Privacy Policy

Effective as of May 1, 2024.

Introduction

Our platform employs state-of-the-art data-driven technologies to tailor your care experience and bolster evidence-based practices, care continuity, outcome measurement, and data-driven insights. We empower mental health professionals with tools and insights to drive tangible clinical improvements for individuals accessing virtual therapeutic services through our platform. Accessible via our website or mobile application, our platform offers personalized care experiences.

Medical Information

When you enroll, inquire about enrollment, or utilize mindhelpa Services (defined below), we retain records of the medical information you provide, as well as any information shared by mindhelpa employees or contracted therapists via our platform (e.g., diagnoses). Medical information encompasses data that:

Identifies you.
Pertains to your past, present, or future physical or mental health, treatment, healthcare services provision, or payment for treatment.

This includes medical history, diagnoses, treatments, current health status, and prescription medication usage. For U.S. subscribers to mindhelpa services, your information qualifies as protected health information ("PHI") under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and relevant provisions of the Health Information Technology for Economic and Clinical Health ("HITECH") Act. Alongside this Privacy Policy, HIPAA Notices of Privacy Practices from mindhelpa or your mindhelpa Provider govern your PHI.

Personal Data Processing

This Policy delineates mindhelpa’s practices regarding processing "personal data," which refers to information relating to an identified or identifiable individual. "Processing" encompasses the use of personal data, including collection, recording, storage, utilization, analysis, amalgamation, transfer, disclosure, or deletion.

Policy Updates

We retain the right to modify the terms of this Privacy Policy at any time by revising it, ensuring transparency about our data collection, utilization, and disclosure processes. We encourage periodic review of this Privacy Policy for updates. Unless stated otherwise, changes take immediate effect upon posting to our website or app.

Policy Contents

  • Personal Data Processing & Usage
  • mindhelpa App Usage
  • Advanced Data Processing
  • Research
  • User Control over Information Collection and Usage
  • Access, Deletion, or Modification of Personal Data
  • California Privacy Rights
  • EU/EEA/UK Privacy Rights
  • Data Retention
  • mindhelpa's Policies Regarding Minors
  • Other Mobile Applications and Services
  • Job Applications at mindhelpa
  • Security Measures
  • Contact Information
  • Additional Information for EU, EEA, and UK Users

our online therapy services. These services collectively constitute the "Services." Your interaction with our Services, as well as how you receive and pay for them, dictates our data practices, whether as a consumer or through an employment-related benefit.

This Policy does not extend to prior websites visited before ours or any third-party sites accessible via mindhelpa Services. We encourage careful review of this Policy to understand your rights regarding personal data and how we process it. Additionally, this Policy complements our Notice of Privacy Practices for U.S. patients and other privacy-related disclosures provided during enrollment or account management, without superseding them.

Should you wish to avoid personal data sharing or feel discomfort with our information usage for Service delivery, we advise against using our Services.

Personal Data We Process & How We Use It

The following list delineates the types of information processed (legally classified as personal data or PHI under HIPAA), their sources, and uses.

Categories of Information:
Identifiers: Including name, email address, DeviceID, and Internet Protocol (IP) address.

Sources of Information:
Directly from you or your devices, such as completed forms before subscription or commercial inquiries about our business.

Uses of Information:
Communication with you, including marketing purposes, and operation of the Website and App.

Sharing of Information:
With service providers for business, professional, marketing, analytics, or technical support, subject to written agreements.

Characteristics of Protected Classifications:
Gender identity, sexual orientation, gender expression, and age.

Sources of Information:
Directly from you, such as survey responses before subscription.

Uses of Information:
Communication, marketing, operation of the Website and App.

Sharing of Information:
With service providers for business, professional, marketing, analytics, or technical support.

Internet or Electronic Network Activity Information:
IP addresses and cookies.

Sources of Information:
Automatically from your computer or device.

Uses of Information:
To provide and enhance the Website or App.

Sharing of Information:
With service providers for business, professional, marketing, analytics, or technical support.

Professional and Employment-related Information:
Job title/designation/qualification, company, or investor type.

Sources of Information:
Directly from you, if representing a business engaging with mindhelpa on behalf of your employer.

Uses of Information:
If representing a business, professional, marketing, analytics, or technical support.

Sharing of Information:
With service providers for business, professional, marketing, analytics, or technical support.

Inferences Derived from Information:
Interests inferred from survey responses.

Sources of Information:
Survey responses before subscription.

