Privacy Policy

Updated 25 September 2019


1. Overview

Your privacy is extremely important to us. This Privacy Policy informs you of our policies, procedures and practices regarding the collection, use and disclosure of any information that you provide through the Platform.

Capitalized words used in the Privacy Policy have the same definition as in the Terms of Service. Read both documents carefully. When you use the Platform, you are agreeing to all the terms in both the Terms of Service and Privacy Policy. If you do not agree to be bound by any part of them, you must not access the Platform and should stop using it immediately. By accessing and using the Platform, you confirm that you have read the Terms of Service and Privacy Policy, and that you understand, agree and acknowledge all the terms contained in them.

2. Information Collection and Use

In order to operate the Platform effectively and optimize your experience as a User, we may collect your personally identifiable information. This may include, but is not limited to, your name, email address, physical address, billing information, debit card or credit card or other Payment Method information, profile information, sign in password, visit log data (such as your IP address, pages you visit, amount of time spent, or actions you take), session history, session data (such as distress ratings, information you enter into the session worksheets during a session), and emails exchanged (collectively the “Information”). In some cases, the Information that you provide to us may be considered health-related data.

You may decide which Information you would like to share with us, but some features and functions of the Platform may not be available to you if you do not provide us with the necessary Information. By deciding to provide the Information, you agree to our methods of collection and use, and the terms of this Privacy Policy.

PROTECTING YOUR INFORMATION IS AN IMPORTANT PRIORITY FOR US. WE DO NOT SELL OR RENT YOUR INFORMATION TO THIRD PARTIES.

Here are some of the ways we may use your Information:

  • Creating your Account on the Platform
  • Enabling you to log in to your Account and use the services for registered Users
  • Managing your Account, providing customer support and ensuring that you are happy with your experience
  • Contacting you or providing you with information, notices, alerts, promotions and suggestions. You may opt out of receiving marketing and promotional emails from us at any time by clicking on the "unsubscribe" link in the emails
  • For billing and payment processing purposes
  • Connecting you with Additional Services that you have requested or are potentially interested in, such as coaching or therapist support
  • Tracking your usage of the Product and measuring the quality, effectiveness and delivery of our services. If tracking data is used for marketing or sales purposes, only aggregated data that does not enable the identification of any individual User is used
  • With your specific and express consent, Sharing your story with other Users in the form of a testimonial, User story, inspiration or motivation, or similar. Your name and personal details will also never be shared in a manner that can identify you, unless you have specifically and expressly requested it or consented to it

We may employ third parties to perform some business tasks, such as processing payments, facilitating services or providing services on our behalf, and performing services such as maintenance, database management, web analytics and improvement of the Platform’s features. During the performance of these tasks, these third parties may have access to your Information. We take all reasonable steps to limit their access to the Information to the extent necessary for them to perform their specific tasks and for the duration of the task.

3. Cookies and Tracking tools

We collect information about your usage and activity on the Platform using tracking technologies such as “cookies”, “web beacons”, and other technologies. These are used to enable the technical operation of the Platform, to manage the log-in process, and to collect visit log data. You can change your browser's settings so it will stop accepting cookies or to prompt you before accepting a cookie. However, if you do not accept cookies it may impact your ability to use the Platform seamlessly.

The Platform may also include the use of cookies and web beacons of services owned or provided by third parties that are not covered by our Privacy Policy and we do not have access or control over these cookies and web beacons. We may also use third party cookies for the purposes of web analytics, attribution and error management.

4. Social Media Tools

We use several publicly-available social media tools and information exchange resources, including our blog, Facebook page, Twitter account, YouTube account, Instagram account and others (collectively "Social Media Tools"). Any information you provide or share while using Social Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.

5. Security and Phishing

Your account is protected by a password for your privacy and security. You are solely responsible for maintaining the confidentiality of your Account and the Information in contains. You must prevent unauthorized access to your Account by protecting your password and never allowing any other person to use your Account. If you know or have reason to believe that your password or log-in information has been compromised, change it immediately. After every session, log out securely and close the browser window. Do not auto-save your log-in details on your browser, even if it is your private computer.

Online identity theft and account hacking, including the practice currently known as "phishing", are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are 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.

6. Third Party Links

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

7. General Data Protection Regulation (GDPR) Notice

This section provides additional information about our Privacy Policy relevant to users from the European Union. It is necessary for us to use your personal information:

  • To perform our obligations in accordance with any contract that we may have with you
  • It is in our legitimate interest or a third party's legitimate interest to use personal information in such a way to ensure that we provide the services in the best way that we can
  • It is our legal obligation to use your personal information to comply with any legal obligations imposed upon us

You can view, edit and control the Information that you have provided to us in your User Profile in your Account, or by writing to us at customerservice@virtualemdr.com. Automated processing of your Personal Information is necessary to operate the Platform effectively and to provide counseling and related services.

8. Retention of Information

Even after your account is terminated, we may retain your Information as needed to comply with our legal, statutory and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons and as is necessary to provide our services effectively.

In the event that we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding, we may disclose or transfer your Information to third parties as part of these proceedings.

9. Necessary disclosure

We may access, preserve, use and disclose, any Information necessary to comply with applicable laws, our Terms of Service or Privacy Policy; to enforce any agreement or to protect the rights, safety, and reputation of the Company, our employees, affiliates, Users and/or others. We may disclose information about you to third parties if we have a good faith belief that such a disclosure is reasonably necessary to (i) take action regarding suspected illegal activities; (ii) enforce or apply our Terms of Service and Privacy Policy; (iii) comply with legal process or other government inquiry; (iv) protect our rights, reputation, and property, or that of our users, affiliates, or the public; (v) detect, prevent or otherwise address fraud, security or technical issues.

10. Changes to the Privacy Policy

We may update this privacy statement at our sole discretion. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices.

If you have any questions about the Privacy Policy, please contact us or email us at customerservice@virtualemdr.com.