Privacy Policy

What is this document?

Privacy policies can be dense and inaccessible. Sometimes you just want your question answered quickly without having to navigate pages of text. With this document, we hope to make that easier. We tried our best to make our Privacy Policy as easy to navigate and understand as possible. If you have any questions while reading it, please don’t hesitate to reach out to info@lyfeline.africa.

For purposes of this Policy and unless otherwise specified, “data” includes information that is linked to one person or household including things like name, email address, phone numbers, device ID, Third Party identifiers, contact information, and communications with Therapists using our digital communication platform (the “Platform”) to provide services (“Therapists”). Some jurisdictions might consider this to be “personal data,” “personally identifiable information,” or “sensitive personal data” in certain circumstances. When you use and access our app or website, you accept and agree to both the Terms and Conditions and this Privacy Policy, including that we’ll share certain data with Service Providers.

Will this document be updated?

We may update this Privacy Policy. When we make significant changes to this Policy, we will notify you through our website or app when you log in to your account. We encourage you to periodically review this page for the latest information.

How to navigate this document

This document is broken into seven sections divided by topic. To navigate to a section, reference the list below which provides examples of the types of questions that will be answered in that section. When you find a section that interests you, just click on it and you’ll be automatically directed there.

Data Collection and Processing

SECTION 1

Data Collection and Processing

• What data do we collect, store, and Process?
• Why do we collect and Process this data?

SECTION 2

Data Sharing

• Why do we share your data?
• How do you use my data to comply with the law?
• Do we sell your data?
• Do we share any information between you and your Therapist with Third Party advertisers?

SECTION 3

Data Retention, Erasure, and Exporting

• How long do we retain your data?
• What type of data do we retain and why?
• How can you request data erasure or a copy of your data?
• Why do we need to retain your data to comply with the law?

SECTION 4

Security and Anonymity

• How do we keep your data secure?
• How do you best remain anonymous when using Lyfeline?
• Who can see the conversations with your Therapist?

SECTION 5

Cookies and Web Beacons

• What is a cookie or web beacon?
• What do we use them for?
• How can you opt in / opt out of them?

SECTION 1

Data Collection and Processing

Do you collect, store, or Process my data?

The categories of data which we are listed below. We Process this data to do things like operate the Platform and make sure you are able to use our services effectively. We may also Process data to send you periodic emails or text messages. In some cases, these communications are to help provide services. Other times, they are to provide marketing communications. You can opt out of receiving texts or marketing communications at any time. Additionally, provided you opt in, we may Process and share some data with Third Parties for advertising purposes. You can find more details in the relevant sections of this Policy.

What specific data are you Processing and why do you collect it?

What data we Process depends on how you’re using our website, app, or the Platform. We explain in the section below the specific data we collect and Process and, in the section following this, the business purpose for collecting and Processing this data.

As highlighted in the table below, we collect and Process “Therapy Data“, which includes health and treatment information that is required to facilitate therapy.

You can find information on how long we store the data we collect and Process these categories of data in the “How long do you retain my data and how do I request data erasure?” section of this Privacy Policy.

Name of category of data, Information that is collected and what it is used for

1. “Visitor data”

What is collected:

When you visit the website, app, or Platform, we Process information like the particular pages visited or which features you interacted with, the amount of time on the website or app, site/app/Platform errors, information about the type of device and browser you’re using, and IP address. We may Process IP address, hashed email address, External Identifiers and Internal Identifiers (if available based on the settings of your device) and will share the information with Third Parties, if you opt in to Advertising (previously “Targeting cookies”) and web beacons.

What it is used for:

• Connecting you with therapy services
• Facilitating tools for you and your Therapist
• Communicating with you
• Monitoring and improving therapy quality
• Personalizing your web or app experience
• Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
• Complying with laws
• Protecting your safety and the safety of others
• Send opportunities, promotions, news, updates and reminders about our services and your account

2. “Onboarding data”

What is collected:

To create an account with the Platform, the user first fills out a questionnaire. We Process the information used to complete this questionnaire.

