Privacy Policy

Effective Date: February 1, 2024

Last Revised: February 1, 2024

1. Introduction.

SJDD Consultancy LLC (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website http://sjddconsultancy.com (our “Website”) or in connection with the online therapy services (the “Services”) provided via our Website or through the software applications made available by us for use on or through computers and mobile devices (the “Apps”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect from the functionalities and in the manner(s) described in the bullet points immediately following this sentence.

• On this Website.
• In email, text, and other electronic messages between you and the Company.
• Through the Apps or other mobile and desktop applications which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• Any other sources.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this document carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or our Services. By accessing or using this Website or our Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website or the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

2. Children Under the Age of 18.

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal data to or on the Website. We do not knowingly collect personal data from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at our Website.

3. Information We Collect About You, How We Collect It and What We Do With It.

When you sign-up, inquire about enrolling for or use the Services, we keep a record of medical information that you provide to us or your provider as well as any medical information that the Company’s employees or independently contracted providers (collectively, “Providers”) provide to you via our Website or the Apps. Medical information means any information that:

• identifies you; and
• relates to your past, present, or future physical or mental health, treatment, the provision of health care services or payment for treatment.

This includes medical history, diagnoses, treatments, current medical condition, and use of prescription medications. If you are a US subscriber to our services, your personal data in our possession is protected health information (“PHI”) protected by the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”), and the applicable provisions of the Health Information Technology for Economic and Clinical Health (“HITECH”) Act. In addition to this Privacy Policy, the HIPAA Notices of Privacy Practices of the Company or your Provider apply to your PHI.

This Policy explains the Company’s practices where we process “personal data”, which is information that relates to an identified or identifiable individual. To “process” or “processing” means the use of personal data including, collecting, recording, storing, using, analyzing, combining, transferring, disclosing, or deleting.

We collect several types of information from and about users of our Website and the Apps. The following is a chart of the types of information we collect, how we collect it and what we do with it:

 

 

Types of Personal Data	How We Get It	What We Do With It
Registration Information you provide when you create an account for yourself (or an authorized account for a minor), are matched to a Provider, or register yourself (or on behalf of a minor) as a client: · 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 Provider · 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	You provide this when you go through the intake process	· Provide you with the Services (including resubscription) · To match you to a Provider · 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 · Respond to a valid legal request · Process claims or insurance information · Provide you with and to evaluate, improve and develop the Services · Conduct Provider 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 Services, including: · Information you disclose in chat data and your chat sharing preferences (transcripts) · Audio/Video communication · Documents you share with your Provider 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 “like” · 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 family 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 address client 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 client 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 (Providers and clients)
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 our technical 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 (Providers and clients) · 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	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

 

The technologies we use for this automatic data collection, from time to time, may include cookies, scripts, pixels, or web beacons.

We do not collect personal data automatically, but we may tie this information to personal data about you that we collect from other sources or you provide to us.

4. Third-Party Use of Cookies and Other Tracking Technologies.

Some content or applications on the Website and the Apps are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website or the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt-out of receiving targeted advertising from many providers, see “Choices About How We Use and Disclose Your Information”.

5. Disclosure of Your Information.

We do not sell, rent or lease our client lists to third parties.

We may disclose aggregated or anonymized information about our users without any restrictions. We will not share your personal data that we collect, or that you provide as described in this Policy, except in the circumstances specified in the bullet points immediately following this sentence.

• With subsidiaries and affiliates for business purposes as permitted.To our subsidiaries and affiliated companies for purposes of management and analysis, decision-making, and other business purposes.
• When we work with service providers. To service providers, contractors, and other third parties that provide us with support services, such as credit card processing, website hosting, email and postal delivery, location mapping, product and service delivery, or analytics services, and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
• When we become involved in a sale or transfer of the Company. If we become involved with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding), to business entities or people involved in the negotiation or transfer.
• When we are required by law. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• When we enforce our rights. To enforce or apply this Policy, our Terms of Use, and other agreements, including for billing and collection purposes.
• To help protect lawful interests. If we believe disclosure will help us protect the rights, property, or safety of the Company, our users, partners, agents, and others. This includes exchanging information with other companies and organizations for fraud protection, and spam and malware prevention.
• To fulfill the purpose for that information or with your consent. To fulfill the purpose for which you provide the information, for any other purpose disclosed by us when you provide the information, or with your consent.

