ValorWell Privacy Policy
SECTION 1: Data Collection and Processing
Policy Revisions and User Notifications
Our Privacy Policy is subject to periodic revisions to ensure it remains current with our practices and compliant with evolving regulations. In the event of substantial modifications to this Policy, we will alert you via our platform—either through our website or mobile application—upon your next login. To stay informed about our data handling practices, we recommend that you check this page regularly for any updates or changes.
What Information Do We Gather?
ValorWell does collect and process a range of personal information. The specific types of data we handle vary based on how you interact with our website, application, or overall platform. This includes, but is not limited to:
● User account details
● Platform interaction data
● Service usage information
● Clinical data (including health and treatment information)
For a comprehensive breakdown of the data categories we manage, please refer to the detailed list provided below.
Why Do We Collect This Information?
We gather and process your data for several key reasons:
● To ensure our platform runs smoothly and efficiently
● To provide you with seamless access to our services
● To continually improve and personalize your experience
Additionally, we may use your information to communicate with you through emails or text messages. These communications typically fall into two categories:
● Essential service-related updates
● Marketing materials (which you can opt out of at any time)
Data Sharing and Advertising
With your explicit consent, we may share certain data with trusted third-party partners for advertising purposes. This is entirely optional and only occurs if you choose to opt in. Your contact phone number and sms consent will never be shared or sold to any third-part for any purposes.
Data Retention and Your Rights
For information about how long we retain your data and your rights regarding data deletion, please consult the "How long do you keep my data and can I request deletion of my data?" section of this Privacy Policy.
Detailed Data Categories
In the following sections, we provide a comprehensive overview of the specific types of data we collect and process, along with our business purposes for each category. This includes sensitive information like "Clinical Data," which is essential for providing our mental health services. We encourage you to review these categories carefully to understand the full scope of our data practices.
DATA CATEGORIES AND USAGE
We collect and process various types of data to operate our platform efficiently, ensure you can use our services effectively, and improve your overall experience. Below, we detail the categories of data we handle and how we use them.
User-Centric Data
User Profile Information
We collect the account name you choose, along with demographic details, contact information (email, phone), age, emergency contact, and email verification status.
How we use it:
● Facilitating your therapy sessions
● Personalizing your platform experience
● Improving our services
● Ensuring your safety and legal compliance
Phone & SMS Information
We collect your phone number and SMS consent from our initial contact form found at https://valorwell.org/get-started
How we use it:
● Facilitating your therapy sessions
● Personalizing your platform experience
● Improving our services
● Ensuring your safety and legal compliance
Unique Identifier
We assign a system-generated unique ID to each user account.
How we use it:
● Enabling core platform functionality
● Facilitating communication between you and your therapist
● Monitoring and improving service quality
● Ensuring user safety and legal compliance
Initial Assessment Data
This includes information you provide during the initial questionnaire when setting up
your account.
How we use it:
● Matching you with appropriate therapy services
● Customizing your platform experience
● Enhancing our service offerings
● Ensuring compliance with healthcare regulations
Platform Interaction Data
Platform Usage Information
When you interact with our website, app, or platform, we gather data such as pages viewed, features used, time spent on the site, errors encountered, device specifications, browser type, and IP address.
How we use it:
● Enhancing your therapy experience
● Improving our service quality and user interface
● Personalizing your interactions
● Ensuring legal compliance and user safety
● Sending relevant updates about our services
User Activity Metrics
We collect data on how you interact with our emails and platform features, including
login patterns, message exchanges, session schedules, and usage of tools like
worksheets and journals. This excludes the content of your therapy sessions.
How we use it:
● Enhancing platform functionality
● Improving communication effectiveness
● Personalizing your experience
● Ensuring compliance and user safety
Support Interaction Logs
We maintain records of your communications with our customer support team.