What it is used for:

• Connecting you with therapy services
• Monitoring and improve therapy quality
• Personalizing your web or app experience
• Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
• Complying with laws
• Send opportunities, promotions, news, updates and reminders about our services and your account

3. “Account Data”

What is collected:

Once a user creates an account with the Platform, we Process data such as the account name the user selects, and other demographic and contact information, such as email, age, phone number, emergency contact details, and whether a user verifies their email address.

What it is used for:

• Facilitating therapy tools for you and your Therapist
• Personalizing your web or app experience
• Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
• Complying with laws
• Protecting your safety and the safety of others

4. “User ID”

What is collected:

We assign each user (including Therapists) who create an account a sequentially-generated user ID. User IDs are unique to each account and are required in order to enable the Platform to function.

What it is used for:

• Connecting you with therapy services
• Facilitating therapy tools for you and your Therapist
• Communicating with you
• Monitoring and improving therapy quality
• Personalizing your web or app experience
• Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
• Complying with laws
• Protecting your safety and the safety of others
• Send opportunities, promotions, news, updates and reminders about our services and your account

5. “Transaction Data”

What is collected:

We Process data about payment transactions on the Platform such as whether a user completed payment for our services, signed up for services using a trial offer, canceled or ended a trial, received a discount or financial aid, or received any extensions or refunds. We also process whether a visitor has registered to create an account.

What it is used for:

• Connecting you with therapy services
• Facilitating therapy tools for you and your Therapist
• Communicating with you
• Monitoring and improving therapy quality
• Personalizing your web or app experience
• Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
• Complying with laws
• Protecting your safety and the safety of others
• Send opportunities, promotions, news, updates and reminders about our services and your account

6. “Engagement Data”

What is collected:

We Process usage data about how you interact with emails we send and different features when you’re logged into the platform. For emails we send, we collect usage data including whether you receive an email, open it, and click any links it contains. When you log onto the Platform, we also collect usage data about activity conducted during that logged in session such as when a user logs in, the login timing, number and length of messages received or sent through the Platform, received or sent message timing, number and duration of live session scheduled or conducted, the number and timing of use of other features such as worksheets, journals, and goals. This category does not include Therapy Data like the content of any messages sent or received by users, the content of any live sessions, or the content of journal entries, worksheets, or goals.

What it is used for:

• Facilitating therapy tools for you and your Therapist
• Communicating with you
• Monitoring and improving therapy quality
• Personalizing your web or app experience
• Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
• Complying with laws
• Protecting your safety and the safety of others
• Send opportunities, promotions, news, updates and reminders about our services and your account

7. “Therapy Data”

What is collected:

We Process written communications and related information users share with their Therapist to facilitate the therapy. This includes messages with Therapists, worksheets, and journal entries. Users may also choose to send audio messages which are automatically transcribed. We do not record the video or audio sessions with Therapists.

What it is used for:

• Facilitating therapy tools for you and your Therapist
• Complying with laws

8. “Therapy Quality Data”

What is collected:

We Process client feedback about their Therapist including, ratings and reviews of their Therapist, actions regarding switching Therapists or quitting therapy, and the reason selected by the client. We Process Therapist session availability, session cancellations and no-shows.

What it is used for:

• Connecting you with therapy services
• Facilitating therapy tools for you and your Therapist
• Communicating with you
• Monitoring and improving therapy quality
• Personalizing your web or app experience
• Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
• Send opportunities, promotions, news, updates and reminders about our services and your account

9. “Customer Service and Communications Data”

What is collected:

We Process communications users have with our Customer Service team.

What it is used for:

• Communicating with you
• Complying with laws
• Protecting your safety and the safety of others

10. “Therapist Data”

What is collected:

In order to engage with Therapists who express an interest in working with us (such as individuals who provide information at in-person or online recruitment events), follow up with Therapists who applied to work with us on the status of their applications, to identify, match, credential, re-credential, run checks, issue 1099s and pay Therapists, we process Therapist information such as the Therapist’s name, bank account information, gender, date of birth, governmental identification numbers (SSN/FEIN), e-mail address, phone number, address, NPI number (if applicable), license information, CAQH number (if applicable), and areas of interest/expertise, education, and job history. Therapists may also separately and outside of this Policy, consent to using facial scans to assist logging them in and verifying their identity.

