Information Collection and Use
Personally Identifiable Information
When you sign up to the Platform, update your account details, provide your billing information, provide your contact information or make other use of our services, we may ask you for personally identifiable information (“Personal Information”). The Personal Information can be used to contact you or identify you and it may include, but is not limited to, your protected health information, your name, your email, your phone number, your address and your credit card information. We may use the Personal Information, either by itself or in conjunction with other information, for the following purposes:
- Create your account at our Platform, let you log in to the account, administer your account, monitor your account, provide customer service and contact you with information, alerts and suggestions that are related to your account.
- Billing-related purposes.
- We invite you to complete surveys and will keep that data stored electronically.
- Collect and analyze statistical or aggregated information which is personally identifiable.
- When you enroll in and take courses, we collect certain data including which courses, assignments and quizzes you’ve started and completed.
- Help us and our Providers to get to know you and your needs.
- Match you with a Provider.
- Reach out to you via electronic communication (see paragraph below)
- Reach out to you, either ourselves or using the appropriate authorities, if either we or a Provider has a good reason to believe that you or any other person may be in danger.
You may at any time give written consent to release your Personal Information to a third party for any purpose such as care coordination, referral, or family intervention. Email communication, phone calls, text messages, video conferencing and all other electronic communications are not HIPPA-secure—your Personal Information is compromised and accessible to non-authorized persons.
When you use the Platform, our servers or servers of third party services automatically record information that your browser sends (“Log Data”). This Log Data may include, but not limited to, information such as your computer, Internet Protocol address (“IP”), pages that you visit and the time spent on those pages, actions that you take and other statistics. We may use this information, either by itself or in conjunction with other information for the following purposes:
- Monitor, analyze and improve the use and functionality of the Platform, the Platform’s technical operation and the match of the Platform functionality to your needs and preferences.
While using the Platform you and a Provider would likely write or say things by means of text-based communication (such as messages), verbal communication or video communication, either internally or to each other (collectively “Session Content”). The Session Content is shared with the Provider(s) that work with you. The Session Content may be used, either by itself or in conjunction with other information, for the following purposes:
- Let a Provider provide the service to you.
- Supervise, administer and monitor the service.
- Allow professional supervision to the Provider by qualified professionals.
Note that all communications transmitted through the Platform, may be recorded or monitored for quality assurance and training purposes and become part of your file and records.
Cookies and Web Beacons
Social and General Information Tools
We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, a Google Plus account and others (collectively “Social and General Information Tools”). Any information you provide or share by using the Social and General Information Tools may be freely read, accessed, collected and used by others.
Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always suspect when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information, your credit card information, in a non-secure or unsolicited communication (e-mail, phone or otherwise).
Aggregate Information and Non-Identifying Information
We may share aggregated information that does not include any Personal Information with third parties for any purpose, including but not limited to industry analysis, research, business transactions and public relations.
Transfer of Business
We may sell or transfer some or all of our assets, including your Personal Information, in connection with a merger, acquisition, consolidation, joint venture, reorganization or sale of assets. Such transactions would be covered by a confidentiality agreement.
We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. When needed we may disclose information, including Personal Information, to such third parties but we will try to limit the Personal Information disclosed to the minimum necessary to perform their task.
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you’re aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.
We also do not allow anyone under the age of 18 to use the Platform without parental consent, authorization and presence.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information, including Personal Information, to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of ourselves or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. We may disclose information, including Personal Information, to take precautions against liability. You should also be aware that Providers may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.
You may review, update, correct or delete the Personal Information in your Account by contacting us or by editing it online. If you would like us to delete your Personal Information or any other information from our system, please contact us with such request. We will use commercially reasonable efforts to honor your request. However, we may retain an archived copy of your records as required by law for legitimate business purposes or for recordkeeping purposes. There may also be residual information that will remain within our databases and other records, including, without limitation, some data may that may be still archived and stored offline. We are not responsible for removing information from the third parties that we have already legitimately shared Personal Information about you.
Last Updated: February 7, 2020