Mettle Works Privacy Policy

Effective Date: 6/5/2025

Last Updated: 6/16/2026

1. Introduction

This Privacy Policy describes how Mettle Works and its subsidiaries ("we," "us," or "our") collect, use, and protect your personal information when you use our website, www.mettle-works.com, and our related services (collectively, the "Services"). We are committed to protecting your privacy and ensuring the security of your health information in compliance with applicable laws, including the Health Insurance Portability and Accountability Act (HIPAA) and other relevant privacy regulations.

2. Information We Collect

2.1 Personal Information

- Name, email address, phone number

- Date of birth and demographic information

- Account credentials and profile information

- Contact preferences and communication settings

2.2 Health Information

- Health conditions, symptoms, and medical history

- Medication information and treatment plans

- Vital signs and health measurements

- Healthcare provider information

- Insurance information (if applicable)

- Photos or documents related to your health condition

2.3 Usage Information

- Usage patterns and features accessed

- Device information (device type, operating system, unique device identifiers)

- Log data (IP address, access times, pages viewed)

- Location data (with your consent)

- Push notification preferences

2.4 Third-Party Information

- Information from healthcare providers (with your authorization)

- Data from connected health devices or apps (with your consent)

- Information from insurance providers (with your authorization)

3. How We Use Your Information

We use your information to:

3.1 Provide Medical Services

- Deliver personalized health recommendations and treatment plans

- Connect you with healthcare providers

- Monitor your health progress and outcomes

- Provide medication reminders and health alerts

- Generate health reports and summaries

3.2 Improve Our Services

- Analyze usage to enhance user experience

- Develop new features and functionality

- Conduct research and analytics (using de-identified data)

- Provide customer support and technical assistance

3.3 Legal and Safety Purposes

- Comply with legal obligations and regulatory requirements

- Protect against fraud, abuse, or illegal activities

- Respond to emergencies or threats to public health

- Enforce our Terms of Service

3.4 SMS/Text Message Communications

United Counseling and Support Services, doing business as Mettle Works Behavioral Health, and its programs including Life Success Academy, may send SMS text messages to clients and program participants, including:

- Appointment and session reminders

- Schedule confirmations and updates

- Program enrollment notifications

- Attendance follow-up communications

Consent: Clients provide consent to receive SMS messages during program intake or enrollment, or through the program enrollment form. Consent is documented in the client record. Consent is not required as a condition of receiving services.

Message frequency: Message frequency varies based on your scheduled appointments and program activities — typically 2–5 messages per week.

Opt-out: You may opt out of SMS messages at any time by replying STOP to any message. You will receive a confirmation message, and no further texts will be sent. You may re-subscribe by replying START or by contacting staff.

Help: Reply HELP to any message for assistance, or contact our office at 240-487-6934.

Message and data rates may apply. Mettle Works does not charge for SMS messages, but your carrier's standard messaging rates may apply. Check with your wireless carrier for details.

Privacy: SMS message content does not include protected health information (PHI), clinical notes, or treatment details. Messages are limited to scheduling, attendance, and program logistics.

Verbal Opt-In Process: During program intake or enrollment, staff verbally inform the client about SMS communications. The client is asked: "Would you like to receive appointment reminders and program updates via text message?" If the client agrees, staff record this consent in the client's intake record with the date and staff member name. Clients are informed they can opt out at any time by replying STOP to any message.

Mobile phone numbers collected during intake are used solely for program-related transactional messages sent by Mettle Works Behavioral Health. Mobile/SMS opt-in information — including phone numbers and consent — will not be shared with, sold to, rented to, or disclosed to any third parties or affiliates for any purpose, including marketing. This SMS opt-in information is excluded from the data sharing described in Section 4 of this policy.

4. Information Sharing and Disclosure

4.1 Healthcare Providers

We may share your health information with:

- Your designated healthcare providers

- Specialists or consultants involved in your care

- Healthcare facilities where you receive treatment

- Insurance providers for coverage and payment purposes

4.2 Service Providers

We work with trusted third-party service providers who help us operate our Services:

- Cloud storage and hosting providers

- Data analytics and research partners

- Payment processors

- Customer support services

- IT security and maintenance providers

All service providers are required to maintain the confidentiality and security of your information.

