Privacy
Policy

Last Updated February 3, 2023

MINDYRA PRIVACY POLICY

Overview

Mindyra is a behavioral care technology company formed to assist employers, universities and large membership organizations to support the mental health needs of their employees, students or members. The firm has developed its proprietary MindHealth Navigator™ platform to accurately assess each individual’s mental health needs and to guide users to their own personalized Care Path™.

This Privacy Policy (“Policy”) describes the information we collect and how we use and share that information. This Policy applies to general users of the Website and the App, practitioners who use the Services and patients who utilize the Services on the recommendation of their practitioner. By using the Website, the App and/or the Services, you consent to the collection, use and sharing of your information under this Policy and, if using the Services, you also agree to our Terms of Use.

What Information Do We Collect?

A) Information You Provide To Us in Connection with Use of Services

We collect information that you voluntarily provide us when you use the Services. (We note that this section of the Policy does not apply to those who are general users of the Website only.) In order for you to use the Services, we may ask you to register and provide information to us. This information may include your name, e-mail address, user ID, mailing address and telephone number. Finally, we may also collect demographic information such as your age, gender, zip code/postal code, and any information that you submit in response to your use of the Services.

Whenever you enter information to use the Services, that information is stored and accessible to us for future use. For example, we may use your account and email address to communicate with you about the Services.

If you share information that you provide to us with someone else, whether a practitioner or other individual, you acknowledge and accept responsibility for your decision to provide such individual with access to potentially sensitive or confidential information. Whether you are a patient of a practitioner who recommends the Services, a family member/guardian of such a patient or a practitioner, we are not responsible for the information you share with others.

B) Other Information We Collect

When you use the Website, the App and/or the Services, we may track information on how you interact and use the Website, the App and/or the Services through server log information, cookies and other similar tools of Internet tracking.

Server Log Information (IP Addresses). An IP address is a number automatically assigned to your computer whenever you access the Internet. All computer identification on the Internet is conducted with IP addresses, which allow computers and servers to recognize and communicate with each other. We collect IP addresses in order to conduct system administration, report Aggregate/De-identified Data (as defined below) to our affiliates and/or partners and to conduct analysis of the Website and/or the App. We will also use IP addresses to identify any users of the Services who refuse to comply with the Terms of Use, and to identify users who threaten the Website, the App, the Services, our users, our clients or others.

Cookies and Web Analytics. We may place a text file called a ‘cookie’ in the browser files of your computer or electronic device. Cookies are pieces of information that a website transfers to an individual's hard disk for record-keeping purposes. We use cookies during your online session to determine whether you are logged on or not, and to improve the performance of the Website and the App. We do not use cookies to store passwords or sensitive information. These cookies do not contain any personal information. You may disable cookies in your browser but doing so may restrict your access to only public pages and you may no longer be able to access many of the features on the Website and App or of the Services. In addition to cookies, we use some web analytics tools to place a single-pixel GIF file on a computer as a tracking indicator.

How Do We Use Your Information?

We use the information we collect to optimize your experience with the Website, the App and the Services. Specifically, we use the information in the following manner:

Internal Purpose We may use your information for various internal purposes. We will store data for as long as it is necessary to provide the Services, provide for legal protections, or as otherwise required by applicable laws and regulations.

De-identified Information. We may provide de-identified information about you and others, such as usage information and trends, to third parties. This information, commonly referred to as “Aggregate Data,” or “De-identified Data”, is pooled information of many individuals, and is stripped of any data that could potentially identify you as an individual. This information is commonly used for research purposes.

Algorithms/Analytics.We may use your information to develop certain analytic or algorithmic information for our future use.

Customer Support.We may use your information to provide, improve and develop the Website, the App and/or the Services, as well as responding to any issues you may have while using the Website, the App and/or the Services.

Communications with You. We may use your information to respond to communications from you or to communicate with you about the Services, other products, promotions, studies, surveys, news, updates, events, and updates to this Policy and the Terms of Use.

Research.We may use your information to monitor and analyze trends and usage of the Website, the App and/or the Services.

To Enforce our Privacy Policy and Terms of Use. We may use your information to enforce our Policy and/or Terms of Use.

Legal Purposes.We may use the information we collect to investigate or address claims or disputes relating to your use of the Website, the App or the Services, or as otherwise allowed by applicable law.

How is Your Information Shared?

Business Affiliates, Vendors and Consultants. We may share your information with any business affiliates, vendors, consultants, marketing partners, research firms, and other service providers or business partners as necessary to provide the Website, the App and/or the Services.

Potential New Owner. We may share Aggregate/De-identified Data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

Legal Purposes. We may share your information if we believe an applicable law, regulation, legal process or governmental request requires it. This includes sharing your information with law enforcement officials, government authorities, or other third parties as necessary to enforce our Policy, Terms of Use, user agreements, or other policies, to protect our rights or property or the rights or property of others, or in the event of a claim or dispute relating to your use of the Website, the App and/or the Services. We store all user information on a cloud server, and such information is encrypted both in transit and at rest.

How Do You Update, Disable, or Delete Your Information?

We want you to be in control of your information. If you are a user of the Service, you can manage the information that you provided to us by updating your profile at any time under your account settings.

If you are using the Services at the recommendation of your practitioner and you no longer wish to use the Services, you may contact Mindyra to disable your account; however, you should be aware that your practitioner may retain information about you in your medical record.

Disabling your account does not notify us that you no longer wish to receive communications from us. Additionally, you should be aware that it is not always possible to completely remove or modify information in our databases. If you no longer wish to receive communications from us, please unsubscribe and opt-out of receiving these communications by using the link in an e-mail communication. Please understand that your ability to opt out from receiving marketing and promotional communications does not change our right to contact you regarding your use of the Website, the App or the Services.

How Is Your Information Maintained?

We store all user information on a cloud server, and such information is encrypted both in transit and at rest.

Links to Third Party Services. The Website and App may contain links to third-party websites (the “Third Party Services”). For example, the Website and App may contain links to Third Party Services to aid practitioner payment for access to the Services. If you decide to visit and submit any information to a Third Party Service, you are subject to such Third Party Services’ privacy policy and practices and not this Privacy Policy. We encourage you to review carefully the legal and privacy notices of all other digital services that you visit.

Security. We recognize the importance of our customers’ information and strive to protect the security of your information. In so doing, we take reasonable technical safeguards to protect the confidentiality, integrity and availability of your information. Moreover, our employees are educated on the importance of our privacy and security policies and must comply with them. However, despite our efforts, there is always some risk that an unauthorized party may inappropriately infiltrate security systems that are in place or that electronic transmissions of your information may be intercepted. Please keep this in mind when using the Services. the Website and the App.

Children’s Personal Information. The Website, the App and the Services are not directed to children under the age of 13, and we do not knowingly collect information from children under 13, unless, however, the information is provided by a child’s parent and/or guardian.

HIPAA. As a provider of services and technology to the healthcare industry, we are often a business associate of covered entities (health care providers, health plans and/or health care clearinghouses). Under HIPAA, each covered entity is required to provide its patients with a Notice of Privacy Practices.To the extent that an affiliate of ours is a covered entity, a Notice of Privacy Practices should be provided to each patient or made available to each patient. However, any such Notice of Privacy Practices is not related to any practice described in this Policy.

Notification of Changes to Privacy Policy

Our Policy may change from time to time. We will always post an up-to-date version on our Website, with the latest revision date posted at the top of the page. We encourage you to periodically review this policy to see if any changes affect you.

We regularly review our compliance with this Policy. If you have any questions, please contact us at: info@mindyra.com.