Uses of Information:
Tailoring communications, marketing, and operation of the Website and App.

Sharing of Information:
With advertising networks for marketing campaign evaluation and tailoring advertising.

Our Policy on Sales and Sharing of Personal Information

Although we do not sell Personal Information, our website utilizes advertising and analytics tools from third parties. In some states, this may constitute a "sale" or "sharing" of personal information or "targeted advertising." We do not target advertising to users under the age of 16. Once you become a patient and use our portal, we refrain from engaging in any sales, sharing, or targeted advertising. We may, however, "sell" or "share" certain categories of Personal Information to data analytics providers, advertising technology vendors, and social media platforms as outlined in this Policy.

To opt-out, you can contact us at privacy@mindhelpa.com, click the "Do Not Sell or Share My Personal Information" link at the bottom of this page, or send a Global Privacy Control signal using your browser or device, as described further in the Policy.

Our Retention Policy:
We retain your Personal Information according to statutory limitation periods required by local law and for legitimate business purposes. This includes as long as your account is active, to provide you with Services, comply with legal obligations, or for dispute resolution and enforcement of agreements.

Introduction:
Our technology platform employs data-driven tools to personalize care and enhance evidence of care, outcomes metrics, and data-based learnings. We offer mental health professionals insights and capabilities to drive improved clinical outcomes for patients receiving virtual therapeutic services through our platform, accessible via the website or our mobile application.

When you enroll or inquire about mindhelpa Services, we record medical information provided by you, your therapist, or mindhelpa employees/contracted therapists via our platform. This includes any information identifying you and relating to your past, present, or future physical or mental health, treatment, provision of healthcare services, or payment for treatment.

This Policy delineates mindhelpa’s practices in processing "personal data," which refers to information relating to an identified or identifiable individual. "Processing" includes collecting, recording, storing, using, analyzing, transferring, disclosing, or deleting personal data.

We reserve the right to modify the terms of this Privacy Policy and recommend checking for updates periodically. Changes apply immediately upon posting to the Website or the App.

What is included in this Policy?

The information on this page applies to the personal data we collect about your interactions, use, and experience with our website at https://www.mindhelpa.com (our “Website”), our app on iOS or Android (our “App”), and in connection with the online therapy services we provide (the Website, App and our online therapy services are together, the “Services”). As noted below, our data practices depend on how you interact with our Services, and how you receive and pay for Services, for example whether purchasing Services as a consumer or receiving them through an employment-related benefit.

This Policy does not apply to any other websites that you visit before our Website or any third-party sites that may be accessible through the mindhelpa Services. Please read this Policy carefully so that you understand your rights in relation to personal data, and how we will process that personal data. This Policy supplements our Notice of Privacy Practices (for US patients) and any other privacy-related disclosures we may provide from time to time (including during your enrollment or management of your account with mindhelpa) and is not intended to override them.

If you do not want us to share personal data or feel uncomfortable with the ways we use information in order to deliver our Services, please do not use the Services.

Personal Data We Process & How We Use It

This list presents the types of information we process (whether legally classified as personal data or PHI under HIPAA), the sources, and the uses.

Personal Data Processing

Types of Personal Data

Registration
Information you provide when you create an account for yourself (or an authorized account for a minor), are matched to a therapist, or register yourself (or on behalf of a minor) as a patient:

Name (e.g. your name or the name of your parent/guardian)
Address
Country
Date of birth
Phone number
Gender and the preferred gender of therapist
Email
Relationship status
Organization/Employer (if applicable)
Payment information and transaction history
Information on the type of subscription you choose
Insurance information (including an image of that information)
Referral source
Information on why you are accessing our Services including what you are hoping to get from therapy
Notification preferences

How We Get It: You provide this when you go through the intake process

What we do with it:

Provide you with the Services (including resubscription)
To match you to a therapist
Provide you with treatment information
Enroll you in services and administer your account
Provide you with support
Process insurance claims, billing, and payment information
Maintaining the safety

What we do with it ?

Provide you with the Services (including resubscription)

To match you to a therapist

Provide you with treatment information

Enroll you in services and administer your account

Provide you with support

Process insurance claims, billing, and payment information

Maintaining the safety and security of our users, our Services, and our business

Provide announcements and communicate with you, including for marketing purposes

Provide mandatory reporting to law enforcement or other governmental authorities, for example in instances of abuse, or ascertainable threats of violence to another person (See Notice of Privacy Practices for more information)

Respond to a valid legal request.

