Counslr Privacy Policy
Last Updated: August 1, 2020

Your privacy is extremely important to us and we are devoted to safeguarding your private information.

We are constantly putting a great deal of thought, effort, tools, resources and procedures in place in order to protect and safeguard your privacy. This document (the “Privacy Policy”) contains details on issues related to your privacy when using our Services. 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.

This Privacy Policy is part of our Terms of Use (the “Terms”), which are available at www.counslr.com/legal/terms. The specific terms used in this Privacy Policy (such as, but not limited to, “Counslr”, “we”, “us”, “our”, “Platform”, “Counselor”, “Counseling Services”, etc.) have the same meaning as in our Terms. When you use the Platform you accept and agree to both the Terms and Conditions and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy, you should stop using the Platform immediately. By accessing and using the Platform, you affirm that you have read the Terms and this Privacy Policy and that you understand, agree to, and acknowledge all the terms and policies contained in both of them.

Information Collection, Use, and Disclosure
In order for Counslr to operate the Platform effectively and to let you use the Platform, including the Counseling Services, we have to collect some information from and about you, including some Personally Identifiable Information (PII). The information we collect may include, but is not limited to, your name, school affiliation, phone number, email address, and address; your billing and payment information; your manually entered profile information; your log data (including information such as your device type, IP address, pages that you visit and the amount of time spent on those pages, actions you take, and other usage statistics), information related to the Counseling Services or your need for Counseling Services, and any information which is exchanged between you and your Counselor (collectively, the “Information”). In some cases, some of the Information that you give to us is considered health-related data. You may decide which Information, if any, you would like to share with us, but some functions of the Platform may not be available to you without providing us the necessary Information. By deciding to provide the Information you agree to our methods of collections and use, as well to other terms and provisions of this Privacy Policy.

Protecting your Information is a top priority for us. We will never sell or rent any Information you shared in the Platform. Other than in the limited ways detailed in this Privacy Policy, we will never use or disclose any Information without your explicit request or approval.

The Information may be used for the following purposes:
(i) Account creation, management, and login to use the Platform.
(ii) Ensuring high-quality customer support.
(iii) Contacting you or providing you with information, alerts, and suggestions that are related to the service.
(iv) Matching you with a Counselor.
(v) Enabling and facilitating the Counseling Services.
(vi) Supervising, administering, and monitoring the Platform and the Counseling Services.
(vii) Measuring and improving the quality, effectiveness, and delivery of the Platform and the Counseling Services.
(viii) Marketing the Platform and Counseling Services to you.
(ix) Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
(x) Reaching out to you, either ourselves or using the appropriate authorities, if either we or a Counselor have a good reason to believe that you or any other person may be in danger.
(xi) Complying with applicable state and federal laws, including, but not limited to, laws related to protecting client and public health and safety.
(xii) Providing, supporting, personalizing, and developing the Platform and Counseling Services.
(xii) Personalizing your experience on the Platform and to deliver content and product and service offerings relevant to you.

Research and Aggregated Information
For the purposes of research and improving the platform, Counslr may collect and maintain de-identified data and metadata through your use of the Platform. This de-identified data is the sole property of Counslr. This data will be stored and used in non-identifiable aggregate form, and not in a manner to identify any individual personally. You shall not request that Counslr remove or delete such de-identified data.

Cookies
Like many websites, Counslr may gather and analyze information regarding usage of our website, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using cookies. the Platform uses cookies and similar technologies to track usage of the website and to address security issues. We may also use cookies to store your preferences relating to use of our website. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet, phablet, cell phone or other electronic device (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track traffic flows.

Cookies record information about your preferences and allow us to tailor the Platform to your interests. During the course of any visit to the Platform, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things such as finding out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking for the cookie left there on the previous visit. Information supplied by cookies can help us to analyze the profile of our visitors so we can provide you with a better user experience.

Social and General Information Tools 
We use several publicly-available tools and information exchange resources, such as (but not limited to) a Facebook page, Twitter page, LinkedIn page, and other social media and other resources (collectively “Social and General Information Tools”). Any information you provide or share while using Social and General Information Tools may be read, accessed,  and collected by that site and users of that site according to their Privacy Policy.