What it is used for:

• Connecting you with therapy services
• Facilitating therapy tools for you and your Therapist
• Communicating with you
• Personalizing your web or app experience
• Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
• Complying with laws
• Protecting your safety and the safety of others
• Send opportunities, promotions, news, updates and reminders about our services and your account

11. “Therapist Engagement Data”

What is collected:

For Therapists, we process such data as number/times of Therapist logins to the Platform, the number of live sessions conducted by a Therapist, number of messages and words exchanged by a Therapist, number of worksheets shared by a Therapist, and number of journal entries shared with a Therapist.

What it is used for:

• Connecting you with therapy services
• Facilitating therapy tools for you and your Therapist

12. “Clinical Health Record”

What is collected:

We Process “Clinical Health Record” which is a record with the minimum information your therapist would need to identify you and document the services you received. This Record includes your therapist’s internal notes, dates you received services, and the following specific subsets of Onboarding, Account, and Therapy data:

• “Onboarding data”: Onboarding Questionnaire Answers
• “Account data”: Account name the user selects, phone number (if one is provided), email address, emergency contact details
• “Therapy data”: Dates of service, messages with therapist, worksheets, journal entries that are shared with therapist, therapist’s internal notes

If you’re a Therapist on our Platform, or being recruited to join us, in addition to the above, we may Process Therapist Data, Therapy Quality Data, Therapist Engagement Data, User ID, Onboarding Data, Account Registration Data to:

• Assist in the Therapist recruitment process and onboard you to the Platform;
• Operate the Platform, match clients to you based on your preferences, and facilitate the communication between you and your clients;
• Verify your identity and secure your account;
• Run background checks and other screening required for credentialing and recredentialing purposes;
• To pay you and comply with all relevant tax laws;
• Provide you quality statistics, feedback from our Lyfeline Clinical Operations team, and feedback from clients.
• Offer you information about new features, opportunities, perks and other incentives.
• Promote your profile on Lyfeline and with Third Party websites and directories to get you more clients (to opt-out email info@lyfeline.africa).
• Send you email, calls or SMS reminders, notifications & updates about your application, profile or account.

In addition to processing, we also share some data with Service Providers in order for us to operate the Platform and to perform necessary website and application functions. Additionally, when you opt into sharing, we share certain data with Third Parties. For more information please see the section: “What are the purposes for sharing my data?”

If you opt in to Advertising (previously “Targeting cookies“) and web beacons we process Visitor Data for advertising purposes: To learn more, see section, “Are you using my data for advertising?”.

Do you Process location data?

We process your IP address to determine your rough location so that we can personalize the platform for you. For example, we show you relevant information about our service that applies to visitors from your country.

We also utilize your rough location to improve your user experience when using our platform. For example we auto populate your state (if applicable) and country when you are completing our onboarding questionnaire.

We do not request or process exact location information such as information provided by your phone via GPS.

We Process your address information when you provide it as part of your emergency contact information when you start therapy on the Platform. Your contact information is required to comply with therapy regulations and ethical code. It can be used, for example, in case your Therapist believes you are in immediate danger. When you are filing out this field, we may process your rough location to provide autocomplete suggestions for your convenience.

Rough location using your IP address is also Processed by the ReCAPTCHA security API tool we use. ReCAPTCHA is a Service Provider we use to identify potentially malicious actors trying to access our site. Here is the ReCAPTCHA Privacy Policy and Terms of Service.

To learn about the additional purposes for which we Process IP addresses, please see:

• Why do you collect and Process my data?
• Are you using my data for advertising?
• Additional Privacy Notice for California Residents

SECTION 2

Data Sharing

What are the purposes for sharing my data?