Process claims or insurance information

Provide you with and to evaluate, improve and develop the Services

Conduct therapist oversight

Control the quality of the Services

Permissive reporting of abuse; expressed threats of violence towards an ascertainable victim

Use of the Services

Data you provide when you use our therapy service, including:

  • Information you disclose in chat data and your chat sharing preferences (transcripts)
  • Audio/Video communication
  • Documents you share with your therapist via our chat functionality
  • Information collected via our symptom tracker and information on your clinical progress
  • Information collected via chat, telephone, or email support channels
  • Messages that you “star”
  • Information on friends you refer
  • Information you provide as part of treatment intake including emergency contact details, information on your health and mental health and medical history, images (optional)
  • If you use couples therapy, sharing of contact details and some communications will be conducted jointly.
  • If you choose to admit another individual to a therapy “room” for a session, their contact information will be collected and used for that purpose.
  • Information shared through the online chat support feature and your email address.

Through your use of the Services

To provide you with the Services

To build, modify, and develop new products, features, and Services.

To conduct clinical and other academic research, internally and with approved research partners and identify summary trends or insights for use in external communications (where direct identifiers such as name and contact details have been removed, or pursuant to explicit patient authorization). For more information see “Research” below. See Notice of Privacy Practices.

To address patient concerns or complaints

To carry out quality assurance and compliance activities

To provide you with assistance in the event of an emergency

To assist you with questions about the services.

To address patient concerns.

When Website visitors contact us, we collect information when you communicate with us via email or our online support service. This includes information that you provide when you contact us, any information you share through the online chat support feature as well as your email address.

You provide this information to us directly

To respond to and address your communication

To provide you with the Services

To improve the Services

Provide support to users (therapists and patients)

Technical Data

Technical information from software or systems hosting the Services, and from the systems, applications and devices that are used to access the Services, such as:

  • Information on the device operating system or mindhelpa environment
  • Metrics on system or App feature use
  • Information on system events and status

Automatically through use of the Services

Create anonymized and/or aggregated data to improve and deliver our Services

Comply with legal obligations

Maintain the security of our infrastructure

Facilitate the delivery and optimization of Services

Monitor performance of our data centers and networks, systems and applications

Provide support to users (therapists and patients)

Administer our business continuity and disaster recovery plans and policies

Detect, investigate, and remediate stop fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) through automated and manual means

To provide you with and to evaluate, improve and develop the Services

To develop new products

Persistent Identifiers

Data collected via cookies, pixels and other tracking technologies (such as Google Analytics and Google Ads), such as:

  • Internet protocol (IP) addresses
  • Device ID
  • Browser type
  • Internet service provider (ISP)
  • Referrer URL
  • Geolocation information (derived from IP Address)
  • Exit pages, the pages and files viewed on our Website (e.g., HTML pages, graphics, etc.)
  • Operating system
  • Date/time stamp

NOTE: Once you become a patient the use of cookies, web beacons, pixels, and other processes are limited to ensure that we do not monitor or use patient information for other purposes without your consent.

Collected automatically when you use the Services

To provide you with and to evaluate, improve and develop the Services

To develop new products

Analyze how our Services are used so we can improve your experience

Evaluate the success of our marketing campaigns

Marketing, including tailoring advertising

Legal Compliance and Corporate Transactions: mindhelpa may be required to disclose your personal data (a) to government and law enforcement authorities to comply with legal or regulatory obligations or requests, (b) to certain third parties such as an acquiring entity or advisers in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), or (c) where we believe disclosure is necessary or appropriate to (i) comply with applicable law, (ii) enforce our terms and conditions; (iii) protect our operations; (iv) protect our rights, privacy, safety, or property, and/or those of you or others; and (v) allow us to pursue available remedies or limit damages that we may sustain.

Where applicable, we may use or disclose your personal data for other reasons as described to you at the time of data collection or otherwise with your consent.

Using the mindhelpa App

The mindhelpa App includes third party software development kits (SDKs) from a number of other companies whom we engage as service providers, for identifying and logging code issues, errors and events; managing interactive communication within the App; compiling analytics on which features get used the most; facilitating customer service contacts regarding subscriptions and service; and processing device identifiers and event logs for ad attribution purposes (such as the initial login event, account creation, subscription events). These third parties process data as a service to mindhelpa only, pursuant to written agreements. mindhelpa does not sell client information to third parties.