How we use it:
● Addressing your inquiries and concerns
● Improving our support services
● Ensuring legal compliance and user safety
Therapy-Specific Data
Therapeutic Communication Content
We process written exchanges between you and your therapist, including messages,
worksheets, and journal entries. We may also process transcribed audio messages if
you choose to send them.
How we use it:
● Facilitating your therapy process
● Ensuring compliance with healthcare regulations
Comprehensive Treatment Documentation
We maintain a clinical record containing essential information for identifying you and
documenting your treatment. This includes therapist notes, service dates, and relevant
subsets of your initial assessment, account data, and therapy interactions.
How we use it:
● Providing therapists with necessary information for quality care
● Facilitating billing and insurance processes
● Ensuring compliance with healthcare regulations and standards
Service Quality Feedback
We collect your feedback about therapists, including ratings, reviews, and reasons for
changing therapists or ending therapy. We also track therapist availability and session
attendance.
How we use it:
● Improving our therapy services
● Enhancing user experience
● Monitoring and maintaining service quality
Financial and Operational Data
Financial Interaction Records
We process data related to your payments, subscription status, trial usage, discounts received, and account creation.
How we use it:
● Processing payments and managing subscriptions
● Improving our service offerings
● Ensuring legal and financial compliance
● Personalizing your experience
Therapist-Related Data
Mental Health Professional Information
For therapists, we process professional and personal details necessary for employment,
including name, financial information, demographic data, professional credentials, and
areas of expertise.
How we use it:
● Facilitating therapist recruitment and onboarding
● Managing therapist accounts and payments
● Matching therapists with appropriate clients
● Ensuring compliance with healthcare regulations
Provider Platform Utilization
We collect data on how therapists use our platform, including login frequency, session
counts, message exchanges, and use of platform tools.
How we use it:
● Optimizing platform functionality for therapists
● Improving therapist-client matching
● Enhancing overall service quality
Special Considerations for Mental Health Professionals
For mental health professionals using our platform or considering joining ValorWell, we handle additional categories of information. This includes Therapist-Specific Data, Service Quality Metrics, Platform Engagement Statistics, Professional Identification, Initial Evaluation Information, and Account Setup Details. We use this data for various purposes:
1. Streamlining recruitment and platform orientation
2. Facilitating client-therapist matching based on expertise and preferences
3. Ensuring secure account access and identity verification
4. Conducting necessary background and credential checks
5. Managing payments and tax compliance
6. Providing performance insights and client feedback
7. Keeping you informed about platform updates and opportunities
8. Enhancing your professional visibility on our platform and partner sites (To adjust your promotional settings, contact dataprotection@valorwell.org)
9. Delivering important notifications about your account and applications
Collaboration with Service Partners
To maintain and improve our platform's functionality, we collaborate with select service providers, which may involve sharing certain data. This sharing is essential for website operations and application performance.
Data Sharing with Your Consent
When you explicitly agree to data sharing, we may disclose specific information to third parties. For a comprehensive explanation of our data sharing practices, please refer to the "Understanding How We Share Your Data?" section of this policy.
Use of Data for Advertising
If you opt in to our advertising features (including what we previously termed "Targeting cookies" and web beacons), we may process visitor data for advertising purposes. For more details on this practice, please consult the "Are you using my data for advertising?" section of our policy.
How We Handle Location Information
At ValorWell, we understand the importance of handling location data with utmost care and transparency. We use your IP address to estimate your general geographical area, which allows us to tailor our platform to your region and provide location-relevant service information. This approximate location detection helps us enhance your user experience in several ways.
One of the primary benefits of this approach is the ability to streamline your interactions with our platform. For example, when you're completing our initial questionnaire, we can pre-fill location fields like your country and state (where applicable), saving you time and effort. It's important to note, however, that we do not collect or process exact location
data, such as GPS coordinates from your mobile device.
When you begin therapy, we ask for your address as part of your emergency contact details. This information is crucial for complying with therapy regulations and ethical standards, and it enables your therapist to act quickly if they believe you're in immediate danger. To make providing this information easier, we may use your approximate
location to offer address autocomplete suggestions.
