Privacy policy

This Privacy Policy describes how Welcome Online Therapy (the "Site", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from welcome-online-therapy.com (the "Site") or otherwise communicate with us regarding the Site (collectively, the "Services"). Welcome-online-therapy.com is owned and operated by NEXGEN GAMING Pty Ltd. For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.

How We Collect and Use Your Personal Information

To provide the Services, we collect personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information We Collect Directly from You

Information that you directly submit to us through our Services may include:

  • Contact details including your name, address, phone number, and email.
  • Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.
  • Account information including your username, password, security questions and other information used for account security purposes.
  • Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect about Your Usage

We may also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Information We Obtain from Third Parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

  • Companies who support our Site and Services, such as Shopify.
  • Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
  • When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

How We Use Your Personal Information

  • Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and other features and functionalities related to your account. We may also enhance your shopping experience by enabling Shopify to match your account with other Shopify services that you may choose to use. In this case, Shopify will process your information as set forth in its Privacy Policy and Consumer Privacy Policy.
  • Marketing and Advertising. We may use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites.
  • Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately..
  • Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you

Cookies

Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for contract fulfillment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:

  • With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).
  • With business and marketing partners to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
  • When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.
  • With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
  • In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We disclose the following categories of personal information and sensitive personal information about users for the purposes set out above in "How we Collect and Use your Personal Information" and "How we Disclose Personal Information":

Category Categories of Recipients
  • Identifiers such as basic contact details and certain order and account information
  • Commercial information such as order information, shopping information and customer support information
  • Internet or other similar network activity, such as Usage Data
  • Geolocation data such as locations determined by an IP address or other technical measures
  • Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners and data analytics providers)
  • Business and marketing partners
  • Affiliates

We do not use or disclose sensitive personal information without your consent or for the purposes of inferring characteristics about you.

Third Party Websites and Links

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

Children's Data

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

Security and Retention of Your Information

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

Your Rights

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

  • Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
  • Right to Delete: You may have a right to request that we delete personal information we maintain about you.
  • Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.
  • Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
  • Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.
  • Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
  • Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
  • Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.

International Users

Please note that we may transfer, store and process your personal information outside the country you live in. Your personal information is also processed by staff and third party service providers and partners in these countries.

If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

Privacy Policy for CRN Solutions AB

CRN Solutions safeguards your personal integrity

Updated: July 4th, 2024

CRN Solutions AB, corp. reg. no. 556855-7275, Humlegatan 2B, 263 38 Höganäs, Sweden, (the ”Company”) respects your privacy and is committed to maintaining a high level of security and integrity regarding your personal data. The Company is also committed to ensuring that processing is carried out in accordance with applicable data protection legislation.

Do not hesitate to contact the Company should you have any questions regarding the Company's privacy protection. The Company’s contact information is set out under the section “Contact Information”.

The definitions of this privacy policy shall have the meaning set forth in the Online-Therapy.com Terms and ConditionsTerms and Conditions for Affiliates and Counselor Agreement.

Data Controller

The Company is the data controller of your personal data and is therefore responsible for ensuring that your personal data is processed correctly and securely in accordance with applicable legislation.

Which personal data does the Company process?

Personal data means any information that directly or indirectly relates to a natural, living person. Accordingly, personal data is information about you and your person, e.g. your name, your contact information, pictures of you and your IP-address.

Processing means any operation which is performed on personal data, such as collection, storage, use, adaption or disclosure.

Counselors

The Company collects and stores the following information about you that the Company needs to contact you and to fulfil its undertakings towards you as a Counselor.

  • Personal information and contact information, such as name, personal identity number, gender, address, telephone number and email address.

  • Title and initials of your credentials.

  • Information that you provide to the Company by email, via the Company’s social media or by other channels of communication. This also includes communication through means such as text chats, messages and worksheets between you and the User.

  • Payment and purchase history as well as payment information, such as PayPal e-mail address and Stripe account name.

  • Information regarding surveys, complaints and warranty matters.

  • Website and social media links.

  • Technical data, such as IP address, MAC address, URL, User-ID, unique device ID, network and device performance, browser, language and identification settings, geographic location, operating system, other information from cookies or similar mechanisms (device information).

  • Your picture.

Users

The Company collects and stores the following information about you that the Company needs to contact you and to fulfil its undertakings toward you as a User.

This also includes you as an employee/member at a company/organization that has registered a business account at the website.

The Company may process special categories of data of you as a User. The legislator has determined that special categories of personal data shall be further protected. As a main principle, special categories of personal data shall not be processed, however, there are a few exemptions. Private health information is one category of such data which as a main principle is prohibited to be processed. However, the Company must process such data in order to provide its services to you as a User. Based on the exemption that special categories of data may be processed in order to provide health care, the Company is entitled to process health care information you have provided the Company.

