Privacy Policy

Welcome to wayForward!  We are a provider of behavioral health solutions for employers, health plans and individuals that is owned and operated by PsyInnovations, Inc.  By accessing and using the services provided on our Site, which includes any mobile application that we may make available to you, you are accepting the practices described in this Privacy Policy and are also agreeing to comply with our Terms of Use.   These are referred to in general as our “Services.”Capitalized terms used in this Privacy Policy but not defined here have the meanings ascribed to them in the Terms of Use.

Before submitting any information which may identify you (“personally identifiable information”) to our Services, please read this Privacy Policy carefully. This Privacy Policy is designed to assist you in understanding how we collect, use, and disclose both personally identifiable information, non-personal information and PHI (as defined below), as applicable (collectively “Information”) that we obtain through your use of our Site.

Our Site provides information to you about our products and services.  When you visit our Site, Information will be automatically collected using cookies and similar technologies.  We may ask your consent when required.

What You Should Know Before Using the wayForward Service

Before using and sharing Information through our Service, you should understand the following.

  • Most users participate in our service and this Site because they are covered by health plans that provide our service to users and employee assistance plans sponsored by the employers of the users.  You should become familiar with the terms of those plans and how they affect you as a user of this Service.
  • You should read and agree with our Terms of Use.
  • If you are in the European Economic Area, UK, or Switzerland, please take notice that our services are not offered to users in those areas.  Any of your information that we collect will be transferred to PsyInnovations in the United States.
  • If you have questions you can always contact us at privacy@Wayforward.io .

As Information that we collect and process may include protected health information or PHI, we intend to fully comply with the Health Insurance Portability and Accountability Act of 1996, as amended, (“HIPAA”) and its implementing regulations, including its final privacy regulation, at 45 C.F.R. Parts 160 and 164 (known as the “Privacy Rule”), as administered by the federal Department of Health and Human Services. HIPAA places certain restrictions on the use and disclosure of PHI.

Sources and Types of Personal Data We Collect from You

We receive and store any Information you enter on our Site or give us in any other way.  We also collect certain Information automatically when you use or visit our Site. If you choose not to provide this Information to us, you will not be able to obtain the benefits of the services as a user of our Service.

Information we collect from visitors of our Site includes Information that will be collected automatically using cookies and similar technologies.  Cookies collect different aspects of information, including personally identifiable information. This kind of Information may include IP addresses, session information, product usage data, tracking data and other information about your visit to our site.

When you are a registered User of our Site, we need to collect more Information to allow you to use the features and functions of our Site.  We will need your email address, information about your gender and your general age, and will request your name. You will also be asked several questions during the registration process so that we can deliver information and resources to you.  Providing some of that information is voluntary on your part.

We also may periodically obtain Information about you from employers or employee assistance plans or health plans that provide you with access to our Site and our services.  We may also receive assessment data from third parties.

How We Use Your Information

PsyInnovations uses the Information we collect about you for registration and to manage your account, to communicate with you, and to connect you with resources.  We will also use your Information to allow those providing the services to you to have the information necessary to answer your questions and to respond to your requests.  

We use your Information when you authorize us to use it and when it is necessary to enforce this Privacy Policy and our Terms of Use.   These purposes may be for:

  • for registration and to manage your account, including to facilitate your access to and use of our Site;
  • to communicate with you and respond to your questions and comments;
  • to enable us to deliver services to you;
  • to resolve disputes or troubleshoot problems;
  • to prevent prohibited or illegal activities;
  • to enforce our Terms of Use and Privacy Policy;
  • to share your information with the providers of listed products or services when you request additional information about a certain listed product or service;
  • to comply with a legal obligation such as court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law;
  • to respond as required for a corporate transaction, such as a divestiture, investment, merger, consolidation, or asset sale, or other significant matter.

How We Share Your Information

Your Information is only shared with a coach or counselor or a care provider if you choose to ask for that service.  That person can only see the Information you have submitted to our Site to help the coach or counselor or care provider assist you and your condition or problem.

We do not share your PHI with employers or health plans except in an aggregated format where your PHI has been de-identified unless you give us specific consent to share that PHI in an identified format.   We may share aggregated data and high-level information in a way that does not identify individuals.