Phishing 
Online identity theft and account hacking, including the practice known as “phishing”, are of great concern. You should always be diligent when you are asked for your account information. Always make sure you only provide your account information on our secure Platform. We will never request your login information in any non-secure or unsolicited communication (email, phone, or otherwise).

Links
The Platform may contain links to other websites or services which are owned, operated, or maintained by third parties. If you click on a third-party link, you will be directed away from the Counslr Platform to that website or service. The fact that we link to a website or service is not an endorsement, authorization, or representation of our affiliation with the party affiliated with that website or service, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third-party websites, services, policies, or terms.

Emails and HIPAA-Compliance
You may email us with questions, concerns, and issues regarding the Platform or your account. Though Counslr’s mobile apps, and the parts of the Platform used to collect information and connect you with a Counselor for Counseling Services, are HIPAA-compliant, emails and other similar insecure communications systems are not, and can not be, HIPAA-compliant. Please be mindful of anything you include in any email, and remember that any personal information you mention, or any other data you include, in an email may not be covered by the same privacy protections as the information you provide and generate through the Counslr Platform.

Security
While using any Internet-based service carries inherent security risks that cannot be completely eliminated, 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 or exceed all applicable federal laws, state laws, and regulations regarding data privacy.

Service Providers
Counslr may employ third-party companies and individuals to facilitate the 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 are 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. We make sure that any data provided to any party with whom we do not have a strict confidentiality agreement in place is completely de-identified and supplied only in aggregate (not in a way that could be used to identify you individually).

Data Transfers
Your information may be transferred to and maintained on computers located outside of your state, country, or other governmental jurisdiction. Regardless of where your data is stored, it will be maintained securely as outlined in this policy. Your consent to our Terms, followed by your submission of such information, represents your agreement to such transfers of data.

Compliance with Laws and Law Enforcement 
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 (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Counselors 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 take action, including by disclosing information, in the following cases: (i) reported or suspected abuse of a child or vulnerable adult; (ii) serious suicidal potential; (iii) threatened harm to another person; (iv) court-ordered presentation of treatment.

Privacy Notice for California Residents
Counslr recognizes that California has articulated specific privacy rights of the users of the Platform in that State. California users should understand that the Platform does not sell user data to third parties. Further, the Platform is a medical records retention company. As such, almost all User data is kept in encrypted storage as a medical record, including all User-created transcripts. State Law requires the Platform to retain such records for at least seven years. The CCPA does not generally apply to medical information governed by the California Confidentiality of Medical Information Act (CMIA) or protected health information collected by a covered entity or business associate governed by the privacy, security, and breach notification rules of the Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009.

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request, once a year, if the Platform have shared their personal information (non-medical record data only) with other companies for direct marketing purposes during the preceding calendar year. This is California’s “Shine-the-Light Law.”  To request a copy of the information disclosure provided by the Platform, please contact us via the “Contact” page on our website.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted on the Platform. the Platform does not have User below the age of 13 and does not typically allow Users to publicly post information. However, if you feel you publicly posted information on the Platform and you are between the ages of 13 and 17, please contact us via the “Contact” page on our website. Please allow reasonable time for a response. Please be aware that such a request does not ensure complete or comprehensive removal of the data/content you have posted and that there may be circumstances in which the law does not require or even allow removal of data, specifically medical data, even if requested.

California Right to Know: You may request access to the specific pieces of personal data we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal data we have collected about you, the sources of such collection, the categories of personal data we share for a business or commercial purpose, and the categories of third parties with whom we share your personal data. You may make these requests by contacting us on the Platform at the “contact us” link on the website. Please allow reasonable time for a response.

California Designated Agent: You may designate an agent to make a request on your behalf. That agent must have access to your account in order for us to verify the request. California Non-Discrimination. the Platform will never discriminate against you, including by denying or providing a different level of service should you choose to exercise your rights under the CCPA.

Changes to this Privacy Policy
We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the top of this policy. 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 opt out.

Contacting Us
If you have any questions or concerns about this Privacy Policy, please contact us via the Contact form on our website or by emailing us at hello@counslr.com.
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