We may process IP addresses for additional purposes beyond what's described here. For a more comprehensive understanding of how we use various types of data, including location information, to provide and improve our services, we encourage you to review other sections of our privacy policy. Specifically, you might find relevant information in the sections titled "Why are you collecting my data?", "Are you using my data for advertising?", and "Additional Privacy Notice for California Residents".
Your privacy is paramount to us, and we strive to use location data judiciously and only in ways that benefit your experience with our mental health services. If you have any questions or concerns about how we handle location information, please don't hesitate to contact our privacy team.
Our Approach to Artificial Intelligence
At ValorWell, we harness the power of advanced technologies to enhance our services and improve your experience. This includes the use of Artificial Intelligence (AI) and sophisticated language processing algorithms. These tools help us develop new features, streamline our operations, and elevate the quality of care we provide.
Our data processing approach combines the precision of automated systems with the nuanced understanding of human oversight. While AI excels at handling repetitive tasks efficiently, we believe in the importance of human judgment in sensitive matters. This balanced approach allows us to offer you a service that's both technologically advanced
and deeply respectful of the human elements of mental health care.
You might wonder how this technology impacts your experience with ValorWell. In practice, AI assists us in various behind-the-scenes ways. It helps us identify potential security risks, ensuring your data remains protected. Our customer service team uses AI to quickly access relevant information, allowing them to assist you more effectively.
Therapists benefit from AI-powered tools that help them manage and document sessions, freeing up more time for meaningful interactions with you.
We're excited about the potential of these technologies to enhance our services for both members and therapists. However, we're equally committed to ensuring that our use of AI remains fair, accurate, and respectful of your privacy. To this end, we take a cautious approach to AI development. We either carefully review existing models or build our
own internally, always prioritizing your privacy and the integrity of our therapeutic relationships.
It's crucial to emphasize that your most sensitive information - your therapy sessions, journal entries, messages, and other private communications with your therapist - is never used to train our AI models. We believe that the confidentiality of these interactions is paramount and should be protected at all costs. Our goal is to use
technology to support and enhance the therapeutic process, never to replace the human connection at its core.
As we continue to explore the potential of AI in mental health care, we remain committed to transparency and ethical practices. We believe that technology, when used responsibly, can play a valuable role in improving mental health services, always in service of the human relationships that form the heart of effective therapy.
SECTION 2: Data Sharing
Understanding How We Share Your Data
At ValorWell, we take the responsibility of handling your data seriously. While we strive to keep your information confidential, there are certain circumstances under which we may need to share your data. We believe in transparency, so we want you to understand these situations clearly.
Firstly, we may be required to share your data to comply with legal obligations. For instance, if a court issues a subpoena, we might be obligated to provide specific information requested in that subpoena. This isn't unique to our platform; it's a standard practice that applies to in-person therapy as well. It's important to note that we generally defer to your chosen therapist regarding the disclosure of psychotherapy notes or messages you've exchanged. Many jurisdictions have
strict rules governing therapist-client relationships and associated confidentiality requirements. We encourage you to discuss any concerns about disclosure obligations with your therapist early in your relationship.
In some cases, a select number of employees from our parent company might handle your data for support services. Rest assured, these employees are bound by strict confidentiality agreements. For example, a paralegal from our parent company might receive legal correspondence or subpoenas on behalf of current or former members, ensuring that such
matters are promptly forwarded to our legal team for appropriate handling.
To maintain and improve our platform, we collaborate with various service providers. This collaboration may involve sharing certain data to facilitate essential functions. For instance, we use cloud hosting providers for data storage, integrate technologies for live audio and video sessions, employ customer service tools to manage inquiries securely, and utilize payment processing services for secure transactions. We also work with analytics providers to understand how our site is used, helping us to continually improve our services. In all these partnerships, we prioritize your data security and only share what's necessary for the specific service.
