1- Overview:

Welcome to NAFSNA SARL “NAFSNA”. Your privacy is extremely important to us. In order to protect and safeguard your privacy, we are constantly putting a great deal of thought, effort, tools, resources and procedures in place. The document herein shall constitute our “Privacy Policy” and it entails details on issues related to your privacy when using our services. This Privacy Policy applies to (i) visitors to the public websites owned and operated by NAFSNA (“Visitor(s)”), (ii) the registered users of NAFSNA’s associated mobile and web application (“App”) and/or any application and/or technology We make available (collectively the Website, the App and NAFSNA Dashboards are referred to  the “Platform”), and/or use any service offered on the Platforms, (“Registered user(s)”),

 

(iii) Users (“User(s)”) and to (iv) the therapists that provide the Services (“Therapist(s)“). It is intended to inform you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide through the Platform.

 

The Privacy Policy does not apply to the collection and use of certain employment-related information. If You are a current or former NAFSNA job applicant, employee, owner, director, officer, or contractor, please contact Us at [email protected] for the appropriate notice.

 

If you are visiting Our website as a [COUNTRY] resident, Your rights under the [COUNTRY] Consumer Privacy Act or GDPR are represented in an addendum to this policy. If You do not see this addendum below, please contact us at [email protected] to receive the additional information describing Your rights under [COUNTRY] law.

 

The Privacy Policy is part of Our Terms and Conditions and shall constitute collectively an agreement (“Agreement”) between You (You, Your, Yourself), and NAFSNA along with its affiliates, successors and assigns (NAFSNA, We, Us, or Our). The terms in the Privacy Policy (such as, but not limited to,”Platform“, and “Therapy Service(s)“) have the same meaning as in Our Terms and Conditions document. When You use Our Platform you accept and agree to both the Terms and Conditions and to the Privacy Policy. However, if You do not agree to be bound to the Privacy Policy You should stop using the Platform immediately or cease to provide the Therapy Services, as applicable. By accessing and using Our Platform or providing the Therapy Services, as applicable, You affirm that You have read the Terms and Conditions and the Privacy Policy and that You understand, agree to and acknowledge all the terms contained in both of them.

2- The Categories of information collected

To let Us operate the Platform effectively and to let You use the Platform, including the Therapy Services, We may collect, use, and store the information described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from You and generated in the course of Your use of the Platform. The data We collect is not used for marketing or any other purposes except as specified in this Privacy Policy.

Visitor Data: NAFSNA collects, uses, and stores data regarding user visits to its website and use of the NAFSNA application (“Visitor Data“), including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to the NAFSNA “FAQ” page, and information about the browser or device used to access the website and application, such as the user’s mobile device ID and IP address. These practices apply to users who visit pages for prospective new customers as well as those who visit pages for prospective Therapists.

Onboarding Data: In addition to the questionnaire responses provided by users (including Therapists) in the process of initial registration, NAFSNA collects, uses, and stores certain additional data from users during the onboarding process (“Onboarding Data“). This data includes the pages viewed by the user, whether the user clicks the “Let’s Start” link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.

Account Registration Data: NAFSNA collects, uses, and stores certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number (“Account Registration Data“). NAFSNA also assigns each user (including Therapists) who creates a NAFSNA account an anonymized, randomly- generated client ID.

Financial Data: NAFSNA collects, uses, and stores certain information regarding payment for its services by users and related transactions on its website, such as whether a user completed payment for NAFSNA’s services, signed up for NAFSNA’s services using a trial offer, canceled or otherwise ended a trial, or completed a request to receive financial aid for NAFSNA’s services (“Financial Data“).

Login Data: NAFSNA collects, uses, and stores data regarding logins to NAFSNA’s Platform by registered users (including Therapists) and activity conducted during that log in such as when a user logs in, the number of messages received or sent through NAFSNA’s website or app during that log in, and whether a user has been assigned, started, or completed a therapy goal (“Login Data“). Login Data does not include the content of any messages sent or received by users or the content of any therapy goals.

Therapy Session(s) or Therapy Session(s) Data: NAFSNA collects, uses, and stores certain general data regarding user therapy sessions such as whether a live session has been scheduled by the user, whether a Therapist or user joins a scheduled session, when a Therapy Session began and ended, and whether a Therapy Session was canceled or re- scheduled.

Customer Data: NAFSNA collects, uses, and stores certain data from users that have signed up for NAFSNA services such as a user’s self-reported name or nickname, age, e- mail address, phone number, and emergency contact information (“Customer Data“).

Therapist Data: In order to credential, recredential, run checks and pay Therapists, NAFSNA collects, uses, and stores certain data from Therapists. This data includes information such as the Therapist’s name, e-mail address, and phone number, address, and education and job history (“Therapist Data“).

Communications Data: NAFSNA collects, uses, and stores communications between users and Therapists on the Platform, and communications between users and NAFSNA’s customer service team (“Communications Data“).

Protecting this information is important for Us. Other than in the ways detailed in this Privacy Policy, We will absolutely never use or disclose any information unless You requested or approved Us to do so.