  • Personal information and contact information, such as name, personal identity number, age, gender, address, telephone number and email address.

  • Information that you provide to the Company by email, via the Company’s social media or by other channels of communication. This includes communication, such as text chats, messages and worksheets between you and the Counselor.

  • Information regarding surveys, customer reviews, complaints and warranty matters.

  • Technical data, such as IP address, MAC address, URL, User-ID, unique device ID, network and device performance, browser, language and identification settings, geographic location, operating system, other information from cookies or similar mechanisms (device information).

  • Financial status.

  • Information related to your appointment such as date, time and nature of the appointment, as well as your preferences regarding your Counselor.

  • Private health information

Emergency Contacts

If the User has provided the Company with an Emergency Contact, the Company collects and stores the following information about you as an Emergency Contact, which the Company needs to contact you in case of an emergency.

  • Contact information such as name, telephone number, and relationship with the User.

Suppliers, partners and affiliates

The Company collects and stores the following information about you that the Company needs to contact you and to fulfil its undertakings towards you as a supplier, partner or affiliate (such as but not limited to computer programmers, sales representatives etc.).

This also includes contact persons to companies that have registered a business account with the Company. However, employees/members obtaining Counselor Services through a business account are covered by “Users” above.

  • Personal information and contact information, such as name, address, telephone number, email address, title, position and employer.

  • Payment information.

Company representatives for e.g. suppliers, partners and affiliates

The Company collects and stores the following information about you that the Company needs to contact you in your capacity as a representative for a company or organization.

  • Personal information and contact information, such as name, address, telephone number, email address, title, position and employer.

  • Information that you provide to the Company by email, via the Company’s social media or by other channels of communication.

  • Where applicable, information regarding phone calls with the Company’s customer service.

  • Where applicable, payment information.

Potential Counselors, suppliers, partners and affiliates and company representatives for potential Counselors, suppliers, partners and affiliates

The Company collects and stores the following information about you in your role as a potential Counselor, supplier, partner or affiliate to the Company or in your role as a representative for a company that is a potential supplier or partner to the Company. The Company needs such information to contact you and to fulfil its undertakings toward you as a potential Counselor, supplier, partner or affiliate or in your capacity as a representative for a potential Counselor, supplier, partner or affiliate.

  • Personal information and contact information, such as name, address, telephone number, email address, title, position and employer.

Visitors of the Company’s website

In connection with visits to the Company’s website, the Company collects the following information about you that the Company needs to be able to improve, streamline, simplify and develop our website.

  • Technical data, such as IP address, MAC address, URL, User-ID, unique device ID, network and device performance, browser, language and identification settings, geographic location, operating system, other information from cookies or similar mechanisms (device information).

  • Information of the visitors use of the Company’s website, such as what pages are visited, scrolls, outbound clicks, mouse movements, search terms and usage of the search function, interaction with forms and videos, duration of the visit, when and how often visits occur, file downloads, what other sites that have been used prior to visiting our website, interaction with advertisements, customer actions to measure success of ads, as well as other interactions with the Company’s website.

Recruitment (job applicants at the Company)

The Company collects and stores the following information about you that the Company needs to be able to recruit the right persons for positions with the Company.

  • Personal information and contact information, such as name, address, telephone number, email address, title, position and employer.

  • Information in cover letter and CV.

  • Where applicable, your picture.

  • Other information that you provide the Company in connection with recruitment.

From where do the company collect your personal data?

With respect to Users and Counselors and potential Counselors, your personal data is usually collected directly from you.

Regarding existing or potential suppliers, partners and affiliates or its company representatives, your personal data is usually collected from the company or organization that you represent, but also, in certain cases, directly from you, e.g. by email, our social media or other channels of communication or in connection with events or meetings. This is also the case if you are an employee/member at a company/organization that has registered a business account at the website.

The Company’s processing of your personal data

The purposes for which the Company intends to process your personal data and the legal basis for the respective processing activities are stated in the tables below.

Users, Counselors, suppliers, partners or affiliates (including company representatives)

Purpose Legal basis

To fulfil legal requirements, such as but not limited to health care requirements, security requirements and accounting requirements.

The processing is necessary for compliance with the Company’s legal obligations.

To provide and maintain the Platform, including to monitor the usage of the Platform.

The processing is necessary for the performance of the agreement with the User or the Counselor.

To manage your account as well as to manage your registration as a User or Counselor.