Here’s some more information about the purposes for which we share your data:

• Your data may be shared to comply with applicable laws. For example, a court might subpoena information from us where we would be required to share certain information requested in the subpoena. This is not unique to Lyfeline and is applicable to in-person therapy as well. Keep in mind that, as a general rule, we defer to your chosen Therapist to decide to produce (or not produce) any psychotherapy notes or messages you have had with them. Many jurisdictions have strict rules governing Therapist/client relationships and the confidentiality requirements associated with that. We encourage you to discuss with your Therapist early on if you have concerns about their disclosure obligations.
• Occasionally, your data may be handled by a select number of employees who are part of our parent company for support services. These employees are under strict duties of confidentiality. For example, a paralegal at our parent company may receive subpoenas or legal correspondence on behalf of Members or former Members and make sure they are provided to Lyfeline’s Legal team to address.
• We may share certain data with Service Providers12 that provide limited services that help us operate the Platform. Examples include:

1. Data hosting and storage providers: For example, cloud hosting providers such as Amazon Web Services (AWS).
2. Technology Service Providers: For example, we sometimes integrate tools into our Platform which give our Platform more functionality, like technology that helps us provide live audio, video and group meetings.
3. Customer Service Providers: For example, we use a tool that helps keep track of requests and questions from our Members, visitors and Therapists in a secure way. Email management and communication Service Providers: For example, we may use a tool that makes reaching out to you easier for us and more convenient for you.
4. Billing and payment processing Service Providers: For example, we use Stripe to help process payments in a secure way. Stripe also assists us in paying Therapists and issuing tax documents to them. For this purpose, we may share email addresses of Therapists with Stripe and other data that is needed to pay Therapists such as a Therapist’s name and tax ID.
5. Reporting and analytics Service Providers: For example, we might use a service to help us keep track of which pages and features are most used on our site.
6. Advisors and lawyers: To assist with business matters.
7. We may share some of your data with Service Providers to ensure the safety and security of the Platform and that of our users.
8. If you’re a Therapist on our Platform, or being recruited to join us, in addition to the above, we may share certain data with Therapist recruiters in order to facilitate, monitor, and track the recruitment process.
9. For Members who receive services in connection with an employer, organization, or other business partner, we may share group-level usage data, which cannot be directly connected to you, with your organization. In the instance of Members who receive services through an Employee Assistance Program (“EAP”), your EAP will provide notice for any individual-level data which is shared with the EAP, if you are utilizing one and have provided them with consent for us to do so. If you have any questions on how your data will be used by or shared with your EAP, please reach out to your EAP directly.
10. We may share some of your data in connection with an asset sale, merger or bankruptcy.

Note that if you make any information publicly available on the Platform, such as with a public post, anyone may see and use such information.

If you opt in to “Analytics (previously “Performance cookies”)”, we may use analytics cookies from trusted Service Providers to Process1 data for activities including but not limited to analyzing traffic sources, visits, and site interactions. This analysis helps us to improve our products and services.

If you opt in to “Advertising (previously “Targeting cookies”)” and web beacons, information regarding your activity on our websites, excluding activity when you’re logged in and have started therapy, may be shared for advertising purposes. To learn more, see section: “Are you using my data for advertising?”

How do you use my data to comply with the law?

When required by law, we cooperate with government agencies. This is not unique to Lyfeline and is applicable to in-person therapy as well. For example, a court might subpoena information from us where we would be required to share certain information requested in the subpoena. Keep in mind that, as a general rule, we defer to your chosen Therapist to decide to produce (or not produce) any psychotherapy notes or messages you have had with them. Many jurisdictions have strict rules governing Therapist/client relationships and the confidentiality requirements associated with that. We encourage you to discuss with your Therapist early on if you have concerns about their disclosure obligations.

You should also be aware that Therapists may be obliged to disclose information to authorities to meet professional and legal responsibilities. Specifically, some laws require mental health professionals to disclose information and/or take action for: (a) reported or suspected abuse; (b) serious suicidal potential; (c) threatened harm; and (d) court-ordered treatment. You should speak with your Therapist if you have concerns about this.

Do you sell my data?

