Privacy Policy

1. Data controller

The controller of your personal data is RETO Health and Performance LLC, with its clinic at 999 Brickell Ave, Suite 520, Miami, FL 33131, United States. For any privacy request, write to info@retohealth.com.

2. Data we collect

Assessment request: first name, last name, email, phone, whether you can come to Miami, and a record that you accepted the Terms and this policy, with the version of the policy you accepted.

Newsletter: your email address and the region you subscribe from.

Product enquiries and waitlist: name, email, the product you ask about and your message.

Card checkout: first and last name, phone, email, date of birth and billing (and, where relevant, shipping) address. Card numbers are entered directly with our payment provider Stripe and never reach our servers.

Medical questionnaire: once your date is agreed, you complete a short health questionnaire (a Google Form) that a RETO clinician reviews before your visit.

Technical data: server logs and IP address, used for security and abuse prevention.

Attribution data: when you arrive, your browser keeps the campaign parameters of the link you used (utm_source, utm_medium, utm_campaign, utm_content and utm_term), the external website you came from and the page where you landed, in session storage, which your browser discards when you close the tab. If you send an assessment request, this information is sent with it so we know which channel brought you.

Country: on the request form, the country that our hosting provider derives from your IP address is used only to pre-fill your phone prefix. It is not stored.

Browser storage: your answer to the cookie notice is saved in your browser's local storage so we do not ask again. The notice about our calendar availability is shown at most once per visit, and your browser remembers that in session storage until you close the tab. After a completed payment for an assessment, a marker is saved in local storage so that notice does not appear again. These items stay in your browser and are not sent to us; you can delete them from your browser settings at any time.

Analytics and performance: we use Vercel Web Analytics, which counts page views and a few interactions (for example, that a button was clicked or that a request was sent), and Vercel Speed Insights, which measures how fast our pages load and respond on the kinds of devices and browsers visitors use. Both work without cookies and without a persistent identifier, and report aggregated data.

3. Purposes and legal bases

We use your data to answer your requests, to manage your assessment request and the appointment we agree with you (steps prior to a contract), to process purchases and payments (performance of a contract and legal obligations), to send you the newsletter you asked for (consent, withdrawable at any time), to keep the site secure and to measure, in aggregate, how it is used and which channels bring visitors (legitimate interest).

4. Who receives your data

We share data with providers that process it on our behalf:

• Vercel (hosting, cookieless analytics and performance measurement)
• Upstash (the database where your requests are stored)
• Resend (transactional email)
• Stripe (card payments)
• Google Workspace (the medical intake questionnaire)
• n8n (internal automation that hands your details to our clinical platform)
• Our clinical platform (scheduling and clinical records)
• Cloudflare Turnstile (anti-spam check on forms)
• LeadConnector (call booking widget for hardware enquiries)
• Cal.com (scheduling, being retired)

If you choose to write to us on WhatsApp, that conversation is governed by the terms of WhatsApp and Meta. We never sell your personal data.

5. International transfers

Our services operate from the United States, so your data is processed there. Where EU law applies to you, transfers rely on appropriate safeguards, such as standard contractual clauses or an adequacy framework of each provider. For the details, write to us at info@retohealth.com.

6. Retention

We keep data only as long as needed for each purpose: assessment requests and enquiries for up to 24 months in our database, after which they are deleted; purchase and billing data for as long as tax and accounting law requires; and your newsletter sign-up for up to 24 months, or until you ask us to remove it. For the details, write to us at info@retohealth.com.

7. Your rights

Where the GDPR applies, you can request access, rectification, erasure, restriction, portability and objection, and withdraw consent at any time without affecting prior processing. Write to info@retohealth.com. You can also complain to your supervisory authority; in Spain, the AEPD (www.aepd.es).

8. Security

We apply technical and organisational measures appropriate to the risk: encrypted transport (HTTPS), payment data handled exclusively by certified providers, and access limited to the people who need it.

9. Minors

This site and our services are intended for adults. We do not knowingly collect data from anyone under 18.

10. Changes to this policy

We may update this policy. The current version, with its date, will always be published on this page, and material changes will be highlighted on the site.

