Sensitive Personal Data or Information or “SDPI” of a person includes any personal information such as a) password, b) financial information – bank account, debit card, credit card or any other payment information c) physical and mental health history, d) sexual orientation, e) medical history, f) biometric, g) any details related to the above points. Any publicly available information is does not come under SDPI.
(i) we own or control;
(ii) are available through the Services; or
INFORMATION THAT WE COLLECT
- Information you provide to us: We may ask you to provide us with SPDI. We may collect this informationthrough various means and in various places through the Services, including account registration, forms, contact us forms, or when you otherwise interact with us. When you sign up to use theServices, you create a user profile. We shall ask you to provide only such SPDI which is for lawful purpose connected with our Services and necessary to be collected by us forsuch purpose.The current data fields that might be requested for are: Name, Email, Mobile number, Password, Gender, Age, professional, mental health related information, language spoken, sexual orientation.
- Information we collect as you access and use our services:
a) In addition to any Protected Information or other information that you choose to submit to us, weand our TPSP may use a variety of technologies that automatically (or passively) collect certaininformation whenever you visit or interact with the Services (“Usage Information”). This UsageInformation may include the browser that you are using, the URL that referred you to our Services, all of the areas within our Services that you visit, and the time of day, among other information.
b) Inaddition, we collect your Device Identifier for your Device. A Device Identifier is a number that isautomatically assigned to your Device used to access the Services, and our computers identifyyour Device by its Device Identifier.In case of interaction via customer service, Felicity may record calls for quality and training purposes.
- Information third parties provide about you: We may, from time to time, supplement the information we collect about you through our websiteor Mobile Application or Services with outside records from third parties.
- Information collected by mobile applications
a) Our Services are also provided through the Mobile Application. We may collect and usetechnical data and related information, including but not limited to, technical information about yourdevice, system and application software, and peripherals, that is gathered periodically to facilitatethe provision of software updates, product support and other services to you (if any) related to the Mobile Application.
b) When you use any of our Mobile Applications, the Mobile Application may automatically collectand store some or all of the following information from your mobile device (“Mobile DeviceInformation”), in addition to the Device Information, including without limitation:
• Your preferred language and country site (if applicable)
• The manufacturer and model of your mobile device
• Your mobile operating system
• The type of mobile internet browsers you are using
• Your geolocation
• Information about how you interact with the Mobile Application and any of our web sites to whichthe Mobile Application links, such as how many times you use a specific part of the MobileApplication over a given time period, the amount of time you spend using the Mobile Application,how often you use the Mobile Application, actions you take in the Mobile Application and how youengage with the Mobile Application
• Information to allow us to personalize the services and content available through the MobileApplication
• Data from SMS/ text messages upon receiving Device permissions for the purposes of
(i) issuingand receiving one time passwords and other device verification, and
USE OF THE COLLECTED INFORMATION
- Our primary goal in collecting your information is to provide you with an enhanced experiencewhen using the Services. We use your SDPI in order to match you to the counsellor best suited to your needs.
- Your mental health related data is shared with the counsellor with your consent so that the counsellor can effectively cater to your needs
- We use your email id and mobile number to send you reminders about upcoming sessions and other information related to your account. We might also use it for marketing and promotional purposes.
- We use your Internet Protocol (IP) address to help diagnose problems with our computer server,and to administer our web site(s). Your IP address is used to help identify you but contains nopersonal information about you.
- We will send you strictly service-related announcements on rare occasions when it is necessaryto do so. For instance, if our Services are temporarily suspended for maintenance, we might sendyou an email.
- All information (and copies thereof) collected by Felicity, including without limitation SPDI, Usage information and other information related to your access and use of the services offered by Felicity, may be retained by Felicity for such period as necessary, including but not limited to, for purposes such as compliance with statutory or legal obligations, tax laws and potential evidentiary purposes and for other reasonable purposes such as to implement, administer, and manage your access and use of our services, or resolution of any disputes.
- To ensure a seamless experience at the Website for you and to ensure your maximum benefit and comfort, we use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including advertising; (c) provide and monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Services; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our service.
- We may use the information collected from you for targeted advertising. This involves usinginformation collected on your web or mobile browsing behaviour such as the pages youhave visited or the searches you have made. This information is then used to select whichadvertisements should be displayed to you on websites other than our website(s). The information collected is only linked to an anonymous cookie ID (alphanumeric number);it does not include any information that could be linked back to you, such asname, address or credit card number.
- We use certain third-party analytics tools to help us measure traffic and usage trends for the Services. These tools collect information, which is not personal or sensitive in nature sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving the Services. We collect and use this analytics information with analytics information from other Users in the form of anonymised logs, so that it cannot reasonably be used to identify any particular individual User.
