If you are visiting our website as a California, United Kingdom, or European Union resident, your rights under the privacy laws applicable in your jurisdiction are represented in an addendum to this policy. If you do not see this addendum below, please contact us at [email protected] to receive the additional information describing your rights under these laws.
Information Collection, Use, and Disclosure
Categories of Information Collected
Visitor Data: TimeToBetter collects, uses, and stores data regarding user visits to its website and use of the TimeToBetter application ("Visitor Data"), including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to the TimeToBetter "FAQ" page, and information about the browser or device used to access the website and application, such as the user’s mobile device ID and IP address. These practices apply to users who visit pages for prospective new customers as well as those who visit pages for prospective Counselors.
Account Registration Data: TimeToBetter collects, uses, and stores certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number ("Account Registration Data"). TimeToBetter also assigns each user (including Counselors) who creates a TimeToBetter account an anonymized, sequentially-generated client ID.
Transaction Data: TimeToBetter collects, uses, and stores certain information regarding payment for its services by users and related transactions on its website, such as whether a user completed payment for TimeToBetter’s services, signed up for TimeToBetter’s services using a trial offer, canceled or otherwise ended a trial, or completed a request to receive financial aid for TimeToBetter’s services ("Transaction Data").
Login Data: TimeToBetter collects, uses, and stores data regarding logins to TimeToBetter’s Platform by registered users (including Counselors) and activity conducted during that log in such as when a user logs in, the number of messages received or sent through TimeToBetter’s website or app during that log in, and whether a user has been assigned, started, or completed a counseling goal ("Login Data"). Login Data does not include the content of any messages sent or received by users or the content of any counseling goals.
Counseling Session Data: TimeToBetter collects, uses, and stores certain general data regarding user counseling sessions such as whether a live session has been scheduled by the user, whether a Counselor or user joins a scheduled session, when a counseling session began and ended, and whether a counseling session was canceled or re-scheduled.
Customer Data: TimeToBetter collects, uses, and stores certain data from users that have signed up for TimeToBetter’s services such as a user’s self-reported name or nickname, age, e-mail address, phone number, and emergency contact information ("Customer Data").
Counselor Data: In order to identify, credential, re-credential, run checks, and pay Counselors, TimeToBetter collects, uses, and stores certain data from Counselors. This data includes information such as the Counselor’s name, bank account information, governmental identification numbers, e-mail address, phone number, address, NPI number (if applicable), CAQH number (if applicable), and education and job history ("Counselor Data").
Communications Data: TimeToBetter collects, uses, and stores communications between users and Counselors on the Platform, and communications between users and TimeToBetter’s customer service team ("Communications Data").
Purposes for Which Information Is Used
We may use the information we collect for one or more of the following purposes:
Communication with you
- To contact you or provide you with information, alerts and suggestions that are related to the Platform.
- To verify your identity.
- To complete an activity you requested, such as register for the Platform or obtain more information.
- To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
Delivery of services to you
- To create your account on our Platform and let you log in to your account and use the Platform.
- To manage your account, provide you with customer support, and ensure you are receiving quality service.
- For billing and transaction processing purposes.
- To match users with Counselors and facilitate the Counselor Services.
- To provide, support, personalize, and develop our Platform and the Counselor Services.
Administration and improvement of services
- To supervise, administer and monitor the Platform.
- To measure and improve the quality, effectiveness, and delivery of our services.
- To personalize the website experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads.
Compliance with law
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To comply with applicable state and federal laws, including, but not limited to laws related to protecting client and public health and safety.
- To allow therapists to comply with the licensure, legal and quality requirements in their jurisdictions.
Other uses with consent
- Any other purpose with your consent.
Purposes for Which Information Is Disclosed to Third Parties
Information about you may be disclosed to third parties for one or more of the following purposes:
For business purposes: Only as necessary for facilitating the Counselor Services, we may share a user’s information with a Counselor and a Counselor’s information with a user. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms.
With your direction or consent: We may share your information with third parties if you request or direct us to do so.
With affiliates within our corporate group: We may share your information with any subsidiaries or parent companies within our corporate group.
For advertising: If you opt-in to the use of targeting cookies and web beacons, information regarding your activity on our websites, excluding activity when you are logged in and have started therapy, may be disclosed to our advertising partners to optimize marketing. We do not share with any advertising platform private information like member names, email addresses, phone numbers, diagnosis, sessions data, journal entries, messages, worksheets, or any other type of communication you have with your therapist. If you want to opt-out of these cookies and web beacons, please contact us via email.
Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.
In the context of a transaction: We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.
Note that if you make any information publicly available on the Platform, anyone may see and use such information.
Cookies and Web Beacons
Like many websites, we use "cookies" and "web beacons" (also known as pixels) to collect information. A "cookie" is a small data file that is transferred to your computer's hard disk for record-keeping purposes. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. A "web beacon" is a tiny and sometimes invisible image or embedded code, placed on a Web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users at a website for the purpose of web analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.