We do share your Information for processing and storage with third parties that have agreements in place with us to protect the confidentiality and security of information that we transfer to them.  

How You Can Inspect and Correct Your Health Information

You have the right to inspect and receive a copy of PHI that you have provided to us.  To inspect and copy PHI in our possession please contact us at privacy@wayforward.io.  If you feel that PHI we have about you is incorrect or incomplete, you may also request that we amend the information that you have provided to us to make it accurate and complete.

Your European Privacy Rights

While we do not provide services to or market the Services or the Site to those who reside in the Europe Economic Area (the “European Union” or “EU”), we will provide accommodations for the exercise of your rights provided under data protection laws of the EU, including the General Data Protection Regulation (the “GDPR”).  

If you are entitled to privacy rights under the GDPR, you are entitled to:

Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or concerns you can contact us any time.

Right of access, objection, restriction of processing, erasure, and portability. You also have the right to withdraw your consent at any time when we process your personal data based on your consent. To exercise these rights, please contact us.

Right to opt-out to direct marketing. While we currently do not do such marketing, you have the right to opt-out at any time to receiving marketing materials from us by following the opt-out instructions in our commercial emails, by contacting us, or by adjusting your preferences on the Site.  Please note that we reserve the right to send you other communications, including service announcements and administrative messages relating to your PsyInnovations account, without offering you the opportunity to opt out of receiving them.

Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you. We use cookies and similar technologies on our Site to personalize your experience on the Site.

Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the European Data Protection law, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.

Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email privacy@wayforward.io .

Do Not Track Technologies

Some browsers may have settings to request that websites “Do Not Track” your activity or usage.  At this time, we do not use services that will accommodate these technologies and your requests may not be able to be honored on our Site.  We do use cookies and other technologies to track your usage and other information about your visit to our Site.

Retention Periods and Deletion

PsyInnovations retains your Information to the extent necessary to reasonably provide the services and the Site requirements, to meet our compliance and legal obligations, to enhance security and fraud prevention, and for audit purposes.  We will keep your Information until you no longer participate as a user of the Site and in accordance with our Terms of Use.

How We Protect Your Personal and Health Information

We want you to feel confident about using our Site, and we are committed to protecting the personally identifiable information and PHI we collect. While no website can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the personally identifiable information and PHI you provide to us.  For example, only authorized employees are permitted to access personally identifiable information and PHI of users and they only may do so for permitted business functions. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized personnel have access to personally identifiable information and PHI that you have provided to us.  In addition, we use encryption when transmitting your personally identifiable information and PHI between your system and ours, and we, together with our partners, employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your personally identifiable information and PHI. You should bear in mind that submission of Information over the Internet is never entirely secure. We cannot guarantee the security of Information you submit via our Site while it is in transit over the Internet, and any such submission is at your own risk.

 

Children’s Privacy

The Site is not a general audience site and does not offer services directed to individuals under 18 years of age.  No one under the age of 18 may provide any Information to or on the Site. We do not knowingly collect personally identifiable information or PHI from individuals under 18.  If you are under 18, do not use or provide any Information on this Site or on or through any of its features, do not register on this Site, use any of the features of this Site, 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. Should an individual whom we know to be under the age of 18 send personally identifiable information or PHI to us, we will delete or destroy it as soon as reasonably possible. If you believe we might have personally identifiable information or PHI, contact us.

Information about International Transfers

If you are visiting our Site from outside the United States, please be aware that your Information will be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. You may also be re-directed to a Site that we maintain in a different country.  The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that PsyInnovations does take steps pursuant to laws in the United States to ensure that your privacy is protected. By visiting our Site or using our services, you understand that your Information will be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

Changes to this Privacy Policy

PsyInnovations may update this Privacy Policy in the future. We will notify you about material changes to this Privacy Policy by either sending a notice to the email address you provided to us and/or by placing a prominent notice on the Site.

How You Can Contact Us

If you have questions about this Privacy Policy, please contact us at privacy@wayforward.io

Or

PsyInnovations, LLC, WeWork c/o PsyInnovation Inc, 85 Broad St, New York, NY 10004

If you want to communicate with us about this policy, please email privacy@wayforward.io.  Please provide your identification and contact details, including your email address used to register with this Site, and a complete explanation of your concern.

Last Updated on 08/2018

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