PlusGuidance Global Limited (“PlusGuidance”) knows that you care about how your personal information is used and shared and takes your privacy seriously.
PlusGuidance is a telehealth platform that we offer to connect clients with our network of affiliated mental health professionals (“Service Providers”) to obtain online counselling and therapy services. “Service Providers” include employees, agents, or independent contractors of Service Providers. “PlusGuidance” or the terms “we” or “us” or similar terms refer to PlusGuidance Global Limited. “You” or “your” or similar terms refer to you as a user of our Platform (defined below).
1. Our promise to you.
We know you are entrusting us with some of your most personal and valuable information, including your personal health information. Your trust is built, in part, on our commitment to respect the privacy and confidentiality of your health information. We are committed to safeguarding and protecting your personal information, including health information.
The PlusGuidance telehealth platform includes, without limitation, the following services (collectively, the “Platform”):
(a) the facilitation of electronic communications with Service Providers,
(b) the provision of appointment scheduling and reminders and other services related to online counselling and therapy for both our registered users and Service Providers, and
(c) the provision of other information about PlusGuidance and our products and services through the Platform.
2. Collection and use of information – in general.
We collect Personal Information in the form of an email address for the purposes of creating a profile and for contacting you about your account. We collect information you provide voluntarily in free-form text boxes on the Platform and through responses to surveys, questionnaires and the like. If you communicate with us by, for example, email, facsimile or letter, any information provided in such communication may be collected as Personal Information.
The main reason we collect Personal Information from you is to provide you a safe, smooth, efficient, and customised user experience. The collection of Personal Information also enables our users to establish a user account and profile that can be used to interact with Service Providers and other users through the Platform. We only collect Personal Information we consider important to achieve that goal. You always have the option not to provide some, or any, Personal Information.
You are under no obligation to provide us with this Personal Information. We use your Personal Information to provide the Platform and administer your inquiries. You may change some of the information that you provide. Please see “11. Changing or deleting your information” below for further information.
3. How we use your non-medical Personal Information.
Some of the Personal Information we collect from you is unrelated to your receipt of counselling and therapy services through the Platform. Examples of how we may use your Personal Information include, but are not limited to, the following:
- Enable you to easily navigate the Platform
- Resolve service and billing problems via telephone or email
- Troubleshoot technical problems
- Bill any amounts due from you
- Better understand users’ needs and interests
- Personalise your experience
- Detect and protect us against error, fraud, and other criminal activity
- Enforce our Terms
- Provide you with system or administrative messages, and as otherwise described to you at the time of collection
- Provide you with further information and offers from us that we believe you may find useful or interesting
If you decide at any time that you no longer wish to receive certain communications from us, please follow the unsubscribe instructions provided in any of the communications or select the appropriate option in your user profile. (See “11. Changing or deleting your information” below.)
4. How we use your medical Personal Information (PHI).
5. Log data.
When you visit the Platform, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, or the web page you were visiting before you came to our Platform, pages of our website and Platform that you visit, the time spent on those pages, information you search for on our Platform, access times and dates, and other statistics. We use this information to monitor and analyse use of the Platform and for the Platform’s technical administration, to increase our Platform’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. For example, some of this information is collected so that when you visit the Platform again, it will recognise you and provide information appropriate to your interests. We also use this information to verify that visitors to the Platform meet the criteria required to process their requests.
Generally, our service automatically collects usage information, such as the numbers and frequency of visitors to our site and its components, similar to TV ratings that indicate how many people watched a particular show. PlusGuidance only uses these data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. These type of aggregate data enable us to figure out how often users use parts of the Platform so that we can improve the Platform.
You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Platform.
7. Web beacons.
We may also occasionally use “web beacons” (also known as “clear gifs,” “web bugs,” “1-pixel gifs”, etc.) that allow us to collect non-personal information about your response to our email communications, and for other purposes. Web beacons are tiny images, placed on a web page or e-mail, that can tell us if you have visited a particular area of the Platform. For example, if you have given us permission to send you emails, we may send you an email urging you to use a certain feature of the Platform. If you do respond to that email and use that feature, the web beacon will tell us that our email communication with you has been successful. We do not collect any PHI with a web beacon, and do not link web beacons with any PHI you have given us.
Because web beacons are used in conjunction with persistent cookies (described above), if you set your browser to decline or deactivate cookies, web beacons cannot function.
We may use a third-party vendor to help us manage some of our email communications with you. While we may supply this vendor with email addresses of those we wish them to contact, your email address is never used for any purpose other than to communicate with you on our or your Service Provider's behalf. When you click on a link in an email, you may temporarily be redirected through one of the vendor’s servers (although this process will be invisible to you) which will register that you have clicked on that link, and have visited our Platform. We also often receive a confirmation when you open an email from PlusGuidance if your computer supports this type of program. PlusGuidance uses this confirmation to help us make emails more useful to you.
Secure electronic messaging is always preferred to insecure email, but under specific circumstances, insecure email communication containing PHI may take place between you and PlusGuidance.
You should consider that standard email is not a secure means of communication. There is some risk that any PHI contained in email may be disclosed to, or intercepted, printed, or stored by, unauthorised third parties. PlusGuidance cannot ensure the security or confidentiality of messages sent by email.
Even if you have given us permission to send emails to you, you may revoke that permission at any time by following the “unsubscribe” information at the bottom of each such email.