You can change your browser's settings so it will stop accepting cookies and web beacons or to prompt you before accepting a cookie or web beacon.
Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our websites for purposes of analytics and analysis of certain Platform usage.
Social and General Information Tools
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).
Security of Information
While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all 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 all applicable federal laws, state laws, and regulations regarding data privacy.
We may employ third-party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational, or other services for us. These tasks include, but are not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.
We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you are aware that we have collected Personal Information from a child under age 13 please let us know by contacting us and we will delete that information.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal processes (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Counselors may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.
General Data Protection Regulation (GDPR) and UK General Data Protection Regulation Notice
TimeToBetter may use your personal information:
When it is necessary to do so to perform our obligations in accordance with any contract that we may have with you, for example to manage your account, and to respond to inquiries about your use of the Platform.
When it is in our legitimate interests or a third party's legitimate interests to use personal information in such a way to ensure that we provide the Platform in the best way that we can. In particular, we have a legitimate interest in using your personal information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of the Platform. We only rely on our or a third party's legitimate interests to process your personal information when these interests are not overridden by your rights and interests.
When it is necessary to do so to comply with any legal obligations imposed upon us, for example under applicable law.
In rare instances, when it is a medical emergency, we may use your personal information to protect your or another’s vital interests if consent is not a reasonable option.
When you have consented to the use of your personal information, for example for marketing purposes or to track your online activities via Cookies and similar technologies.
Sensitive Data Clause
About sensitive personal information:
TimeToBetter may also collect and process certain categories of personal information, which legally may be considered “sensitive personal information,” based on (1) health and social care, (2) our establishment, exercise, or defense of a right or legal obligation, or (3) substantial public interest. Sensitive personal information that we process includes your racial or ethnic origin, religious or philosophical beliefs, and data concerning your health or about your sex life or sexual orientation.
When you begin to use our services and register your account, we ask you to provide answers to a questionnaire to customize the service, to match you with the right counselor, and to provide therapy and related services to you. In providing your responses to the questionnaire you may provide us with “sensitive personal Information” as described above. You may also continue to share such data with us as you receive services. This data allows us to continue providing services to you and customize our services for you. We may also use this information to improve our service and understand how you interact with the services.
Use your sensitive personal information to provide you with our services and conduct the processing described above;
Transfer your personal information outside of the EU or the UK as described below; and
Share your personal information, including sensitive personal information, with counselors to provide you with our services, and with other third parties (such as vendors that enable us to provide you services, lawyers, and auditors), subject to us entering into written agreements with them which require them to implement and maintain appropriate safeguards to manage your personal information.
How We Obtain Your Personal Information
TimeToBetter obtains the categories of personal information listed above from the following sources:
Directly from you. For example, information when you apply to be a counselor or that you submit during the process of using and paying for our Services.
Indirectly from you. For example, through your actions on our website.
From third-party business partners such as social media sites, ad networks, and analytics providers.
Your Rights and Choices
EU, UK, and Swiss residents have specific rights regarding their personal information. This section describes your rights if you are resident in the EU, UK, or Switzerland, and explains how to exercise those rights.
Right of access: You may be entitled to ask us for a copy of any personal information which we hold. This right is known as a ‘Subject Access Request.’ We will normally send you a copy of the personal information within one month of your request. However, that period may be extended by two further months where necessary, taking into account the complexity of the request or the difficulty in accessing the personal information that you request. There is usually no charge. In exceptional circumstances, we may charge a reasonable fee after discussing the fee with you.
Right to rectification: If the personal information we hold about you is inaccurate, you may request rectification. The personal information will be checked, and, where appropriate, inaccuracies will be rectified.
Right to erasure: In certain circumstances, you may be entitled to ask us to erase your personal information.
Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic personal Information that we hold about you to another organization.
Right to object: You may object to your personal information being used for direct marketing. You may object to the continued use of your personal information in any circumstances where we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for processing your personal information, you may object to us continuing to process your personal information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your personal information, we may continue to do so. In that event, we will let you know the reasons for our decision. In some instances, objecting to certain processing may impact our ability to provide you with services.
Rights related to automated decision-making including profiling: We use limited personal information to operate the Platform and to carry out certain profiling activities to support and grow our business. When doing so, we rely upon our legitimate interests as the lawful basis for processing your personal information and you may exercise the above rights if you do not wish us to process your personal information in this way.
To exercise the rights in relation to your Personal Information set out in this section, please contact us at [email protected].
International Data Transfers
As a part of our standard business practices, we may transfer your personal data to organisations based in countries that have not been granted an adequacy decision under the General Data Protection Regulation.
Where data is transferred to such countries, we shall ensure that specific safeguards or derogations have been established.
These might include where the data transfer is necessary in order to fulfil a contract between us and yourself, where we have received your specific consent after having made you aware of any risks involved, or where contracts are in place between us and the third-parties involved that ensure the recipient organisation has a suitable standard of data protection in place.
Last Updated and Effective: May 10, 2022