For our therapists and those considering joining our platform, we may share relevant data with recruiters to facilitate the hiring process. If you're receiving our services through an employer or Employee Assistance Program (EAP), we might share group-level usage data with your organization. However, this data is aggregated and cannot be linked directly to you. In cases where individual-level data needs to be shared with an EAP (with your consent), the EAP will notify you directly.
In the event of significant business changes, such as an asset sale, merger, or bankruptcy, we may need to share some of your data as part of that process. Additionally, any information you choose to make public on our platform, such as through a public post, becomes accessible to anyone.
Lastly, if you opt in to certain features like analytics or advertising cookies, we may process data about your site interactions or share information about your website activity (excluding logged-in therapy sessions) with trusted service providers for advertising purposes.
We understand that the idea of data sharing can be concerning, especially when it comes to mental health services. That's why we're committed to being upfront about our practices and to protecting your privacy to the fullest extent possible within the bounds of providing our services and complying with legal requirements. If you have any questions or concerns about how your data is shared, we encourage you to reach out to our privacy team for more information.
Navigating Legal Requirements and Your Privacy
At ValorWell, we're committed to protecting your privacy while also adhering to our legal obligations. It's important to understand that, like any mental health service provider, we sometimes need to use your data to comply with the law. This isn't unique to our online platform; the same principles apply to traditional in-person therapy as well.
There may be instances where we're required to cooperate with government agencies. For example, if a court issues a subpoena, we might be legally obligated to share specific information requested in that document. However, we want to reassure you that we take your privacy seriously. As a general rule, we defer to your chosen therapist when it comes to
decisions about producing (or not producing) psychotherapy notes or messages you've exchanged. Many jurisdictions have strict regulations governing therapist-client relationships and the associated confidentiality requirements. We strongly encourage you to have an open conversation with your therapist early in your therapeutic journey if you have any concerns about their disclosure obligations.
It's also crucial to be aware that therapists themselves may have legal and professional responsibilities that require them to disclose certain information to authorities under specific circumstances. These situations typically involve scenarios where there's a risk of harm to yourself or others. For instance, mental health professionals are often required by law to report cases of suspected abuse, situations where there's a serious risk of suicide, threats of harm to others, or to comply with court-ordered treatment.
These reporting requirements are designed to protect vulnerable individuals and ensure public safety. They reflect the delicate balance between maintaining client confidentiality and fulfilling the broader duty of care that mental health professionals have to society. While these situations are rare, we believe it's important for you to be informed about them. If you have any concerns or questions about these potential scenarios, we strongly recommend discussing them with your therapist. They can provide more detailed information about their specific obligations and how they navigate these sensitive situations while striving to maintain your trust and confidentiality to the greatest extent possible.
At ValorWell, we're committed to transparency about these legal realities while doing everything in our power to protect your privacy and maintain the confidentiality of your therapeutic experience. Our goal is to create a safe, trusting environment where you can focus on your mental health journey, secure in the knowledge that your information is being handled responsibly and ethically.
Understanding Your Data and Advertising
At ValorWell, we believe in transparency about how we handle your information. Let's address two important questions: whether we sell your data and how we might use it for advertising purposes.
Firstly, we want to be clear that we don't sell your data in the traditional sense - we're not in the business of trading your personal information for money. However, it's important to understand that privacy laws, particularly in California, have a broad definition of what constitutes a "sale."
Under these laws, even sharing personal information in exchange for services of value could be considered a "sale." This means that if you opt in to our use of advertising cookies and web beacons, it might be classified as a "sale" under California law. If you're a California resident, we encourage you to review the additional notice we've provided specifically for you, which outlines your data rights in more detail.
Now, let's talk about advertising. Our goal is to reach individuals who might benefit from mental health support, and to do this effectively, we advertise on various third-party websites and apps. We strive to make these ads relevant and interesting to you, which not only improves your experience but also helps keep our costs down - savings we can pass on to you. If you choose to opt in to advertising cookies and web beacons, we may share some of your visitor data for advertising purposes. It's crucial to note that this never includes any information from your therapy sessions or when you're logged into our platform. You might notice our ads on other websites as a result of this sharing.
