Notice of Privacy Practices

Recover, Inc. (“Recover,” “we,” “us,” or “our”) operates FMLA Now and FairExams (each a “Brand,” collectively the “Services”). This Privacy Policy describes how we collect, use, and share information across both Services.

• FMLA Now provides nonclinical certification support services to help individuals navigate FMLA and related leave certification.
• FairExams provides nonclinical evaluation support services to help students document eligibility for academic and testing accommodations under the Americans with Disabilities Act (ADA) and related law.

Neither Brand is a treatment provider. Neither FMLA Now nor FairExams diagnoses or treats any medical or mental health condition, and use of either Service does not create a doctor-patient, therapist-client, or other clinical treatment relationship between you and Recover, any Recover personnel, or any independent licensed clinician involved in your evaluation. Clinical determinations are made by independent, licensed clinicians acting in their own independent professional judgment, in a manner comparable to an independent evaluation — not as your treating provider.

Information We Collect

Information You Provide Directly

• Contact and account information (name, email, phone number, and, for FMLA Now, employer information; for FairExams, educational institution or testing program information).
• Information submitted through either Brand’s free eligibility assessment tool, whether or not you subsequently purchase or use certification or evaluation services (“Assessment Data”). Both free assessments are administrative and eligibility-focused, designed to help you understand whether you may qualify for the relevant certification or accommodation, and do not themselves constitute a clinical or diagnostic evaluation.
• Information provided when you register for, purchase, or use either Brand’s services, including information submitted to independent licensed clinicians in connection with an evaluation.
• Information you submit through customer support, surveys, or online forms.
• Payment information, processed by a third-party payment processor; Recover does not collect or store full payment card information.

Information We Collect Automatically

• Device and usage information (IP address, browser type, operating system, pages visited, referral source).
• Information collected through cookies, pixels, and similar tracking technologies, as described in “Advertising, Analytics, and Cookies” below.

Protected Health Information

To the extent either Brand’s services result in the creation of information that constitutes protected health information (“PHI”) under HIPAA, that information is handled in accordance with the applicable Brand’s separate Notice of Privacy Practices, available at [INSERT LINK — FMLA Now] and [INSERT LINK — FairExams]. Assessment Data collected through either Brand’s free eligibility assessment, where it does not include clinical or diagnostic content, is treated as personal information under this Policy rather than as PHI, consistent with the administrative, non-clinical nature of that tool.

How We Use Your Information

• To provide, operate, and improve the Services, including processing certification/evaluation requests and communicating with you about your account.
• To communicate with individuals who completed a free assessment (either Brand) but did not proceed with paid services, including through remarketing, as described below.
• To understand how our Services are used and to improve our marketing and offerings.
• To detect, investigate, and prevent fraud, abuse, or activity that violates our policies or applicable law.
• To comply with legal obligations, including responding to lawful requests from courts, regulators, or law enforcement.

Advertising, Analytics, and Cookies

This section describes how we share information with advertising and analytics partners across both Brands — please read it carefully.

We use cookies, pixels, and similar technologies, and we work with third-party advertising platforms (such as Meta/Facebook and Google) to deliver and measure advertising and to reach individuals who may be interested in FMLA Now or FairExams. In connection with these activities:

• We may share hashed (cryptographically obscured) contact information — such as a hashed email address or phone number — with advertising platforms to match our existing contacts or website visitors against that platform’s users, for purposes of ad delivery, measurement, and building “lookalike” or similar audiences of new prospective users, separately for each Brand.
• The lists we use for this purpose may include individuals who completed either Brand’s free eligibility assessment but did not purchase or use paid services, as well as current or former customers of either Brand.
• We do not share clinical, diagnostic, or health-condition-specific information with advertising platforms for either Brand. Only contact information, in hashed form, is shared for this purpose.
• You may opt out of interest-based advertising from participating companies through mechanisms such as the Digital Advertising Alliance’s opt-out tool (optout.aboutads.info) or your device or browser privacy settings. You may also contact us directly to request exclusion of your contact information from advertising-audience uploads for either or both Brands going forward.