Advanced Data Processing

The mindhelpa therapy experience is enhanced by advanced data processing activities, carried out in order to measure and improve clinical outcomes. Our proprietary matching algorithm and machine-learning tools provide real-time engagement insights, inform treatment, and track clinical progress, and are fundamental to our precision therapy care delivery model.

Matching Algorithm

During onboarding we ask you to provide information so that we can assess your condition and incorporate your preferences. We then leverage a proprietary algorithm (and/or support from a mindhelpa consultant) to match you to a provider.

Optimizing Diagnosis and Treatment

Throughout your experience, your provider uses the mindhelpa Services to manage your diagnosis and treatment plan. The advanced machine learning features of our proprietary Services include natural language processing of communications with therapists. A core focus of our machine learning strategy is to provide the therapist with insights on patient needs and behaviours and offer techniques and suggestions that we believe are likely to maximize clinical outcomes. We also use advanced machine learning features to generate therapy notes where requested by our therapists.

Research

Separate and apart from internal healthcare operations and quality assurance activities undertaken for the purpose of delivering and optimizing patient care on the platform, from time to time, mindhelpa conducts or participates in research studies with select universities. You may be offered the opportunity to participate in these studies. If your protected health information will be disclosed as part of these studies, your information will only be included with your written authorization. You will be asked to review and accept terms and enrollment separately from the information included in this Policy. Information from these studies may be published by third parties including through various media platforms/academic journals. See our Notice of Privacy Practices.

What choices do you have about how we collect or use your information?

When you create a mindhelpa account or otherwise use the mindhelpa Services, we collect (or you may provide us with) your email address, and you have the choice to receive newsletters or promotional material about our services at this address. These messages may be tailored to your responses to onboarding surveys so that you receive information relevant to you. You can further manage your email preferences by unsubscribing from emails (via the link in the message), emailing privacy@mindhelpa.com or by visiting our online preference center within the App or the Website.

In addition to your rights as a patient as set out in the Notice of Privacy Practices, you can ask us to:Stop sending marketing or promotional emails and mobile marketing communications from mindhelpa. Limit the use of cookies, pixels, or web beacons. If you are a EU, EEA or UK user, you can also exercise the rights set out below. Certain California residents may have additional rights set out below. To ask us about these choices, contact connect@mindhelpa.com.

How can I access, delete, or modify my personal data?

You may request access to, correction of, or deletion of your Personal Information. We will honor your request regardless of where you live or are physically located unless a legal requirement prevents us from doing so or a legal exception applies. Please complete the appropriate request form below and email the completed form with a copy of your photo identification to privacy@mindhelpa.com.

Data Request Forms

Individuals Authorization for Release of Information

Third Party Authorization for Release of Confidential Information

Request for Information Deletion/Removal

Data Subject Rights Request Form (GDPR)

US Privacy Rights

Depending on your U.S. state of residence, you may have certain rights in relation to your personal data, including:

  • Right to Know: You may have the right to know what personal data we have collected about you, including the categories of sources from which the personal data is collected, the business or commercial purpose for collecting, selling, or sharing personal data, the categories of third parties to whom we disclose personal data, and the specific pieces of personal data we have collected about you. Please note that we may not be required to respond to your requests “to know” or access specific pieces of personal data more than twice in any 12-month period.
  • Right to Data Portability: You may have the right to access your information in a portable format.
  • Right to Delete: You may have the right to request that we delete personal data that we have collected from you, subject to certain exceptions.
  • Right to Correct: You may have the right to correct inaccurate personal data that we may maintain about you, subject to appropriate verification.
  • Right to Opt Out of Certain Types of Personal Data Uses and Disclosures: We use and disclose to third parties personal data for analytics and advertising purposes. Accordingly, you may have the right to opt out of the “sale” or "sharing” of your personal data, or the use and disclosure of your personal data for “targeted advertising” (as these terms are defined in applicable law).

Please note that, where permitted under applicable law, we may decline a request if we are unable to verify your identity (or an agent’s authority to make the request) and confirm the personal data we maintain relates to you.

If you are interested in exercising one or more of the rights outlined above, please contact us at connect@mindhelpa.com. You must put the statement “Your Privacy Rights” in the subject field of your email. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us. Submitting a privacy rights request does not require you to create an account with us.

We will not discriminate against you if you decide to exercise your privacy rights.

Agent Requests: Only you, or someone legally authorized to act on your behalf, may submit a request related to your personal data Information. You may also submit a request on behalf of your minor child. Depending on your U.S. state of residence, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.