For mobile app users, the process is a bit different. If you've allowed app tracking on iOS or opted into advertising cookies on Android, we use some data - like your device identifier and app usage information - to make our Google advertising more effective. This is done through an integration between Google Analytics and Google Ads. Don't worry, though - you're always in control. On Android, you can opt out of advertising in the app's "Sharing Settings." For iOS users, you can manage tracking permissions when you first download the app or later in your device's privacy settings.
We want to emphasize that even if you opt in to these advertising features, we don't engage in "retargeting" - we won't chase you around the internet with ads just because you visited our site once. More importantly, we never share any of your therapy-related information with advertisers. This includes your name, email, phone number, diagnosis, questionnaire answers, session data, journal entries, messages, or any other private communications you have with your
therapist on our platform. Your therapy experience remains confidential and separate from our advertising efforts.
We understand that privacy in mental health services is paramount. That's why we've taken these steps to balance our need to reach those who might benefit from our services with our commitment to protecting your personal information. If you're interested in learning more about the third parties we work with for advertising, we invite you to review our Third Party Partners Disclosure List.
Your trust is essential to us, and we're committed to using your data responsibly and transparently. If you have any questions or concerns about how we handle your information in relation to advertising, please don't hesitate to reach out to our Data Protection Team at dataprotection@valorwell.org.
SECTION 3: Managing Your Data: Retention, Erasure, and Access
At ValorWell, we take our responsibility for your data seriously. We're committed to retaining your information only for as long as necessary to provide our services and comply with legal requirements. We understand that you might have questions about how long we keep your data and how you can request its removal. Let's explore these
important topics.
Our approach to data retention is designed with your needs in mind. Even after you've cancelled your membership or your account becomes inactive, we retain certain categories of data for a period of time. This practice serves two main purposes: it allows for a smooth reactivation process if you choose to return to our services, and it enables
therapists to access historical information that might be relevant to your care.
Additionally, retaining some data is essential for the proper functioning of our platform and services.
We've developed a comprehensive data retention policy that takes into account various factors. These include the type of data we're processing, whether you've participated in therapy sessions, and whether you've specifically requested data erasure. Our policy also considers cases where data erasure might be triggered due to prolonged inactivity on the platform.
It's important to note that when we talk about data erasure, we're referring to the permanent removal or obfuscation of identifiable information. Once erased, this data is no longer accessible by anyone, ensuring your privacy is protected.
We believe in empowering our members to control their data, regardless of where they live. That's why we've established a process for all members to request data erasure or access their data without undue delay. Our Data Protection Department is dedicated to handling these requests efficiently and transparently.
If you're curious about how long we retain specific types of data associated with your account, or if you'd like to request data erasure or access, we're here to help. You can reach out to our Data Protection Department at dataprotection@valorwell.org for assistance with these matters.
We understand that data retention and erasure are complex topics, especially when it comes to sensitive information like mental health records. Rest assured that our policies are designed to balance your right to privacy with our obligations to provide quality care and comply with legal requirements. We're committed to being transparent about our practices and responsive to your needs and concerns regarding your personal data. For any member that requests data deletion, all the following personal identifiable information is deleted within 24 hours: Account Data; User ID; Transaction Data;
Member Engagement Data; Therapy Data; Customer Service and Communications Data.
Exercising Your Data Protection Rights
At ValorWell, we're committed to upholding your rights under data protection laws. This includes your right to request erasure of personal data we hold about you, as well as your right to request a copy of this data. We want to make exercising these rights as straightforward as possible for you.
If you wish to request data erasure, the process is simple. Start by logging into your account and navigating to the "My Account" or "Account Settings" section. Look for the "My Personal Information" tab, where you'll find an option to request complete erasure of your account. Following this link will guide you through the erasure process. Rest assured, we'll send you a confirmation email within 24 hours of receiving your request. We understand that you might encounter difficulties accessing your account or using this method. In such cases, don't hesitate to reach out to our Data Protection
Department at dataprotection@valorwell.org. They're here to assist you with the process, ensuring you receive a confirmation email within 24 hours of your request, just as you would through the account settings.