CONFIDENTIALITY AGREEMENT AND CONSENT TO TREATMENT

The Client Agreement, Waivers and Informed Consents below are reproduced verbatim from the document you accept when you register for services at RETO Health and Performance LLC. It is an English-language document and is published here in English in every region.

CONFIDENTIALITY AGREEMENT

Ordinarily, the information obtained during assessment or treatment is held confidential.

I understand and consent for the sharing of necessary information between the providers at Reto Health and Performance LLC in order to improve and facilitate my treatment.

Additionally, and consistent with relevant mental health laws and professional ethics, confidentiality may be breached under the following circumstances:

• 1. Client authorized release of information with a signature.
• 2. The therapist is ordered by a court to release information.
• 3. For supervision purposes, therapists discuss clients in supervision.
• 4. A client enters into litigation against one of the doctors.
• 5. A client is at risk of harming him or herself.
• 6. A client presents a serious risk of harm to others.
• 7. Any suspected or renewed child/elderly abuse and/or neglect.
• 8. In the last three cases, the therapist is required by law to protect life by informing emergency contact, legal authorities and/or potential victims.
• 9. Your managed Care Insurance requires the following information: symptoms, severity of symptoms, level of functioning, diagnosis, treatment plans, and sometimes progress notes to ensure quality of services and payment.

CONSENT FOR TREATMENT

I understand the above limitations to confidentiality and if I have any questions will discuss them with my therapist.

I understand that I have voluntarily agreed to and give consent for treatment (psychotherapy, psychological testing if appropriate).

I understand the importance of coming to my appointments and agree to attend all scheduled sessions during the treatment period.

I understand the importance of and agree to arrive at all scheduled appointments on time in order to receive the full amount of time scheduled.

I agree to provide 24 hours notice of cancellation of an appointment or I will be charged for the full fee of the time scheduled.

Tele-Mental Health Informed Consent

I hereby consent to participate in tele-health with, Dr. Cristina Grand from Reto Health and Performance LLC, as part of my psychological treatment. I understand that tele-mental health is the practice of delivering clinical health care services via technology assisted media or other electronic means between a practitioner and a client who are located in two different locations (with video included). I understand the following with respect to tele-mental health:

• 1) I understand that I have the right to withdraw consent at any time without affecting my right to future care, services, or program benefits to which I would otherwise be entitled.
• 2) I understand that there are risks, benefits, and consequences associated with tele-mental health, including but not limited to, disruption of transmission by technology failures, interruption and/or breaches of confidentiality by unauthorized persons, and/or limited ability to respond to emergencies.
• 3) I understand that there will be no recording of any of the online sessions by either party. All information disclosed within sessions and written records pertaining to those sessions are confidential (as indicated in confidentiality form).
• 4) I understand that the privacy laws that protect the confidentiality of my protected health information (PHI) also applies to tele-mental health unless an exception to confidentiality applies (as indicated in confidentiality form).
• 5) I understand that during a tele-mental health session, we could encounter technical difficulties resulting in service interruptions. If this occurs, end and restart the session. If we are unable to reconnect within ten minutes, please call me or text me at 305-596-4663, you can also call 305-323-2293. The session may need to be re-schedule.
• 6) I understand that if I am having suicidal or homicidal thoughts, actively experiencing psychotic symptoms or experiencing a mental health crisis that cannot be resolved remotely, it may be determined that tele-mental health services are not appropriate, and that a higher level of care may be required.
• 7) I understand that my therapist may need to contact my emergency contact and/or appropriate authorities in case of an emergency.

Emergency Protocols: You agree to inform me of the address at the beginning of each session if different from your home or office address. Your emergency contact person will be notified if needed and only if an emergency has taken place. I have read the information provided above and discussed it with my therapist. I understand the information contained in this form and all of my questions have been answered to my satisfaction.

I HAVE READ THE ABOVE WAIVER AND RELEASE, CONFIDENTIALITY AGREEMENT, CONSENT TO TREATMENT, AND TELE-MENTAL HEALTH INFORMED CONSENT AND, BY SIGNING, I AGREE TO ITS CONTENTS. IT IS MY INTENTION TO EXEMPT AND RELIEVE RETO HEALTH AND PERFORMANCE LLC FROM LIABILITY FOR PERSONAL INJURY, PROPERTY DAMAGE, OR WRONGFUL DEATH BY ANY CAUSE.