We aren’t paid by anyone for any data. However, in California, the laws define “sale” broadly to include the sharing of personal information in exchange for anything of value. If you opt in to our use of Advertising cookies and web beacons, this use may be considered a “sale” of personal information under that specific California law. For specific information on your data rights as a resident of California, see the additional notice for California residents.

Are you using my data for advertising?

In order to reach people who may be looking for mental health support, we advertise on some Third Party web properties such as Third Party websites and apps. In order to minimize advertising costs related to this process and downstream costs to you, we strive to deliver ads that are relevant, interesting, and personal.

Therefore, if you opt in to Advertising cookies and web beacons, some Visitor Data, excluding activity when you’re logged in and have started therapy, may be shared for advertising purposes. As a result, you may see ads for our services on some Third Party websites.

If you use the App and have “Allowed” app to track using IOS or have opted into Advertising Cookies on Android, some data such as your mobile device identifier (IDFA and IDFV for iOS, and Android Advertising ID for Android) and data about how you use the App which is collected by our Service Provider Google (specifically GA4) will be used to make our Google advertising more effective. This happens through an integration we have enabled between GA4 and Google Ads. If you do not want to enable this, for Android users, you can navigate to “Sharing Settings” in the App and opt out of advertising. For IOS users, you can “Ask App Not to Track” when you download the app or, at a later time, go to your device’s privacy settings to see a list of apps that requested to track your activity (Go to Settings > Privacy & Security* > Tracking). From there, you can tap to turn off or turn on permission to track for the Lyfeline app.

Even if you do opt in, we still do not engage in “retargeting” advertising. Retargeting advertising is a type of advertising whereby advertisers leverage the fact that you viewed a page or took an action on their site to advertise to you again on third party properties in the hope that you will see the ad and return to their site.

To be clear, we don’t share any data or information you share with your Therapist with any Third Party advertisers. Even if you opt in to Advertising cookies and web beacons, we still don’t share information with Third Party advertisers like Member names, email addresses, phone numbers, clinician diagnosis, questionnaires answers, sessions data, journal entries, messages, worksheets, or any other type of private communication you have with your Therapist on the Platform.

For additional information regarding Third Parties that Lyfeline may share data with, please reference our Third Party Partners Disclosure List.

SECTION 3

Data Retention, Erasure, and Exporting

How long do you retain my data and how do I request data erasure?

Lyfeline is committed to ensuring that all applicable Member data is retained only for the amount of time required to provide relevant products and services and in accordance with relevant legal requirements.

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

In addition to the data retention schedule outlined below, Lyfeline maintains a process for all Members (regardless of where they live) to receive and process, without undue delay, requests to erase or access their data.

The following sections describe both how long a Member can expect their data to be retained for given specific account information as well as how to request data erasure and access. In this Policy, data erasure is defined as the permanent removal or obfuscation of identifiable data (See “What is this Privacy Policy”) so that it is no longer accessible by anyone.

Retention Policy

Lyfeline’s data retention policies are based upon what data is being Processed1, whether or not the Member has participated in therapy, and if the Member proactively requested data erasure or if the erasure is triggered due to Platform inactivity.

I am a Member who and How long your data is retained

• Did not start therapy and Did not request data erasure

Your data is retained for 3 years after your last login date and is then erased.

• Did start therapy and Did not request data erasure

Your data is retained for 10 years after your last login date and is then erased.

• Did not start therapy and Did request data erasure

Your data is erased within 24 hours of the erasure request.

• Did start therapy and Did request data erasure

Your information which is classified as Clinical Health Record (See “What Specific Data are you Processing”), Communications (e.g. record of Member complaints or deletion requests), or disclosures of PII to Third Parties2 is erased after 10 years.

All other personal identifiable information in the following categories is erased within 24 hours of the erasure request: Visitor Data; Onboarding Data; Account Data; User ID; Transaction Data; Member Engagement Data; Therapy Data; Customer Service and Communications Data.

Exercising Your Data Protection Rights:

As stated, you have certain rights under data protection laws, including the right to request that we erase personal data we hold about you, and the right to request a copy of it. The following sections describe how you can exercise those rights.