For those who prefer alternative methods, we've created an opt-out instructions page. Here, you can not only request data erasure but also opt out of any settings you previously agreed to.
It's important to note that we can only proceed with data erasure requests after verifying your identity. This step is crucial to protect your privacy and prevent unauthorized access to your information. While we typically process these requests free of charge, in rare circumstances, we may need to charge a reasonable fee. Should this be necessary, we'll discuss it with you beforehand.
When making a request, please keep in mind that only you or your authorized representative can initiate this process. If you're making a request on behalf of a minor child, your ability to do so may depend on applicable laws. We'll need sufficient information to verify your identity or your status as an authorized representative. Additionally, please provide enough details for us to understand, evaluate, and respond to your request effectively.
For members who joined ValorWell through an organization or Employee Assistance Program (EAP), the process is slightly different. In these cases, account erasure requests must be made by contacting our Data Protection Department directly, as the option won't be available within the platform itself.
It's crucial to understand that there are circumstances where legal or regulatory requirements may limit our ability to honor erasure requests. We may have to decline such requests if the information is subject to a litigation hold, necessary for legal compliance, or essential for maintaining business integrity. This includes Clinical Health Records, which fall under a special exemption.
Our compliance obligations also require us to retain records of certain interactions relate to your membership. As such, we can't erase information contained in records of communications about complaints, erasure or access requests, or disclosures of personal data to third parties.
If we find ourselves unable to comply with an erasure request, we'll explain our reasoning, detailing how we balanced your rights and freedoms against our legal obligations. In these cases, any retained information will only be used for purposes allowed under legally recognized exemptions.
At ValorWell, we strive to be transparent about our data practices and to respect your rights. If you have any questions or need assistance with exercising your data protection rights, please don't hesitate to contact our Data Protection Department at dataprotection@valorwell.org. We're here to help you navigate these important matters regarding your personal information.
Section 4: Understanding the Privacy of Your Therapeutic Interactions
At ValorWell, we prioritize the confidentiality of your therapy sessions while balancing the need for quality assurance and safety. We want you to feel secure in knowing who can access your interactions with your therapist, so let's break it down.
First and foremost, your therapeutic relationship is between you and your therapist. The messages you send and the worksheets you submit are visible to both of you, creating a secure space for your therapy work. If you choose to share journal entries, your therapist can see these too, but this is entirely optional and under your control.
We understand that quality of care is paramount in mental health services. To ensure we're maintaining the highest standards, we have a system in place for review. With your consent, a licensed therapist from our Clinical Operations Team may review your correspondence with your therapist. This typically happens in specific circumstances, such as if you express concerns about your therapist or if we need to assess the quality of care being provided. Rest assured, these
reviews are conducted by professionals bound by the same ethical and confidentiality standards as your therapist.
Your safety and the integrity of our platform are also top priorities. In rare cases where we have reason to believe there might be a security, legal, or fraud issue with a specific account, our Data Protection Department may need to review correspondence. This is a measure we take seriously and implement only when necessary to protect our users and comply with legal obligations.
We want to emphasize that your privacy is of utmost importance to us. Your messages with your therapist are never shared with any third parties. We don't record your live sessions, and we don't share information about when you send messages or have sessions with your therapist.
At ValorWell, we're committed to creating a safe, confidential environment for your mental health journey. We implement these measures to ensure the quality and security of our services while respecting the sanctity of your therapeutic relationship. If you ever have questions or concerns about the privacy of your interactions, we encourage you to reach out to our Data Protection Department at dataprotection@valorwell.org. Your trust is fundamental to the therapeutic process, and we're here to support you every step of the way.