3- Purposes for which the information is collected

3.1. General

We may use the information We collect for one or more of the following purposes:

3.1.a. To communicate with You

• To verify Your identity and to contact You or provide You with information, alerts and suggestions that are related to the
• To complete an activity You requested, such as register for the Platform or obtain more information and to reach out to You, either ourselves or using the appropriate authorities, if We have a good reason to believe that You or any other person may be in danger or may be either the cause or the victim of a criminal

3.1.b.  To deliver services to You and to personalize Your experience

• To create and manage Your account on Our Platform and let You log in to Your account and use the Platform and ensure You are receiving quality
• For billing and transaction processing
• To provide, support, personalize, and develop Our Platform and the Therapy Services.
• To personalize the website experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads through Our websites, and via

3.1.c. To evaluate the services

• To carry out, evaluate and supervise the
• To measure and improve Our business and enhancing the user experience on the Platform

3.1.d. To comply with the law

• To respond to law enforcement requests and as required by applicable law, court order, or governmental
• To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and

3.1.e. For other uses with your consent

• Any other purpose with Your
• Your information collected through the Platform may be stored and processed in any country in which NAFSNA and any subsidiary company

3.2. To third parties

We disclose Information about You to third parties for one or more of the following purposes:

For Internal business purposes: Only as necessary for facilitating the Therapy Services, We may share a user’s information with a Therapist and a Therapist’s information with a user. We may also share Your information with service providers, including Our data hosting and data storage partners, analytics and service providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.

With Your consent: We may share Your information with third parties if You request or direct Us to do so. The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If You click on a third party link, You will be directed to that third website or service. The fact that We link to a website or service is not an endorsement, authorization or representation of Our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and We do not have control over their privacy policies and terms of use.

Push notifications: When using Our Platform, You have agreed to receive Push Notifications and/or the review box and/or emails to the email address You have provided to us under these Terms. Please note that You can post Your comments in the review box privately or anonymously or publicly.

For cooperation purposes: We may share Your information with any subsidiaries or parent companies within Our corporate group.

For marketing and advertising purposes: Due to the use of cookies and similar technologies, information regarding Your activity on Our websites, excluding activity when You are logged in and have started therapy, may be disclosed to Our advertising partners to optimize marketing. We do not share with any advertising platform private information like member names, email addresses, phone numbers, diagnosis, sessions data, journal entries, messages, worksheets, or any other type of communication You have with Your Therapist. If You want to opt out of these cookies and similar technologies, manage Your options here.

Compliance with law: We may share Your information if We are required to so by law, regulation, or legal process.

For transactions purposes: We may share Your information in connection with an asset sale, merger, bankruptcy, or other business transaction.

For other reasons: We may share Your information to enforce any applicable Terms and Conditions and Terms of Use, and to ensure the safety and security of the Platform and Our users.

Note that if You make any information publicly available on the Platform, anyone may see and use such information. We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, and others (collectively “Social and General Information Tools“). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.

4- Unsubscribe

You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of Our marketing email communications.

5- Cookies and Similar Technologies

Like many websites, We use “cookies” and similar technologies to collect information. A “cookie” is a small data file that is transferred to your computer’s hard disk for record- keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking.

You can change your browser’s settings so it will stop accepting cookies or to prompt You before accepting a cookie or similar technologies. Opt-out options for cookies are  located here.

We may use third party cookies and similar technologies for the purposes of web analytics, attribution, and error management. Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on Our websites for purposes of analytics and analysis of certain Platform usage.

You and others may see certain ads for Our services or for the Platform on other websites because We participate in ad networks. The information Our ad networks may collect includes information about Your visits to websites that participate in the relevant ad networks, such as the pages or advertisements You view and the actions You take on the websites. This data collection takes place both on Our websites and on third-party websites that participate in the ad networks. This process also helps Us evaluate the effectiveness of Our marketing efforts and assists other websites and advertising partners to find You or people like You on different platforms, including social media websites. As mentioned above, You can opt-out of cookies and similar technologies by visiting this link here.

6- Phishing

Be aware of online identity theft and account hacking, including the practice currently known as “phishing“. You should always be diligent 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 or Your credit card information in any non- secure or unsolicited communication (email, phone or otherwise).

7- Information Security

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, Our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable laws and regulations regarding data privacy.

8- Service Providers

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. We will share with them only the minimum necessary information to perform their task for Us and only after entering into appropriate confidentiality agreements.

9- Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to become Our user, without parental supervision. The Platform is not directed and not intended to be used by children under the age of 18. If You are aware that We have collected Personal Information from a child under age 18 please let Us know by contacting us and We will delete that information.

10- Compliance with Laws

We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process, and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Therapists 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:

• reported or suspected abuse of a child or vulnerable adult;
• serious suicidal potential;
• threatened harm to another person;

court-ordered presentation of treatment

11- Changes to the Privacy Policy

We reserve the right to change and/or update this privacy statement at Our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage You to periodically review this page for the latest information on Our Privacy Policy and practices. Regardless of changes to Our Privacy Policy, We will never use the information You submit under Our current privacy notice in a new way without first notifying You and giving You the option to stop using the Platform.

12- Closure of Account

Your Personal Data will generally stop being available to anyone on Our Platform within 24 hours if You choose to close Your NAFSNA account. Within 24 months of account closure, We usually delete closed account information, except as noted below.

If sufficiently required to comply with Our legal obligations (including law enforcement requests), comply with regulatory requirements, resolve disputes, maintain security, avoid fraud and abuse, enforce Our Terms, or meet Your request to ‘unsubscribe’ to further messages from Us, We will retain Your personal data even after You have closed Your account.

13- Boycott and Sanctions

NAFSNA or other person acting on behalf of NAFSNA will refuse to provide services to You in the event (i) You are from a boycotted country or (ii) a sanctioned person.

14- Contacting us

If You have any questions or concerns about this Privacy Policy or Our privacy-related practices, please contact Us at [email protected].