Requesting Data Erasure:

To request data erasure, please log in to your account and go to Menu > My Account (or Account Settings) > My Personal Information, where you will see a link to request complete erasure of your account. Click that and follow the instructions to begin the data erasure process. You will receive a confirmation email from us within 24 hours of your request.

If you do not have access to your account or are having trouble with this method, you can directly contact Member Success as contact@lyfeline.africa and they will assist you with the process. As with the first way, you can expect a confirmation email within 24 hours of your request.

Additionally you can visit our opt out instructions page to request erasure or to opt out of previous settings you have opted into.

You may reach out to us at info@lyfeline.africa if you need additional help. We will only comply with a request for the erasure of your data if we can verify your identity. There is usually no charge. In exceptional circumstances, we may charge a reasonable fee after discussing the fee with you.

If you reach out to either Member Success or info@lyfeline.africa, we have specific requirements that must be met in order for us to process your data erasure request.

Requirements:

• Only you or your authorized representative may make a request on your behalf. You may also make a request on behalf of your minor child depending on the applicable laws.
• You must provide sufficient information that allows us to reasonably verify your identity or status as an authorized representative.
• You must provide details that allow us to understand, evaluate, and respond to your request.

If a Member joined the platform via an organization or Employee Assistance Program (“EAP”) then the only way to erase their account will be via contacting Member Success. The Member will not be able to request account erasure from within the Platform.

In some circumstances, legal or regulatory requirements limit our ability to honor erasure requests. As such, we may decline requests for erasure if the information is:

• Subject to a litigation hold or legal request to preserve it.
• Necessary to comply with laws and regulations and to maintain business integrity.
• Clinical Health Record (described above) falls under this exemption.

Additionally, compliance obligations require us to retain records documenting certain interactions you have with us related to your Membership. As such, we cannot honor erasure requests for information contained in records of:

• Communications about complaints and erasure or access requests.
• Disclosures of personal data to Third Parties.

If we don’t intend to comply with a request, then we will tell you why this is the case, and outline how we weighed your rights and freedoms against our legal obligations. In such instances, any information retained will only be used for purposes contemplated under the legally recognized exemption.

Requesting a copy of my data

To receive a summary copy of your data, please log in to your account and go to Menu > My Account (or Account settings) > My Personal information, where you will see an option to request a copy of your data. The data you will receive as part of this request includes the contact information that you input on the site, questionnaire answers, worksheet entries, emergency contact information, messages you sent to your Therapist, journal entries that you created, and other personal information.

Additional data which we maintain includes email interactions with our help desk, which is stored on your email system. You may also request this information by writing to info@lyfeline.africa. As with data erasure, we are not always able to respect your request for data access. For more information on why this may be and how the situation will be handled, please reference the previous section.

SECTION 4

Security and Anonymity

How do you keep my data secure?

We apply industry standards and strive to apply best practices to prevent any unauthorized access and disclosure. Internet-based services carry inherent security risks, but our systems infrastructure, encryption technology, operation and processes are all designed, built, and maintained with your security and privacy in mind. 

Lyfeline has an experienced team of data security professionals whose job it is to make sure we use secure technology to protect your data. We have an Information Security team who test internal security at Lyfeline to try and anticipate threat actors and act defensively to build processes and infrastructure to prevent incidents and attacks. We have numerous robust security practices such as:

• All messages between a Member and their Therapist are secure and have 256-bit encryption.
• Our servers are distributed across multiple Tier 3 AWS Data Centers for optimal security and protection.
• Our browsing encryption system (SSL) follows modern best practices.
• Our databases are encrypted and scrambled rendering them useless in the unlikely event that they are stolen or inappropriately retrieved.
• We have robust monitoring and alerting systems and procedures in place that include both automated systems and humans. For example, there are always security personnel active in our 24/7 rotation.

