify and repair errors that impair existing intended functionality; 

(4) exercise free speech, ensure the right of another consumer to exercise his or her free speech, or exercise another right provided for by law; 

(5) comply with the California Electronic Communications Privacy Act; 

(6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent; 

(7) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; 

(8) to comply with a legal obligation; or 

(9) otherwise use your information, internally, in a lawful manner that is compatible with the context in which you provided the information. 

We use a two-step process for requests to delete Personal Information. First, you must make a verifiable consumer request. After receiving your request, we will contact you to separately confirm that you want your Personal Information deleted. We will contact you further once your Personal Information has been deleted.

If we cannot verify the identity of the person requesting deletion of Personal Information, we may deny the request and will inform the requestor we cannot verify their identity.  If we deny your request to delete Personal Information, we will notify you of the reasons why. We will delete any part of your Personal Information not covered by the exception allowing us to deny deletion of a portion of your Personal Information.

Non-Discrimination

If you are covered by the CCPA, we will not discriminate against you merely because you have exercised any of your rights under the CCPA.  Except as permitted by the CCPA, we will not, merely because you have exercised your rights under the CCPA, do any of the following:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties;
• Provide you with a different level or quality of goods or services; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

[Note: Do you offer financial incentives for the collection, sale or deletion of personal information, such as collecting email addresses in exchange for discounts or rewards programs? If so, additional documentation will be required, including a good faith and reasonable method for calculating the value of the consumers’ data]

Opt-Out Right

Our use of cookies may be considered a sale of your Personal Information pursuant to the CCPA. For more information on how we use cookies, please see our [Cookie Policy] [insert hyperlink]. You have the right to opt-out of this sale by following the instructions on the Do Not Sell My Personal Information page drpolacheck.com or by contacting us at drpolacheck@aol.com or drmptheapy@gmail.com.  If you have opted-out, we will wait at least 12 months before asking you to reauthorize the sale of your Personal Information. 

Once we receive your request to opt-out, we will stop selling your Personal Information within 15 days.  We will notify all third parties that we have sold your information to within the 90 days before our receipt of your request that you have opted out of the sale of your Personal Information, and instruct them to stop selling your Personal Information.  We will notify you once this is complete.

You can use an authorized agent to submit your request to opt-out. Your authorized agent must have written permission to act on your behalf. If we believe a request to opt-out is fraudulent, we will notify the requestor that we will not comply with the request and provide an explanation as to why we think it is fraudulent. 

You can opt back in to the sale of your Personal Information at any time by contacting us at drpolacheck@aol.com or 562-2254093 A request to opt-in is a two-step process.  First, you must clearly request to opt-in.  Then, we will separately confirm your choice to opt-in.

After opting in, you can opt-out by following the instructions on the Do Not Sell My Personal Information page  or by contacting us at drpolacheck@aol.com or 562 225-4093 

We do not knowingly sell the Personal Information of consumers under the age of 16.

Contact Information 

To request your right to disclosure or deletion of the Personal Information we have collected about you, please submit a verifiable consumer request to us by calling us at [562-225-4093 by emailing us at drmptherapy@gmail.com or drpolacheck@aol.com. If you have questions or concerns about our privacy policies or practices, please contact us at drmptherapy@gmail.com or drpolacheck@aol.com or 562-2254093

A verifiable consumer request can only be made by you, by you on behalf of your minor child, or by a person or entity registered with the California Secretary of State authorized by you to act on your behalf. In order to ensure we are able to promptly respond to your request, your request should include sufficient information that allows us to verify you are the person about whom we collected Personal Information or that you are an authorized representative of such person (including, for example, your full name, email address, and mailing address) and a detailed description of what you are requesting. We will review the identifying information provided in your request against information contained in our records to verify the request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. 

If you are using an authorized agent to exercise any of your rights under the CCPA, you must provide us proof in the form of a signed, written authorization of the authorized agent’s ability to act on your behalf. You must also provide us with your full name, email address and mailing address to enable us to verify your identity.  We will confirm receipt of your verifiable consumer request within 10 business days of our receipt. We will also provide you with information about our verification process and when you should expect a response. 

We will disclose and deliver the Personal Information required within 45 days of receiving your verifiable consumer request.  Should we require more time (up to an additional 45 days), we will notify you of the extension and the reasons for the delay.  The disclosure will cover the 12-month period preceding the receipt of your verifiable consumer request.

If requests from you are manifestly unfounded or excessive, we may charge a reasonable fee to respond to your request or we may refuse to act on the request. If we choose not to take action on your request, we will notify you of the reasons behind our decision.

Children’s Privacy

Our services are not directed to, and we do not knowingly collect Personal Information from children under the age of 16.  If we receive Personal Information that we discover was provided by a child under the age of 16, we will promptly destroy the information.  We recommend that parents actively participate in their children’s use of the Internet.

Data Security

Unfortunately, the transmission of information via the internet is not completely secure.  Although we implement reasonable measures to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Platform, or thereafter.  Any transmission of Personal Information is at your own risk.  It is important for you to protect against unauthorized access to your password and to your computer or mobile device.  Be sure to sign-off when finished using a shared computer or mobile device and use other reasonable measures to secure your sensitive information.

Links to Other Websites

We may provide (and permit other parties to provide) links to other websites or resources.  Because you acknowledge and agree that we have no control of such websites and resources, we are not responsible for the availability of such websites or resources, and we do not endorse and are not responsible or liable for any content, advertising, products or other materials on or available from such websites or resources.  You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such website or resource.

How We Use Cookies and Similar Technologies

The Platform and third parties that provide content, advertising or functionality, or analyze advertising performance on the Platform may use cookies, mobile ad identifiers, web beacons and similar technologies to improve the Platform, determine or improve the advertising shown to you here or elsewhere, to provide you with a personalized experience, or to facilitate administration and navigation of the Platform. For more information on how we use cookies, please see our [Cookie Policy] [insert hyperlink].

Contact Us

We have a dedicated privacy officer to investigate and respond to privacy issues and to be accountable for our compliance with this Privacy Notice. You can contact them at drmptherapy@gmail.com or drpoalcheck@aol.com 

If you do not consent to the collection, use and disclosure of your Personal Information, please do not provide us with Personal Information. 

[Note: This policy must be accessible to consumers with disabilities by following generally recognized industry standards, such as the Web Content Accessibility Guidelines, version 2.1 of June 5, 2018, from the World Wide Web Consortium]