4.3 Legal Requirements

We may disclose your information when required by law:

- In response to court orders, subpoenas, or legal process

- To comply with regulatory requirements

- To protect public health and safety

- In emergency situations to prevent harm

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

4.5 SMS/Text Messaging Exclusion

The sharing described in this Section 4 does not apply to text messaging originator opt-in data or consent. Phone numbers and SMS opt-in information collected for text messaging are never shared with, sold to, or disclosed to any third parties or affiliates for any purpose, including marketing, analytics, or research. In the event of a business transfer, SMS opt-in data remains subject to this no-sharing commitment.

5. Data Security

We implement comprehensive security measures to protect your information:

5.1 Technical Safeguards

- End-to-end encryption for data transmission

- Secure data storage with industry-standard encryption

- Multi-factor authentication for account access

- Regular security audits and vulnerability assessments

- Secure APIs and data connections

5.2 Administrative Safeguards

- Employee training on privacy and security protocols

- Access controls and authorization procedures

- Incident response and breach notification procedures

- Regular privacy and security policy reviews

5.3 Physical Safeguards

- Secure data centers with restricted access

- Environmental controls and monitoring

- Secure disposal of physical media containing data

6. Your Rights and Choices

6.1 Access and Control

You have the right to:

- Access your personal and health information

- Request corrections to inaccurate information

- Download or export your data

- Delete your account and associated data

- Restrict or limit how we use your information

6.2 Communication Preferences

You can:

- Opt out of marketing communications

- Customize notification settings

- Choose your preferred communication methods

- Update your contact preferences at any time

6.3 Data Portability

You can request a copy of your health information in a portable format to transfer to another healthcare provider or app.

7. Children's Privacy

Our Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected such information, we will take steps to delete it promptly.

For users between 13–17 years of age, we require parental consent before collecting or using their health information.

8. International Data Transfers

If you are located outside the United States, please note that your information may be transferred to and processed in the United States. We ensure appropriate safeguards are in place for such transfers in compliance with applicable data protection laws.

9. Data Retention

We retain your information for as long as necessary to:

- Provide you with our services

- Comply with legal obligations

- Resolve disputes and enforce agreements

- Support your ongoing healthcare needs

You may request deletion of your information at any time, subject to legal and regulatory requirements.

10. Cookies and Tracking Technologies

Our Services may use cookies, beacons, and similar technologies to:

- Remember your preferences and settings

- Analyze usage and performance

- Provide personalized content and recommendations

- Improve security and prevent fraud

You can control cookie settings through your device preferences.

11. Third-Party Links and Services

Our Services may contain links to third-party websites or integrate with other health services. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you use.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

- Sending you an email notification

- Posting a notice on our website

- Updating the "Last Updated" date at the top of this policy

Continued use of our Services after changes become effective constitutes acceptance of the updated policy.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Mettle Works

Privacy Officer: Clay Gregory

9701 Apollo Drive, Suite 100 & 330

Upper Marlboro, MD 20774

Email: privacy@mettle-works.com

Phone: 240-487-6934

For HIPAA-related inquiries:

HIPAA Compliance Officer

Email: hipaa@mettle-works.com

Phone: 240-487-6934

14. State-Specific Rights

Depending on your location, you may have additional privacy rights under state laws such as the California Consumer Privacy Act (CCPA) or similar regulations. Please contact us to learn more about rights specific to your location.

15. Terms of Service — SMS Communications

Program Name: Mettle Works Behavioral Health SMS Notifications

Operated by: United Counseling and Support Services

By providing your phone number during program intake or enrollment, you agree to receive transactional SMS messages from Mettle Works Behavioral Health regarding appointment reminders, attendance confirmations, scheduling notifications, and program updates.

Message frequency varies based on your program schedule — typically 2–5 messages per week.

Message and data rates may apply. Check with your wireless carrier for details about your messaging plan.

To opt out: Reply STOP to any message. You will receive a confirmation and no further messages will be sent.

To get help: Reply HELP to any message, or contact our office at 240-487-6934.

For questions about this service, contact:

United Counseling and Support Services / Mettle Works Behavioral Health

9701 Apollo Drive, Suite 100 & 330

Upper Marlboro, MD 20774

Phone: 240-487-6934

Email: administrator@mettle-works.com

Mettle Works Behavioral Health © 2026