SECTION 5: Handling Data for Minors
At ValorWell, we are committed to providing mental health services to individuals of all ages, including minors. We understand the importance of protecting the privacy and rights of our younger clients while also adhering to legal requirements. Here's how we handle data for minors:
1. Equal Treatment of Data: We handle all clients' information with the same level of care and security, regardless of age. This includes the application of our robust data protection measures and privacy practices to all user data, whether
the user is a minor or an adult.
2. State-Specific Requirements: We recognize that laws regarding minors' rights, particularly in healthcare decisions, vary by state. ValorWell is committed to complying with the specific requirements of each state regarding the handling of
minors' data and their rights to make certain decisions about their healthcare.
3. Release of Information for Minors: Requests for release of information for minors are handled in accordance with the laws of the state where the minor resides. These laws dictate different ages at which minors have certain rights
regarding their health information.
4. Honoring Minors' Rights: In cases where a child is under 18 but state law grants them the right to make certain decisions about their healthcare or data, ValorWell is required to honor these policies. This means that in some cases, a
minor may have the right to control certain aspects of their data or treatment decisions, even if they are not legally an adult.
5. Parental/Guardian Involvement: While we respect the rights of minors as dictated by state laws, we also recognize the important role that parents or guardians play in a minor's mental health care. We strive to balance the minor's right to privacy with the parent's or guardian's need to be involved in their child's care, always in accordance with applicable laws.
6. Consent and Assent: Depending on the age of the minor and state laws, we may require parental consent for treatment and data collection. In some cases, we may also seek the minor's assent (agreement) to treatment, even when
parental consent is the legal requirement.
7. Privacy in Communication: We take extra precautions to ensure that communications with minors are kept private and secure, recognizing the sensitive nature of mental health discussions for this age group.
8. Data Access and Control: As with adult users, minors (or their parents/guardians, as appropriate under state law) have the right to request access to their data, ask for corrections, or request data deletion, subject to legal and therapeutic considerations.
We encourage parents, guardians, and minor clients to discuss any questions or concerns about data handling and privacy with their therapist or our support team. For specific questions about how your state's laws affect the handling of a minor's data, please contact us at privacy@valorwell.org.
ValorWell is committed to providing mental health services to minors in a way that respects their privacy, complies with all applicable laws, and supports their well-being and that of their families.
SECTION 6: Understanding Cookies and Web Beacons in Your ValorWell Experience
In the digital world, terms like "cookies" and "web beacons" often come up when discussing online privacy. At ValorWell, we believe in demystifying these concepts and explaining how we use them to improve your experience on our platform.
Imagine cookies as small digital notebooks that your computer keeps. These notebooks contain information that helps our website remember you and your preferences. For instance, cookies can save you the hassle of entering your login information every time you visit our site. They're instrumental in personalizing your experience and enhancing the performance of our platform.
Web beacons, sometimes called "pixels," are like tiny digital eyes on a webpage or in an email. They're usually invisible to you but can observe how you interact with our site or emails. These tools help us understand how users engage with our content, allowing us to optimize our services and tailor our communications to your needs. At ValorWell, we use a combination of our own cookies and web beacons, along with those from our service providers and trusted third parties. This mix allows us to offer you a faster, safer experience on our platform. We use these tools to monitor and analyze how our site is used, ensure we're complying with relevant laws, and, with your permission, deliver personalized advertising.
We understand that you might have concerns about online tracking. That's why we've made it easy for you to control your cookie preferences.
For those who prefer a cookie-free experience, we've created a straightforward opt-out process. Simply visit our opt-out instructions page, where you'll find clear directions on how to stop tracking via cookies or web beacons. This page also includes information on removing any cookies that have already been set on your device.
We also want to respect your preferences when it comes to email communications. If you're receiving marketing emails from us and would like to stop, it's a simple process. At the bottom of each marketing email, you'll find an unsubscribe link. Clicking this link will allow you to opt out of future marketing communications.