The processing is necessary for the performance of the agreement with the User or Counselor.

To handle purchases and booked appointments.

The processing is necessary for the performance of the agreement with the User.

To be able to contact you regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

The processing is necessary for the performance of the agreement with the User or Counselor.

To enable marketing and communication about the Company's brand and the Company's products (e.g. mailing of newsletters and other marketing materials, invitations to the Company's events, meetings and other gatherings etc.).

The processing is necessary for the Company’s legitimate interest to market its brand, its products and other similar products to you as a customer or to the company that you represent (legitimate interest).

To carry out surveys regarding the Platform and to enable the User to review a purchase.

The processing is necessary for the Company’s legitimate interest to evaluate, develop and improve its brand, its service and its marketing (legitimate interest).

To ensure payment and analyze purchase history in order to offer Users and Counselors the right services and marketing.

The processing is necessary for the performance of the agreement with the User or Counselor.

The processing is also necessary for the Company’s legitimate interest to offer Users or Counselors relevant marketing with regard to the customers previous purchases (legitimate interest).

To ensure payments to the Counselor in connection with providing the Counselor Services.

The processing is necessary for the performance of the agreement with the Counselor.

To receive payments from Users in connection with purchases of the Company’s products and services.

The processing is necessary for the performance of the agreement with the User.

To be able to respond to and compensate Users and Counselors in connection with complaints and warranty matters.

The processing is necessary for the performance of the agreement with the User or Counselor.

To be able to keep in touch with a representative of the supplier or partner.

The processing is necessary for the Company’s legitimate interest to keep in touch with you in order to fulfil its obligations under the agreement with its supplier or partner, i.e. the company that you represent (legitimate interest).

Potential future Counselors, suppliers or partners

Purpose Legal basis

To enable marketing and communication about the Company's brand and the Platform (e.g. mailing of newsletters and other marketing materials, invitations to the Company's events, meetings and other gatherings etc.).

The processing is necessary for the Company’s legitimate interest to market its brand, its service and other similar products to you or to the company that you represent (legitimate interest).

Emergency Contacts

Purpose Legal basis

To be able to contact you in case of an emergency.

The processing is necessary for the Company's legitimate interest in being able to initiate appropriate action in case of emergency (legitimate interest).

Visitors of the Company’s website

Purpose Legal basis

To ensure the operation of the Company's website and application.

To be able to develop the Company's website and to better adapt the website based on how it is used.

The processing is necessary for the Company’s legitimate interest to improve, streamline, simplify and develop its website and to attract more Users/Counselors/partners and to increase the number of recurring Users/Counselors/partners (legitimate interest).

To measure the effectiveness of the Company’s advertising (through conversion tracking) and to ensure that relevant advertisement is shown to you.

The processing is necessary for the Company’s legitimate interest to understand and analyze the website traffic and to optimize ad performance (legitimate interest).

To verify that data input on the website is made by a human and not an automated program.

The processing is necessary for the Company’s legitimate interest to protect the website from spam and abuse (legitimate interest).

Recruitment (job applicants at the Company)

Purpose Legal basis

To, in connection with recruitment, be able to decide who is best suited for a position with the Company and to ensure that the relevant person has the necessary skills.

The processing is necessary for the Company’s legitimate interest to recruit the right employees and ensure that skilled people work for the Company (legitimate interest).

How long does the Company store your personal data?

Your personal data is stored as long as there is a need to preserve them in order to fulfil the purposes for which the data was collected in accordance with this Privacy Policy. Thereafter, your personal data will be deleted.

We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Some personal data will, for the purpose of complying with applicable accounting legislation, be stored for seven years, counting from the end of the calendar year during which the financial year, to which the information pertained, was terminated.

Contact information regarding company representatives is stored during such time the Company considers that the information is necessary to maintain the relationship with the company/organization. Deletion shall take place when the Company becomes aware that the information is no longer adequate or relevant for the purpose, or at the request of the contact person.

For more information about how long the Company stores specific personal data, please contact the Company. Contact information is provided under section "Contact Information" below.

With whom does the Company share your personal data?

The Company does not disclose personal data to third parties, except when necessary to fulfil a legal obligation or to fulfil the Company's obligations to you and/or partners. Situations when your personal data must be disclosed to third parties are listed in the table below.

Your personal data will not be sold to third parties for marketing purposes.

Third party Reason for third-party disclosure

Suppliers of cloud solutions

Personal data may be transferred to suppliers of cloud solutions since the Company stores certain information in cloud solutions.