Information that you post on or through the public areas of the Services (e.g., chat rooms, bulletin boards, and discussion groups) are generally accessible to, and may be collected and used by, others and may result in unsolicited messages or other contact from others. Users of the Services are encouraged to exercise caution when providing personal data about themselves in public or interactive areas.

“Do Not Track” is a privacy preference you can set in most web browsers. When you turn on this preference, it sends a signal or message to the websites you visit indicating that you do not wish to be tracked. Please note that we currently do not respond to Do Not Track browser settings.

6. Choices About How We Use and Disclose Your Information.

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with control over your information as detailed in the bullet points immediately following this sentence.

• Cookies & Other Tracking Technologies. You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or that allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings. If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or may not function properly.
• Promotional Communications from the Company. If you do not wish to have your contact information used by the Company to promote our own or third-party products or services, you can opt-out by: (i) informing us of your preference at the time you register for an account; complete an order form, sign up for our newsletter, or complete any other form on or through the Services which we collect your data; (ii) modifying your user preferences in your account profile by checking or unchecking the relevant boxes; (iii) following the opt-out instructions in the promotional emails we send you; or (iv) sending us an email stating your request. Please note that if you opt-out of receiving promotional communications from us, we may still send you transactional communications, including emails about your account or purchases.
• Location Information. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by: (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or your device manufacturer.
• Voice Transmissions. You may be able to adjust the settings of your device so that your voice transmissions cannot be sent to us or third parties by: (a) disabling microphone and speech recognition services within the device settings; or (b) denying certain websites or mobile applications permission to access microphone and speech recognition services by changing the relevant preferences and permissions in your mobile device or browser settings.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

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

You may request access to, correction of, or deletion of your personal data. Within our reasonable discretion, 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 send us an email where you state your request and include a copy of your photo identification to: info@SJDDConsultancy.com.

8. How long do you retain my data?

Our data retention policies are based upon the type of data, whether or not you have used our Services, and whether you have proactively requested data erasure or if the erasure is triggered due to Website or Services inactivity.

Generally, 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.

Certain categories of data are retained for a period of time after you become inactive. These categories of data are retained to allow for a seamless reactivation in the event you begin using our Services again and allow Providers to reference historical information. Retaining this data is also needed to ensure our products and services function.

9. Transfer of Information to the United States.

Our site is operated in the United States and intended solely for users located in the State of Texas of the United States. If you are located outside of the United States, please be aware that information we collect, including personal data, will be transferred to, processed, stored and used in the United States. The data protection laws in the United States may differ from, and may be less protective than those of the country, or aggregation of countries subject to common regulation, in which you reside or are located, and your personal data may be shared with third parties for direct marketing purposes and may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using our Website, Services, or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including personal data, in the United States as set forth in this Privacy Policy.

10. Data Security.

We take reasonable precautions to secure your personal data. We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. When you transmit highly sensitive information (such as a credit card number) through the Services, we encrypt the transmission of that information using Secure Sockets Layer (SSL) technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website or the Apps. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or the Apps.

11. Changes to Our Privacy Policy.

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal data, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

12. Terms of Use.

If you choose to visit the Website and/or use the Services, your visit and any dispute over privacy is subject to this Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the governing law.

13. Contact Information.

To ask questions or comment about this privacy policy and our privacy practices, contact us at

Email: info@SJDDConsultancy.com.

Address: SJDD Consultancy LLC, 1333 W McDermott Dr., Suite 200, Allen, TX 75013, United States of America.