How We Share Information

• Service Providers: vendors who perform functions on our behalf, bound by contract to use information only as directed by us. Vendor functions include billing and collection, auditing and accounting, professional services, analytics services, security, IT, and marketing emails.
• Advertising Partners: as described above.
• Social Media Platforms: if you interact with us on social media platforms, or with social media objects embedded in our Services (for example, a “like” button), the platform — and possibly your connections on that platform — may be able to view that activity. This is distinct from the advertising-audience-upload practices described above; review the relevant platform’s own privacy policy to understand this separately.
• Independent Licensed Clinicians: certification- or evaluation-related information is shared with independent licensed clinicians engaged as independent contractors. These clinicians exercise independent professional judgment and are not directed or controlled by Recover in their clinical determinations.
• Government Entities: we may share information when we believe in good faith that we are lawfully authorized or required to do so — to respond to subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property, rights, or the safety of our employees, clients, or other individuals.
• Business Transfers: in connection with a merger, acquisition, financing, or sale of assets. We cannot promise that an acquiring or merged entity will maintain the same privacy practices described in this Policy.
• Aggregated/De-identified Data: we may use and share, at our discretion, data that has been aggregated or de-identified such that it can no longer be linked to a particular individual.

We do not sell clinical or diagnostic health information to any third party for either Brand. As described above, hashed contact information may be shared with advertising platforms; certain categories of this activity may be considered a “sale” or “share” under California law, as described below.

Cross-Border Transfer of Data

If you use our Services outside of the United States, you understand that we may collect, process, and store your information in the United States and other countries, where privacy laws may differ from those of your country. Any such transfers will comply with safeguards required by applicable law.

Cookies, Do Not Track, and Opt-Out Preference Signals

Most web browsers automatically accept cookies, but you can usually modify your browser settings to disable or reject them; some features of the Services may not work properly if you do. We do not currently respond to Do Not Track browser signals. With respect to opt-out preference signals — including Global Privacy Control — required under California’s CPRA, see the California Privacy Rights section below.

Your Choices and Rights

• You may request access to, correction of, or deletion of your personal information by contacting us, subject to legal limitations described in this Policy.
• You may opt out of the use of your contact information for advertising-audience purposes as described above, for either or both Brands.
• California residents have additional rights described below.

California Privacy Rights

This section supplements the Policy for California residents under the CCPA/CPRA, applicable to both Brands.

• Categories of personal information collected: identifiers; customer records information (Cal. Civ. Code § 1798.80(e)); protected classification characteristics; commercial information; internet/network activity; geolocation; sensitive personal information; professional/employment information (FMLA Now); non-public education information under FERPA (FairExams).
• Categories of personal information disclosed for a business purpose, or “sold”/“shared” under CCPA/CPRA in the preceding 12 months: identifiers and internet/network activity, in connection with the advertising practices described above, for either Brand.

Do I have the right to know what information you have about me? 

Yes. As a California resident, you can request certain information about what we have processed over the past 12 months, including: the categories of personal information collected about you; the categories of sources for that information; our business or commercial purpose for collecting it; the categories of third parties with whom we shared it; the specific pieces of personal information collected; and whether we disclosed your information for a business purpose and to which categories of recipients. We will verify your identity by matching the information you provide with information we maintain. To make a request, email privacy@withrecover.com.

Can I opt out or request that you delete my information?

Yes, you can request deletion of your data. Once verified, we will delete your information in line with our legal requirements and retention policy. We cannot fulfill a deletion request where the data is necessary to: provide you services or otherwise perform our contract with you; detect security incidents or protect against fraudulent or illegal activity; debug products to identify and repair errors; exercise free speech or another right provided by law; comply with applicable law (including the California Confidentiality of Medical Information Act); engage in public-interest research consistent with your prior consent; or make other internal, lawful uses compatible with the context in which you provided the information.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, email privacy@withrecover.com. California residents may submit a request to know, delete, or correct personal information, or to opt out of sale/sharing, by emailing privacy@withrecover.com or by using [INSERT “Do Not Sell or Share My Personal Information” LINK, IF APPLICABLE].

Children’s Privacy

Both Services are intended for individuals age 18 and older. We do not knowingly collect personal information from children under 13. If we learn we have inadvertently done so, we will delete it.

Data Security

We use administrative, technical, and physical safeguards designed to protect the information we collect. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Changes to This Policy

We may update this Policy from time to time. The “Effective Date” above reflects the date of the most recent revision. Material changes will be communicated as required by applicable law.

Contact Us

Recover, Inc. Attn: Privacy Officer

801 International Parkway, 5th FloorLake Mary, FL 32746

Phone: (855) 25-RECOVER

Email: privacy@withrecover.com