Last Update: January 30, 2023
We collect personal and other information from you directly when you provide it to us through the Site and the App. We may also automatically collect certain information about you when you and your mobile or other such device use, access, or interact with our Services.
You can visit the Site without submitting any information that we can use to identify you personally. However, if you use certain features on the Site, such as the “Contact Us” feature, you will be required to provide personal information. Such information could include, for example, your name, email address, or phone number. When you register with us and use the App, you may provide your name, email address, age, password and other registration information, transaction-related information, and information you provide when you contact us via the App. We may also collect this information when you create an account by using a third-party services such as Facebook (each, an “SNS Account”). If you use an SNS Account to create your Pal account, we will gather your name, email address, and other personal information that your privacy settings on the SNS Account allow us to access.
It is possible for you to submit your own content, such as answers to guided questions, journal entries, or other writings, in all cases submitted in the App. Pal does not share your content with advertisers, nor does it sell your content. Pal may occasionally use an anonymised version of your content to improve your Pal experience. Such content is securely stored in the cloud.
Because of the nature of the Services, we will be collecting information about you that relates to your mental health. Such information may include reflections on your mental health status, information about current mental state or mood, information on symptoms of mental health conditions, previous diagnoses, personal history, and additional personal information related to answers provided to guided questions. Such information is only collected when you provide it to us. We do not share this information with third parties and only use this information to provide you with appropriate content.
When purchasing the App through the App store, Apple collects credit or debit card data with respect to in-app purchases, including payments for an App subscription. If you purchase a membership subscription through the Site, Pal may receive your name, email address, and credit card details for the purpose of the transaction. If purchasing an App subscription on the Site or in the App, your payment will be processed by our third-party vendor, Stripe, and may be made via credit card or Apple Pay. Stripe collects, uses, and processes your information, including payment information, in accordance with its privacy policies, available at https://stripe.com/privacy. By using Stripe, you agree to its privacy policies.
When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address, device domain, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
The Site contains cookies. Cookies are small files that are stored on your computer by your web browser. First-party cookies are cookies set by our Services. Third-party cookies are cookies set by external services such as Facebook. Our Site uses first-party and third-party cookies. A cookie allows a website to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link that you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer by clearing the browsing history of your browser. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.
From time to time, we may also collect aggregated or de identified information about Site users for internal use to improve the product. Such aggregated or de identified information will not identify you personally.
We use the information that we collect for a variety of purposes in the interest of consistently delivering the best and most personalized mental health services. These purposes include, for example:
- To provide the Services;
- To respond to your questions or requests concerning the Site, App, or other services offered by us;
- To fulfill the terms of any agreement you have with us;
- To fulfill your requests for our Services or otherwise complete a transaction that you initiate, including in-App and Site purchases;
- To send you information about our Services and other topics that are likely to be of interest to you, including through emails from which you may opt-out;
- To deliver confirmations, account information, notifications, and similar operational communications;
- To improve your user experience and the quality of our products and Services;
- To comply with legal and/or regulatory requirements;
- and To manage our business.
In addition to the purposes above, we use the information that we collect automatically through the Site and the App for such purposes as:
- Counting and recognizing visitors to the Site and users of the App;
- Analyzing how visitors use the Site and various Site features;
- Analyzing how users of the App use the App and App features;
- Improving the Site and App and enhancing users’ experiences with the Site and the App;
- Creating new products and services or improving our existing products and Services;
- Enabling additional website analytics and research concerning the Site and the App;
- and Engaging in interest-based advertising (as described below).
We may link information gathered through the Site or the App with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.
In order to deliver the best personalized experience to you, we may share your personal data from time to time, including in encrypted form: To provide our Services.
To provide the best experience to you, our user, Pal uses third-party service providers that perform services on our behalf, including web-hosting companies, application development platforms, database as a service providers, payment systems, advertising platforms, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.We may share your information with other third parties when necessary to fulfill your requests for Services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
The Services also enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties, such as Facebook, may use the fact that you visited our Site or App to target online ads to you about our Services. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your mobile activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Services currently do not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.If you use the Services through your mobile device, you may also opt-out of interest-based by adjusting the advertising preferences on your mobile device. You may further opt out for companies that participate in the Digital Advertising Alliance's AppChoices tool by downloading it here and following the instructions on the website.]
We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:To comply with applicable law or a court order, subpoena, or other legal process; To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party; To establish, protect, or exercise our legal rights or defend against legal claims; orTo facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets. You will be notified via email or a notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.We never sell your information. The App allows you to share collected data with your social media accounts, like Facebook, but only with your permission.
If you want to learn more about the personal information that Pal has about you, or you would like to update, change, or delete that information, please contact us by email at email@example.com.You may also opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at firstname.lastname@example.org.You may stop all collection of information by the App by uninstalling the App. You may use the standard uninstall process as may be available as part of your mobile device or via the mobile application marketplace or network.While using the App, the App allows you to access your data, edit your data, share your data and delete your data. You may do this in the Settings section of the App, which can be found in your profile.
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. Your user content is deidentified and it is not read or reviewed by Pal or any third parties. However, no website or App is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Site, to the App, or to us, and you transmit such information at your own risk.
We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it, which includes the time period during which you are using the App and a reasonable time thereafter. We will retain automatically-collected information for up to 24 months and thereafter may store it in the aggregate as anonymized data. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.We store your data in the cloud and on U.S. servers. If you would like to delete the personal data that you have provided via the Site or the App, please contact us at email@example.com and we will respond in a reasonable time. Please note that some or all of your personal data may be required in order for the Site or the App to function properly.
The information that we collect through or in connection with the Site and the App is processed in the United States for the purposes described above. We also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or other information to us, you expressly consent to such transfer and processing.
If you are a user in the European Economic Area, we process your personal data in the United States as data controller and in compliance with the European General Data Protection Regulation (“GDPR”).In addition to the data categories outlined above, we collect “data concerning health” as defined in the GDPR. Data concerning health means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.
When we process your personal data, we will only do so for the following reasons:As necessary to perform our responsibilities under our contract with you (including to provide the Services);When we have a legitimate interest in processing your personal data, including to communicate with you about changes to our Service, to help secure and improve our Services, and to analyze use of our Services;As necessary to comply with our legal obligations; andWhen you have provided us with your consent to do so.
You have the right to:access personal data we hold about you;request rectification or erasure of your personal data;request the restriction the of processing of your personal data;object to the processing of your personal data; anddata portability. If we have requested your consent, you may withdraw such consent at any time.If you would like to exercise any of your data subject rights under the GDPR, including by withdrawing your consent, please contact us at firstname.lastname@example.org. You have the right to lodge a complaint regarding our data processing with a supervisory authority. The EU Commission provides a list of supervisory authorities here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Our service providers or other third parties with whom Pal may share your personal data from time to time, as described above, may be located abroad, and in particular outside the European Economic Area. In such case, Pal will require them to take, in accordance with applicable legislation, all organizational and technical measures reasonably necessary to ensure an adequate level of protection of your personal data. We will also comply with all applicable requirements related to international data transfers, including implementing standard contractual clauses (SCCs) where necessary.
Content on this Site and in the App is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information or personal information, as defined in GDPR, from children under the age of 13.In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we are able to take the necessary action.
We may make changes to the Site and the App in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Site, in the linked policy on the AppStore, in the App under “Settings” and on our Site. You should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice.
For the purpose of this Policy, Pal is the data controller. Should you have any questions or concerns about this Policy, you can contact us at email@example.com