For your own security, keep the following in mind:

• Phishing: This is a type of online identity theft or account hacking. We will never request your login information or credit card information in any non-secure or unsolicited communication. You should always be diligent when you are asked to provide your account information and make sure it is in our secure system.
• External links: Our Platform may contain links to an external website or service. We do not control external websites, and do not have control over their privacy policies and terms of use. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that external party or of their privacy and security policies or practices.

Can I sign up for Lyfeline and remain anonymous?

When you sign up for an account on Lyfeline, we ask you for your full name. You have to provide your “fullname” which will identify you in the system. You will need to provide an email address so that we can verify your account, and so we can communicate with you. You can choose an email that does not include your name (including if you are coming to us from an employer, organization, or other business partner and do not want to use your organization’s email address), but you should be aware that in some jurisdictions emails may be considered “personal data,” “personally identifiable information,” or “sensitive personal data” in certain circumstances. Your Therapist may request additional specific information about you as required by their license or other accreditation guidelines.

Even though we try to limit the kinds of information you must provide to us as discussed above, it is very difficult to be truly “anonymous” when you use any app or the internet. Read more about what data we Process1 and why here:

• What specific data are you Processing?
• Do you Process location data?
• Why do you collect and Process my data?
• What are you using cookies and web beacons for?

If you’re interested in further limiting what data is Processed, visit our opt-out instructions page to opt-out of tracking via cookies or web beacons, or for instructions on how to remove previously set cookies.

Who can see the interactions I have with my Therapist?

You and your Therapist are able to see the messages you send, the worksheets you submit. Your Therapist can also see the journal entries you submit if you opt in to sharing journal entries.

If you consent, a licensed Therapist who is employed as part of the BetterHelp Clinical Operations Team may review correspondence with your Therapist for quality assurance purposes. For example, if you raise a concern about your Therapist, or if we have concerns about a specific Therapist’s clinical care.

In addition, our internal Trust and Safety or Legal teams may review correspondence for specific accounts if we have a reason to believe that there is a security, legal, or fraud issue occurring with that specific account.

Messages with your Therapist are not shared with any Third Party, and your live sessions are not recorded. We also do not share when you send a message, or have a session with your Therapist, with any Third Party.

How do you treat data from children?

We don’t knowingly collect or solicit any data or information from anyone under the age of thirteen (13) or knowingly allow such persons to become our users. The Platform is not directed at and not intended to be used by children under the age of thirteen (13). If you’re aware that we have collected personal information from a child under age thirteen (13), please let us know by contacting us, and we’ll delete that information.

SECTION 5

Cookies, Web Beacons and Contact

What is a cookie or web beacon?

A “cookie“ is a small data file that is accessible within a folder on a computer, and it is used for record-keeping purposes. Cookies are used to enhance performance of the Platform, personalize your experience and can be used for Third Party tracking (as described above). For example, cookies may be used to help you quickly log into certain platforms and websites without having to enter your credentials every time.

A “web beacon“ or “pixel” is a tiny and sometimes invisible image or embedded code, placed on a web page or email that can report your visit or use to a Third Party (as described above). In general, these tools can be used to monitor the activity of users for the purpose of web analytics, advertising optimization, or page tagging.

What are you using cookies and web beacons for?

We use our own, Service Providers and Third Party cookies and web beacons to deliver a faster and safer experience, to monitor and analyze usage, to comply with laws, and for advertising purposes. To read more about the kinds of Third Party cookies we use and their purposes, to update your settings, or to opt out, click here.

How do I opt out of cookies, web beacons, and other tracking technology?

Please visit our opt-out instructions page to opt-out of tracking via cookies or web beacons, or for instructions on how to remove previously set cookies.

How can I stop receiving direct marketing emails from you?

You can always opt out of receiving marketing emails. In order to opt out, you can select the unsubscribe link located at the bottom of the relevant email communication.

Contact Information and responsible Lyfeline Entities. 

For questions or complaints about this Privacy Policy or Lyfeline’s handling of personal information (i) If you reside in Nigeria contact Lyfeline App Limited, No. 2 Aliade Cl, Garki or by emailing us at hello@lyfeline.africa or by calling us at (+234) 916-011-1135.