- Any information shared by you during personal consultation (“Confidential Information”) shall be excluded from the definition of Personal Information and shall not be collected/used in the same manner as Personal Information as mentioned above.
- Your Confidential Information shall not be disclosed or shared by Felicity, its employees, its agents, or any third-party contractors, including the counsellors; either orally or in writing; except only in the following circumstances:
a) If Felicity believes that there is a significant/ real/ imminent threat or risk to your health,safety or life or to the health, safety or life of any other person or the public.
b) If Felicity is required to share such Confidential Information to any authority by law; and
c) If you have claimed a health care insurance and such Confidential Information is required by the insurer.
SHARING OF THE COLLECTED INFORMATION
- We may share Personal Information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Felicity is part of, or that become part of that group (“ Affiliates”).Our Affiliates may only use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences).
- We also may share your Personal Information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Services to you. Our service providers will only be given access to your information as is reasonably necessary to provide the Services.All the Service Providers and third parties engaged by Felicity shall be bound by adequate confidentiality terms to protect the Confidential Information and the Personal Information of the User so that such information is not used in any manner it is not intended to be used.
- While sharing any information with any third party, we will remove parts of data that can identify you and share only anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that anonymised aggregated information which cannot be traced back to you.
- Please note that only Personal Information or content that you voluntarily disclose for posting to the Website, or post to any social media account owned and operated by Felicity becomes available to the public. No other information provided by you is shared with the public. Once you have shared such information or made it public, the same may be re-shared by others, re-posted by Felicity, or used by Felicity for the purposes of analysis, research or studies.
- Felicity shall not ordinarily share the sensitive Personal Information of a User without their prior consent. You agree that Felicity may share sensitive Personal Information of a User with any third party without obtaining the prior consent of the User in the following limited circumstances:
THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES
The Services may contain content that is supplied by a third party, and those third parties maycollect website usage information and your Device Identifier when web pages from any online ormobile Services are served to your browser. In addition, when you are using the Services, youmay be directed to other sites or applications that are operated and controlled by third parties thatwe do not control. We are not responsible for the privacy practices employed by any of these thirdparties. For example, if you click on a banner advertisement, the click may take you away fromone of our websites onto a different web site. These other web sites may send their own cookiesto you, independently collect data or solicit Protected Information and may or may not have theirown published privacy policies. We encourage you to note when you leave our Services and toread the privacy statements of all thirdparty web sites or applications before submitting any SPDI to third parties.
SOCIAL MEDIA FEATURES AND WIDGETS
- The Protected Information and Usage Information we collect is securely stored within ourdatabases, and we use standard, industry-wide, commercially reasonable security practices suchas encryption, firewalls and SSL (Secure Socket Layers) for protecting your information. However,as effective as encryption technology is, no security system is impenetrable. We cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this policy. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing, or otherwise offering any definitive promise of security in connection with your Information.
- The User is solely responsible for maintaining confidentiality of the User’s password and User identification. The User shall be solely responsible for all activities and transmission performed by the User through his User identification. Felicity assumes no responsibility or liability for their improper use of information relating to such usage of credit cards and/or debit cards by the User, whether online or off-line.
- If you are located outside India and choose to provide information to us from there, Felicity will transfer and keep your information in India. Your submission of information represents your consent to this transfer.
CHANGE OF INFORMATION AND CANCELLATION OF ACCOUNT
- You are responsible for maintaining the accuracy of the information you submit to us, such asyour contact information provided as part of account registration. If your SPDI changes, or if you no longer desire our Services, you may correct, delete inaccuracies, or amendinformation by making the change on our user profile page or by contacting usthrough email address mentioned on our website or Mobile Application. We will make goodfaith efforts to make requested changes in our then active databases as soon as reasonablypracticable.
- You may also cancel or modify your communications that you have elected to receive from theServices by following the instructions contained within an e-mail or by logging into your useraccount and changing your communication preferences.
- If upon modifying or changing the information earlier provided to Us, we find it difficult to permitaccess to our Services to you due to insufficiency/ inaccuracy of the information, we may, in oursole discretion terminate your access to the Services by providing you a written notice to this effecton your registered email id.
- If you wish to cancel your account or request that we no longer use your information to provideyou services, contact us through the contact details on the website. Even after youraccount is terminated, we will retain your SPDI and Usage Information as needed to comply with our legal and regulatoryobligations, resolve disputes, conclude any activities related to cancellation of an account,investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and forother business reason. After a period of time, your data may be anonymized and aggregated, andthen may be held by us as long as necessary for us to provide our Services effectively, but our useof the anonymized data will be solely for analytic purposes.