RECORDING AND MONITORING CONSENT

By accessing, entering, visiting, using, communicating with, receiving services from, providing services to, or otherwise interacting with Reto, its affiliates, subsidiaries, personnel, contractors, agents, systems, facilities, websites, applications, products, services, events, communications platforms, or communication channels (collectively, the "Services"), you expressly acknowledge, agree, and consent to the following:

1. Consent to Recording.

You knowingly, voluntarily, and irrevocably consent to the capture, monitoring, observation, collection, recording, storage, reproduction, transcription, analysis, use, disclosure, and retention of your voice, likeness, image, appearance, communications, activities, conduct, statements, interactions, and other information by any means and in any format, whether now existing or later developed.

2. Scope of Recordings.

Your consent applies to all forms of recording and monitoring, including but not limited to:

• (a) telephone calls, voice calls, VoIP calls, conference calls, and similar communications;
• (b) video calls, videoconferences, webinars, virtual meetings, screen-sharing sessions, livestreams, and similar communications;
• (c) audio recordings;
• (d) video recordings;
• (e) photographs and still images;
• (f) surveillance systems, security systems, access-control systems, and monitoring systems;
• (g) recordings occurring within, around, or in connection with any facility, office, building, property, vehicle, event, or location owned, leased, operated, managed, controlled, or used by Reto; and
• (h) recordings of interactions with employees, contractors, agents, representatives, customers, visitors, vendors, and other individuals.

3. Facility Entry Consent.

Entry into or presence within any Reto-controlled facility, premises, office, event space, property, vehicle, or operational area constitutes your acknowledgment of and consent to ongoing audio recording, video recording, photography, surveillance, monitoring, and data collection that may occur in such locations.

4. Communication Consent.

Participation in any communication with Reto, including by telephone, video conference, messaging platform, email, chat system, collaboration platform, support channel, or other communication medium, constitutes your consent to the recording, monitoring, storage, review, transcription, analysis, and use of such communications.

5. Purpose.

Recordings may be used for any lawful purpose, including security, safety, compliance, quality assurance, training, auditing, dispute resolution, documentation, recordkeeping, operational improvement, product development, analytics, legal proceedings, regulatory compliance, marketing, promotional activities, and business operations.

6. Rights Granted.

To the fullest extent permitted by applicable law, you grant Reto a perpetual, worldwide, transferable, sublicensable, royalty-free right and license to record, reproduce, store, modify, edit, publish, distribute, transmit, display, perform, analyze, create derivative works from, and otherwise use recordings and information collected under this consent.

7. No Expectation of Privacy.

To the fullest extent permitted by applicable law, you acknowledge that you should not expect communications, activities, conduct, statements, or interactions occurring through or in connection with the Services or within Reto-controlled facilities to remain unrecorded.

8. Third-Party Participation.

You represent and warrant that, where required, you will obtain any necessary permissions, notices, authorizations, or consents from third parties participating in communications or activities involving you before engaging in such communications or activities through Reto's Services.

9. Retention and Disclosure.

Recordings and related information may be retained for any period deemed appropriate by Reto and may be disclosed to affiliates, service providers, professional advisors, auditors, business partners, acquirers, successors, law enforcement authorities, courts, regulators, or other third parties where permitted or required by law or where reasonably necessary for business purposes.

10. Withdrawal.

Where permitted by applicable law, this consent remains effective unless and until withdrawn in writing. Any withdrawal shall not affect the legality of any recording, collection, use, disclosure, processing, or retention occurring before receipt and implementation of such withdrawal. Reto reserves the right to deny access to facilities, communications channels, products, services, events, or other interactions if consent is withdrawn and recording is reasonably necessary for operational, security, legal, or business purposes.

11. Governing Limitation.

This consent shall be interpreted to the maximum extent permitted by applicable law. If any portion of this provision is held unenforceable, the remaining provisions shall remain in full force and effect.

BY ACCEPTING THESE TERMS, ACCESSING OR USING THE SERVICES, PARTICIPATING IN COMMUNICATIONS WITH RETO, OR ENTERING ANY RETO-CONTROLLED FACILITY OR LOCATION, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREED TO THIS RECORDING AND MONITORING CONSENT.