Service providers

The Company may share personal data with service providers to monitor and analyze the use of the Platform, to show advertisements to you, to help support and maintain the Platform, to ensure encryption, to contact you, to handle your booking of live sessions, to enable you to review your purchase, to advertise on third party websites to you after you visited our Platform or to be able to process payments.

Suppliers and partners

The Company may disclose personal data to suppliers and/or partners, if the suppliers and/or partners need your personal data to fulfil their undertakings toward the Company.

Authorities

Personal data may be disclosed to authorities when necessary for compliance with the Company’s legal obligations.

Sale

If the Company intends to transfer all or part of its business, personal data may be disclosed to a potential buyer.

Regarding payments

The Company may provide you with paid products and/or services. In that case, the Company may use third-party services for payment processing (e.g. payment providers).

The Company will not store or collect your payment card details. That information is provided directly to our third-party payment providers whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The Company uses the following payment providers:

  • Stripe: Their Privacy Policy can be viewed here »

  • PayPal: Their Privacy Policy can be viewed here »

Transfer of personal data to third countries

The Company may transfer your personal data to countries outside the EU/EEA.

If personal data is transferred to a country outside the EU/EEA, the Company will take measures to ensure that the personal data continues to be protected and will also take the necessary measures to ensure a legal transfer of the personal data to countries outside the EU/EEA.

Such necessary measures consist of ensuring that the third country to which the personal data is transferred, is subject to a decision from the European Commission that it ensures an adequate level of protection or taking appropriate protection measures, for example Binding Corporate Rules (BCR) or Standard Contractual Clauses (SCC). If you wish to receive a copy of such BCR or SCC, please contact the Company.

All communication between Users and Counselors is end-to-end encrypted. All databases are encrypted at rest with industry-leading encryption. Further, all private health information is hosted behind a 3-tiered web application, with multiple checks and controls to keep your data safe.

Social media

The Company uses share buttons on the website, provided by social media companies such as Twitter and Facebook. If you interact with these buttons (e.g. click to share content), the respective social media platform may collect information through cookies. For further information on how the social media platforms use cookies, please refer to their respective policies.

Regarding personal data that occurs and is processed on social media, such as Facebook, Instagram, Youtube, Twitter, Snapchat and LinkedIn, we also refer users to the policy provided by the respective service providers for information on how each service provider processes personal data. In the Company’s view, the purpose of the processing is that you shall be able to interact and maintain contact with the Company via social media, in order to contribute to good relationships with Users, Counselors, customers and partners and to make the Company's customer service and product widely accessible through several different channels. The processing is necessary for the purposes of the Company’s legitimate interest to market its brand and its products to existing and potential customers and to partners (legitimate interest).

Your rights

As the data controller, the Company is responsible for ensuring that your personal data is processed in accordance with applicable legislation.

The Company can, at your request or on its own initiative, rectify, erase or complete any information found to be inaccurate, incomplete or misleading.

You have the right to request access to and rectification or erasure of your personal data (e.g., if such erasure is required by applicable law), request restriction of the processing of your personal data and object to the processing, as permitted by applicable personal data legislation (e.g. if you contest the accuracy of the personal data or if the processing is unlawful but you oppose the erasure of the personal data and request restriction of its use instead).

Under certain conditions, you have the right to data portability, i.e., a right to receive your personal data in a structured, commonly used and machine-readable format and the right to transmit those data to another controller.

If you do not want the Company to process your personal data for direct marketing purposes, you have the right to object to such processing at any time. When the Company has received your objection, the Company will cease the processing of your personal data for such marketing purposes.

You have the right, through a written and signed application, to obtain free of charge a register extract from the Company regarding which personal data are stored about you, the purposes of the processing and to which recipients the data has been or shall be transferred. You also have the right to obtain information about the envisaged period for which the personal data will be stored or the criteria used to determine this period. You also have the right to receive information about your other rights as specified in this paragraph “Your Rights”.

We look forward to hearing from you if you have any complaints regarding the Company’s processing of your personal data, in order to correct our processing if necessary. You also have the right to file complaints regarding the Company's processing of your personal data with the Swedish Authority for Privacy Protection.

Security of your personal data

You should always be able to feel safe when you provide us with your personal data. Therefore, the Company has implemented the security measures that are necessary to protect your personal data against unauthorized access, alteration and destruction. The Company will not disclose your personal data, other than as expressly provided by this Privacy Policy.

The Company encrypts your data in transit and at rest on its servers, and all private communication with your Counselor is end-to-end encrypted. The Company stores all private health information on servers with full HIPAA compliance.

