Effective Date: 2020-12-23
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.
What You Should Know Before Using the wayForward Services
Before using and sharing information through our Services, you should understand the following.
Most users participate in the Services because they are covered by health plans that provide our service to users and employee assistance plans sponsored by the employers of the users. Information provided to us by your health plan or employer is controlled by their privacy policies and practices, and we encourage you to familiarize yourself with the terms of those plans and how they affect you as a user of the Services.
If you have questions you can always contact us at email@example.com.
It is our policy to comply with all applicable laws and regulations relating to the privacy of our customers’ information, including information that wayForward obtains related to your health.
Information Sources and Types of Personal Data We Collect from You
We receive and store any information you enter on our Services 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 Services.
The personal information that you provide may include:
- Identifiers, such as name, contact information, and mailing or billing address.
- Demographic information about you, such as date of birth and gender.
- Registration and referral information, such as the types of services you are seeking, and information about your health relevant to connecting you with the right provider.
- A record of text communications between you and your coach or mental health service provider.
- Any other information that you choose to provide.
Information we may collect with these technologies may include, but are not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track when and how frequently you access or use the Services, including how you engage with or navigate our website or mobile application.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). If you disable cookies, you may be prevented from taking full advantage of the Services because the Services may not function properly. As we adopt additional technologies, we may also gather additional information through other methods.
We Obtain from Third Parties. 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 where necessary to administer the Services. This information may include information about your employment status, employee identification number or identifier, job title, benefits information, and your primary work site (place of work). The information that we collect from these third parties is only as directed or permitted by those third parties and we are subject to contractual obligations to keep such information confidential. We may also receive information about you from third parties for the purposes of referring you to a participating provider.
Location Information. When you use our Services, we may collect general geolocation information (such as your city/state inferred from your IP address). This information may be used to deliver tailored content through Services.
How We Use Your Information
We may use the information we collect about you for the following purposes:
- 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 the Services;
- to resolve disputes or troubleshoot problems;
- to prevent prohibited or illegal activities;
- 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; and
- for any other purpose, with your consent.
Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties at our discretion.
Online Analytics. We may use third-party analytics services (such as those of Google Analytics) on our Sites to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
Legal Bases for Use of Your Information
If you are an individual from the European Economic Area (“EEA”), the UK, or Switzerland, our legal bases under the General Data Protection Regulation (“GDPR”) for using your personal information are as follows:
- To honor our contractual commitments to you in providing the Services including to communicate with you regarding any scheduled or available services or to connect you to a provider.
- Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
- Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
- Administrating our services, including for billing and account management;
- Managing our relationships and communicating with you and with your health care plan or employer, as necessary to manage our accounts and business.
- communicating with you to provide updates to you and our customers about new features and services that we may offer;
- Responding to any complaints and resolving disputes raised by you or our customers;
- Carrying out analytics, quality control, security processes and similar activities, in order to provide, develop and identify potential improvements to our services, to share analytics data related to outcomes of the Services, for benchmarking and other marketing and research purposes].
- Registering and onboarding you for the use of Services and further tailoring our products and services for your use;
- Managing your access to the Services through our Site and mobile applications;
- Measuring your satisfaction with Services through surveys, feedback and ratings;
- Developing potential sales and other business opportunities related to current and future Services;
- To prevent, detect, and prosecute illegal or fraudulent activity on the Services.
- Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
How We Share Your Information
We 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.
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 Services to help the coach or counselor or care provider assist you..
We may also share information with providers of third-party products or services listed on our Site or Services when you request additional information about a certain listed product or service;
We may share aggregated data and high-level information in a way that does not identify individuals. We do not share information with employers or health plans, except in an aggregated format where the information has been de-identified, unless you give us specific consent to share that information in an identified format.
Your Choices and Rights
How You Can Inspect and Correct Your Health information. You have the right to inspect and receive a copy of registration, self-assessment, and communications that you have provided to us through the service. To inspect and copy this information please contact us at firstname.lastname@example.org. If you feel that information 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.
Right to opt-out to direct marketing. We may occasionally send you information about additional services that we think may be of interest to you. You have the right to opt-out of receiving marketing materials from us by following the opt-out instructions in our commercial emails or by contacting us at email@example.com. 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.
Data Controller. Data protection laws in certain jurisdictions differentiate between the “controller” and “processor” of information. PsyInnovations has partnered with WorkPlace Options LLC (“WPO”) to provide services to international users. Both we and WPO are “controllers” of the personal data, which means that both organizations are responsible for how we collect, use, and disclose information collected by and through the Services. Where WPO is providing services to you, they will have control over the use of that personal information, and you will need to contact them directly regarding the exercise of your rights under applicable data protection laws.
International. When PsyInnovations acts as a controller, individuals in the EEA, the UK, Switzerland and some other jurisdictions (such as Canada and Australia) have certain additional legal rights to do the following with “personal data” we handle:
- 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.
Please note that many of the rights described above are subject to limitations or exceptions under applicable law. Additionally, most of these requests and rights can be handled directly through menu features of the Services.
Individuals also have a right to file a complaint with the relevant supervisory authority, but we invite you to kindly first give us an opportunity to address your concern.
If you are an individual in the European Economic Area or the United Kingdom, and have any questions about exercising your rights you may contact us at the contact information provided below.
Notice to California Residents
California’s “Shine the Light” law (Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of “personal information” (as defined in the Shine the Light law) to third parties for their direct marketing purposes. We do not share your “personal information” with third parties for their own direct marketing processes.
Notice to Nevada Residents
Certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the methods outlined in the “How You Can Contact Us” section. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
Retention Periods and Deletion
PsyInnovations retains your information in an identifiable form to the extent necessary to reasonably provide the Services, to meet our compliance and legal obligations, to enhance security and fraud prevention, and for audit purposes. informationWe will delete or de-identify personal information about you upon request except where it is necessary to continue providing services to you or for our business purposes, or where we are legally required to retain it.
How We Protect Your Information
We want you to feel confident about using our Services, and we are committed to protecting the information we collect. While no website can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the information you provide to us. We cannot guarantee the security of information you submit via our Services while it is in transit over the Internet, and any such submission is at your own risk.
The Services are not intended for a general audience and PsyInnovations 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 Services. We do not knowingly collect information from individuals under 18. If you are under 18, do not use or provide any information on this Services or on or through any of its features, do not register on this Services, use any of the features of this Services, 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 information to us, we will delete or destroy it as soon as reasonably possible. If you believe we might have such information, contact us.
Information about International Transfers
How You Can Contact Us
PsyInnovations LLC, 30 W 18 Street, Apt 14B, New York, NY 10003
Please provide your identification and contact details, including your email address used to register with our Services, and a complete explanation of your concern.