Opt-Out Requests: You may request to opt out of the sale or share of your personal data, or of targeted advertising, at any time by clicking the “Do Not Sell or Share My Personal Information” link here or at the bottom of our Services’ homepages, or you can email us at privacy@mindhelpa.com. Alternatively, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including us. If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of personal data linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each browser or profile.

Right to Appeal: Depending on your U.S. state of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at privacy@mindhelpa.com.

Use and Disclosure of Sensitive Data: To the extent that we collect, use, or share “sensitive personal information” as that term is defined in applicable state privacy laws, we limit our use or disclosure of the sensitive personal information for permitted business purposes.

EU/EEA/UK Privacy Rights

If you are located in the European Union, the European Economic Area, or the United Kingdom, this Policy is supplemented by our Additional Privacy Statement for EU, EEA and UK Users which explains your privacy rights and how you can exercise these rights (among other matters).

Retention

We will retain your information in accordance with the appropriate statutory limitation periods as required by local law, in line with our legitimate business purposes for as long as your account is active or for as long as needed to provide you with the Services, as required in order to comply with our legal obligations, a court order or to defend or pursue legal claims, in line with industry codes of practice, to resolve disputes and enforce our agreements.

mindhelpa and Minors

In the United States, mindhelpa may collect information and may provide Services to minors ages 13 – 17 with the written authorization of a parent or guardian. mindhelpa does not provide therapeutic services to minors outside of the US.

Other Mobile Applications and Services

This Policy does not apply to any third-party applications or software that you download, or any other third-party websites, mobile applications, or online products, services, or businesses you may access from the mindhelpa Website or App.

Applying for a Job at mindhelpa

Please see our statement on Candidate Privacy for more information on the personal data we process in connection with recruiting.

Security

We take commercially reasonable steps to protect the integrity and confidentiality of personally identifiable and health information that you may share with us. We have complied with the HIPAA security rule for administrative, technical, and physical security safeguards and have third party assessments of our controls performed annually. However, please be aware that no security measures are perfect or impenetrable and we cannot guarantee the absolute security of your information.

We will do our part to protect your information, but it is important for you to protect your information as well. In addition, we do not control the actions of anyone with whom you or any other mindhelpa user may choose to share information. As such, you should be cautious about the access you provide to others when using mindhelpa, and the information you choose to share when using the mindhelpa website or App.

How to Contact Us

If you have any privacy-related questions or comments related to this Policy, please send an email to privacy@mindhelpa.com.

Additional Information for EU, EEA and UK Users

Please see our Additional Privacy Statement for EU, EEA and UK Users for further details on your privacy rights, how we share your personal data, international transfers of personal data and retention of personal data.

We process the personal data described above in accordance with the following legal basis:

  • With your consent;
  • As necessary to perform our agreement with you, including when you agree to our Terms of Service;
  • As necessary for our legitimate interests, such as to provide you with the Services;
  • As necessary to comply with our legal obligations;
  • As necessary for the establishment, exercise or defense of legal claims; and
  • As necessary to protect the vital interests of an individual.

We are a limited liability company established in 651 North Broad Street, Suite 201, Middletown, Delaware, United States. 19709, and, if you are based in the EU, EEA, or UK for the purpose of the EU and UK General Data Protection Regulation, we are the data controller.

Limited Use Requirements

Mindhelpa use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

User Consent for AI Apps

In Mindhelpa, we utilize advanced language models to process your voice searches, helping you find the right therapy group that meets your needs. We are committed to ensuring your data privacy and security at all times. Here’s how we manage your personal data in relation to the AI models and third-party services we use:

  1. Voice Search Processing:
    • When you use voice search in our app, the spoken input is processed by our language model to understand and interpret your request.
    • Importantly, we do not send any of your personal data, including your voice search inputs, to the AI models we plan to use now or in the future.
  2. Third-Party Services:
    • Our app integrates with several third-party libraries and APIs to enhance functionality. For instance, we use Google OAuth for secure user authentication.
    • Any data received from these third-party services, such as authentication tokens or user profile information from Google OAuth, is handled with strict confidentiality.
    • We ensure that this data is not transmitted to or processed by our language model, adhering to our commitment to protect your personal information.

We prioritize your privacy and are transparent about how your data is used and protected. Should you have any questions or concerns about our data handling practices, please feel free to contact our support team at connect@mindhelpa.com