Cookies

The Company uses cookie-like techniques in order to provide certain functions on the Company’s website www.online-therapy.com and to improve the website and to deliver a better and more personal service. The information is stored in the form of a file comprising encrypted login data.

The Company may gather and analyze information regarding usage of our website, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using cookies. The Company uses cookies and similar technologies to track usage of the website and to address security issues. Further, the Company may also use cookies to store your preferences relating to use of our website. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet, phablet, cell phone or other electronic device (a "Device") browser from a website's computer and is stored on your Device's hard drive. Each website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track traffic flows.

Cookies record information about your preferences and allow the Company to modify the Platform to your interests. During the course or any visit to the Platform, the pages you see, along with a cookie, are downloaded to your Device. Many websites do this, because cookies enable website publishers to do useful things such as finding out whether the Device (and probably its user) has visited the website before. This is done on a repeat visit by checking for the cookie left there on the previous visit. Information supplied by cookies can help the Company to analyze the profile of our visitors in order to provide you with a better user experience and will not entail any further foreseeable consequences to you.

reCAPTCHA and Google Analytics

The Company and some of the Company’s services providers use reCAPTCHA which is a service provided by Google Inc. reCAPTCHA is used by the Company to protect its website from for example automated spam or other attacks. Google’s Privacy Policy and Terms of Service apply to reCAPTCHA.

Further, the Company uses Google analytics, which is a web analysis services provider which helps the Company to understand how visitors interact with the website. Information about Google analytics and how it collects, and processes data is available at https://policies.google.com/technologies/partner-sites.

If you do not share your personal data with the company

The processing of your personal data is necessary in order for the Company to enter into an agreement with you. If you do not share your personal data with the Company, the Company will not be able to fulfil its legal or contractual obligations towards you.

California Consumer Privacy Act (CCPA)

The Company recognizes California’s specific privacy rights of the Company’s Users in that State. California Users should be aware that the Company does not sell User data to third parties. Further, the Company is a medical records retention company. As such, almost all personal data is kept in encrypted storage as a medical record, including all User created transcripts. Under State Law, the Company shall retain such records for at least seven years. The CCPA is not generally applicable to medical information governed by the California Confidentiality of Medical Information Act (CMIA) or protected health information collected by a covered entity or business associate governed by the privacy, security, and breach notification rules of the Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009.

According to Section 1798.83 of the California Civil Code (also known as the “Shine the Light Law”), residents of California are entitled to request, once a year, if the Company have shared their personal information (non-medical record data only) with other companies for direct marketing purposes during the preceding calendar year. To request a copy of the information disclosure provided by the Company, please contact us on Online-Therapy.com at the “contact us”-link on the website. Please allow reasonable time for a response.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted on our site. The Company does not have User below the age of 13 and does not typically allow Users to publicly post information. However, if you feel you publicly posted information on the Platform and you are between the ages of 13 and 17, please contact us on Online-Therapy.com at the “contact us”-link on the website. Please allow reasonable time for a response. Please be aware that such a request does not ensure complete or comprehensive removal of the data/content you have posted and that there may be circumstances in which the law does not require or even allow removal of data, specifically medical data, even if requested.

California Right to Know. You may request access to the specific pieces of personal data we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal data we have collected about you, the sources of such collection, the categories of personal data we share for a business or commercial purpose, and the categories of third parties with whom we share your personal data. You may make these requests by contacting us on Online-Therapy.com at the “contact us”-link on the website. Please allow reasonable time for a response.

California Designated Agent. You may designate an agent to make a request on your behalf. That agent must have access to your account in order for us to verify the request.

California Non-Discrimination. The Company will never discriminate against you, including by denying or providing a different level of service should you choose to exercise your rights under the CCPA.

CalOPPA

Our Service does not respond to Do Not Track (DNT) signals. However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Changes

The Company reserves the right to change this Privacy Policy at any time. In the event of changes to this Privacy Policy, the Company will publish the amended Privacy Policy on www.online-therapy.com with information on when the changes will come into effect and may also notify customers and partners in an appropriate manner.

Links

The Platform may contain links to other websites that are not operated by the Company. If you click on a third party link, you will be directed to that third party's site. The Company strongly advise you to review the privacy policy of every site you visit. The Company has no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Contact information

Do not hesitate to contact the Company online-therapy.com if you have any questions about this Privacy Policy, the processing of your personal data or if you wish to exercise your rights under this Privacy Policy or applicable legislation.

CRN Solutions AB
Corporate registration number: 556855-7275
Postal address: Humlegatan 2B, 263 38 Höganäs, Sweden
Email address: info@online-therapy.com

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