9. Messages and transactions.
Comments or questions sent to us using email or secure messaging forms will be shared with our staff who are most able to address your concerns. We will archive your messages once we have made our best effort to provide you with a complete and satisfactory response.
However, these communications will not become part of your medical record (or other appropriate treatment record) unless and until you use the Platform to obtain mental health advice or a consultation from a Service Provider.
10. Information sharing and disclosure.
We will not rent, sell, or share Personal Information about you with other people or non-affiliated companies except to provide the Platform, when we otherwise have your permission, or under the following circumstances:
Service Providers. When you use the Platform to access mental health services, you will be sharing your Personal Information with a Service Provider via the Platform. By using the Platform, you expressly consent to sharing your Personal Information with your Service Provider, and you understand that all information shared with your Service Provider is subject to your Service Provider’s professional and legal duties of confidentiality and responsibility, which PlusGuidance does not control. To increase coordination of care and reduce overhead for you, you authorise the sharing of this information with other Service Providers on PlusGuidance whom you elect to contact.
User Profiles. User profile information, including your name, location, and other information you enter in your profile, may be displayed to your Service Providers to facilitate user interaction with the Platform.
Communications in response to user submissions. As part of the Platform, you may receive from PlusGuidance and other users email and other communications relating to your requests, mental health services, and other transactions. When you transmit information relating to your mental health services needs, PlusGuidance and the Service Providers you select may send you emails and other communications that they determine in their sole discretion to relate to your mental health services needs.
Aggregate information and non-identifying information. We may share aggregated information that does not include Personal Information and we may otherwise disclose non-identifying information and Log Data with third parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Third-party workers. We may employ third-party companies and individuals (“Third-Party Workers”) to process your payments, facilitate our Platform, provide the Platform on our behalf, perform Platform-related services (including, without limitation, maintenance services, database management, web analytics and improvement of the Platform’s features), or to assist us in analysing how our Platform is used. We do not share customer details with any third parties.
Compliance with laws and law enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of PlusGuidance or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. This includes, without limitation, exchanging information with Service Providers and law enforcement in response to Service Providers’ professional and legal responsibilities.
PLEASE NOTE THAT ANY INFORMATION, TEXT AND IMAGES THAT YOU POST OR DISCLOSE ON OR THROUGH PUBLIC PORTIONS OF THE SITE, OR ANY OTHER PUBLIC FORUMS, BECOMES PUBLIC INFORMATION AND MAY BE AVAILABLE TO VISITORS TO THE PLATFORM AND/OR SEARCHABLE VIA THE INTERNET.
Information regarding your activities in such Platform may also be available for view by other users (for example, other users may be able to view a list of all postings you have made in all available forums). We urge you to exercise discretion and caution when deciding to disclose your Personal Information through a forum or otherwise through the Platform.
PLUSGUIDANCE IS NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH A FORUM OR OTHERWISE THROUGH THE PLATFORM.
11. Changing or deleting your information.
You may review, update, correct or delete some portions of your Personal Information in your registration profile by making the appropriate modifications in your user account settings or by contacting us at firstname.lastname@example.org. Some Personal Information, such as your answers to online assessments, may not be updateable or deleted once submitted. If you delete certain information required to use the Platform then you may no longer be able to use the Platform and your account may be deactivated. If you would like us to remove your records from our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the records.
Please note that we may need to retain certain information for record-keeping purposes, and there may also be residual information that will remain within our databases and other records, which, irrespective of any efforts by us to delete information, will not be removed from them. We also reserve the right, from time to time, to re-contact former users of the Platform.
Finally, we are not responsible for removing information from the databases of third parties with whom we have already shared Personal Information about you.
We employ administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorised access, use, and disclosure. Except for appointment reminders, treatment referrals and prescription information, these measures include encrypting your communications by utilising Secure Sockets Layer (“SSL”) software, and using a secured messaging service when we send your Personal Information electronically. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable laws, including, without limitation, HIPAA. Except when you have requested us to send emails to you outside of the secure section of our Platform, all electronic PHI will be encrypted when we store it or transmit it, and we will use secure servers that we will back up regularly.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted electronically stored “personal information” (including but not limited to PHI or medical information). To the extent permitted by applicable laws, we will make such disclosures to you via email or conspicuous posting on the Platform in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Platform by Internet or email, or any electronic storage system, cannot be guaranteed. As a result, although we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Platform or that which is stored by us. You acknowledge and agree that any information you transmit through the Platform or upload for storage in connection with the Platform is so transmitted or stored at your own risk.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below. In addition, if you have privacy or data security-related questions, please feel free to contact us in the same way.
13. Our employees.
We will limit access to your Personal Information to personnel who have a need to know it for purposes of delivering our Platform.
All of our personnel must comply with our restrictions on access, use, and disclosure of PHI or face disciplinary action, up to and including termination.
14. International transfer.
Your information may be transferred to — and maintained on — computers located outside of your country, state, province, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United Kingdom and choose to provide information to us, we may transfer your Personal Information to the United Kingdom or European Union and process it there. Your submission of such information represents your agreement to that transfer.
15. Links to other sites.
The Platform is not directed to children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of the Platform. We do not knowingly collect personally identifiable information from children. Any users we suspect are under 18 years may be suspended immediately without warning or explanation. We do this to protect our Service Providers who may not be allowed to provide services to Clients under 18 years.
17. Agreement and changes.
18. Contacting us.
Last revised: 22/07/2016