At ValorWell, we're committed to balancing the benefits of data-driven improvements with your right to privacy. We use cookies and web beacons to enhance your experience, but we also respect your choice to limit or opt out of their use. If you have any questions about our use of these technologies or need assistance managing your preferences, please don't hesitate to contact our Data Protection Department at dataprotection@valorwell.org. Your privacy is important to us, and we're here to help you navigate these choices.
SECTION 7: Additional Privacy Notice for California Residents
This Privacy Notice for California Residents supplements the ValorWell Privacy Policy to comply with the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act ("CPRA") of 2020.
The CCPA and the CPRA are California laws that provide its residents with certain rights over information about them, including notice about the categories of personal information we have collected from them in the preceding twelve (12) months and the purposes for which the information is used or disclosed, and correction of personal information.
The following Sections outline the data that is Processed by us, as well as the purpose for collection, and the categories of sources of such information:
● What specific data are you Processing?
● Do you Process location data?
● Why are you collecting my data?
● What are you using cookies and web beacons for?
The data referenced at those links may fall in certain defined categories under the CCPA and CPRA. Accordingly, we may have collected:
● Identifiers;
● Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
● Protected classification characteristics under California or federal law;
● Commercial information;
● Biometric information;
● Internet or other similar network activity;
● Geolocation data;
● Sensory data;
● Sensitive Personal Information;
● Professional or employment-related information; and
● Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
The information that we have disclosed in the past 12 months and the recipients of the information are described above, in the section titled "Understanding How We Share Your Data?" The information that we may have shared in the past 12 months falls into the following personal information categories under the CCPA and CPRA:
● Identifiers;
● Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
● Protected classification characteristics under California or federal law;
● Commercial information;
● Internet or other similar network activity;
● Geolocation data;
● Sensory data;
● Sensitive Personal Information;
● Professional or employment-related information;
● Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
As noted in the Section titled "Do you sell my data?", our "sale" of information (including sale of information about consumers under the age of 16) consists of the disclosure of your information for targeted advertising purposes, and we aren't paid by any external or Third Party for any data. The information that we may have "sold" (for purposes of the
CCPA and CPRA) in the past 12 months falls into the following personal information categories under the CCPA and CPRA:
● Identifiers;
● Commercial information; and
● Internet or other similar network activity.
Do I have the right to know what information you have about me?
Yes, as a California resident you can request certain information about what we have Processed over the past 12 months. Once we receive and verify your consumer request, we can provide:
1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting that personal information.
4. The categories of Third Parties with whom we shared that personal information.
5. The specific pieces of personal information we collected about you.
6. Whether we disclosed your personal information for a business purpose and the personal information categories that each category of recipient obtained.
We will verify your identity by matching the information you provide with information that we maintain about you or via biometrics (specifically, FaceID via iOS). You also have the right to request that we correct personal information about you if it is found to be inaccurate. To make such a request, please send an email to dataprotection@valorwell.org.
Can I "opt out" or request that you delete my information?
Yes, you can request that we delete your data as described in the section of this Policy called: "How long do you keep my data and can I request deletion of my data?" Once your request is received and verified by matching the information you provide with information that we maintain about you or via biometrics, we'll move forward with the Process of deleting your information in line with our legal requirements and Retention Policy. We cannot fulfill a deletion request and need to retain your information if the data is necessary to:
● Provide you services, take actions reasonably anticipated within the context of our ongoing business relationship, or otherwise perform our contract with you.
● Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
● Debug products to identify and repair errors that impair existing intended functionality.
● Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
● Comply with applicable laws, including but not limited to, the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) and information covered by the California Confidentiality of Medical Information Act.
● Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair
the research's achievement, if you previously provided informed consent.
● Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
As noted above, you do not need to opt in to the "sale" of personal information about you by withdrawing your consent to accept cookies used for advertising here. Our websites are also designed to implement a do-not-sell privacy preference.
Other California privacy rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to Third Parties for direct marketing purposes. To make such a request, please send an email to dataprotection@valorwell.org.