The Four Steps
DRAFT — not yet reviewed by an attorney. Do not treat as final or legally binding.
Privacy Policy
Last updated: [DATE]
Who we are
The Four Steps ("the App," "we," "us") is a self-help tool created by [LEGAL ENTITY NAME] to help adults work through everyday, non-clinical anxiety using a four-step method. The App is operated at foursteps.dhrosmarin.com.
The App is not a healthcare service and is not therapy. It is a self-help and educational tool, comparable to a self-help book. It is separate from any clinical services you may receive from the Center for Anxiety or any other provider.
Who can use the App
The App is intended only for adults aged 18 and older. We do not knowingly collect information from anyone under 18.
What we collect
- Information you provide: your name, email address, phone number (if provided), and birth year.
- What you share in the App: the things you type, record, or upload while using the four-step process, including voice recordings (which we transcribe to text).
- Self-assessment responses: your answers to periodic anxiety self-assessment questions (including the GAD-7), and the resulting scores over time.
- Usage information: how you interact with the App, including session summaries used to give you continuity and personalized insights.
How we use it
- To provide the App's core function — guiding you through the four steps and remembering your context between visits.
- To show you your own progress and self-insights over time.
- To contact you (email and/or text) with session summaries, reminders, and check-in prompts. You can opt out of these at any time — see "Your choices."
- If you request it, to help you connect with professional care, including facilitating an intake with the Center for Anxiety.
- In aggregate and de-identified form, to understand how the App is used and improve it.
About your sensitive information
Some of what you share — including anxiety self-assessment scores and what you write about your feelings — is sensitive. We treat it with care. We do not sell your personal information. We do notuse your individual conversations to train third-party AI models. [CONFIRM THIS IS TRUE OF YOUR AI PROVIDER'S TERMS — e.g., Anthropic's API does not train on your data by default, but verify and state accurately.]
How your information is shared
- Service providers who help us run the App (e.g., hosting, database, AI processing, email/SMS delivery, transcription) — under agreements that limit their use of your information.
- The Center for Anxiety, only if you choose to request a referral or begin an intake.
- When required by law, or to address a safety emergency (for example, a risk of serious harm to you or others).
For your attorney:The flow of self-assessment scores and personal information toward the Center for Anxiety (a HIPAA-covered entity) is the key issue to review. Depending on how that data moves and when, some of this activity may fall under HIPAA rather than a standard consumer privacy regime. This policy needs to be reconciled with your clinic's Notice of Privacy Practices and any Business Associate arrangements with your service providers.
Crisis situations
The App is not an emergency service and cannot provide crisis intervention. If the App detects language suggesting a crisis, it will direct you to appropriate resources (such as 988). This is not monitoring by a clinician and does not guarantee any response.
How long we keep information
We keep your information for as long as your account is active or as needed to provide the App, or until you ask us to delete it.
Your choices
- You can request access to, correction of, or deletion of your information by emailing dhr@dhrosmarin.com.
- You can opt out of non-essential emails and texts at any time via the unsubscribe link or by replying STOP to texts.
- [Add state-specific rights as applicable — e.g., California/CCPA, if relevant to your users. For your attorney.]
Security
We use reasonable technical and organizational measures to protect your information. No system is perfectly secure, and we cannot guarantee absolute security.
Changes
We may update this policy. We'll post the new version here and update the date above.
Contact
[LEGAL ENTITY NAME] — dhr@dhrosmarin.com — [MAILING ADDRESS IF REQUIRED]
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