**Privacy Policy for My Daily Therapy**

**Effective Date: [September 11, 2023]**

[Your Company Name] ("we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the "My Daily Therapy" mobile application ("the App"). By using the App, you consent to the practices described in this Privacy Policy.

**1. Information We Collect**

1.1. **Personal Information:** When you use the App, we may collect certain personal information, including but not limited to your name, email address, and other contact details.

1.2. **Usage Information:** We may collect information about your interactions with the App, including your use of features, interactions with content, and device information (such as device type, operating system, and unique device identifiers).

**2. How We Use Your Information**

2.1. **To Provide Services:** We use your personal information to provide you with access to and use of the App, including to provide notifications and support.

2.2. **To Improve the App:** We may use the information we collect to analyze and improve the functionality and user experience of the App.

2.3. **To Communicate:** We may use your contact information to communicate with you about updates, news, and other information related to the App.

**3. Disclosure of Your Information**

3.1. **Third-Party Service Providers:** We may share your information with third-party service providers who assist us in providing and maintaining the App.

3.2. **Legal Requirements:** We may disclose your information when required by law, court order, or other government or law enforcement authority.

**4. Your Choices**

4.1. **Access and Updates:** You may review, update, or delete your personal information by contacting us at [Mydailytherapyapp@gmail.com].

4.2. **Communication Preferences:** You may opt out of receiving promotional communications from us by following the instructions in those communications.

**5. Data Security**

5.1. **Security Measures:** We take reasonable measures to protect your personal information from unauthorized access, use, or disclosure.

**6. Children's Privacy**

6.1. **Age Limitation :** The App is not intended for use by individuals under the age of 13. We do not knowingly collect or maintain personal information from individuals under 13 years of age.

**7. Changes to this Privacy Policy**

7.1. **Updates:** We may update this Privacy Policy to reflect changes in our practices and the App's features. We will notify you of any material changes by posting the updated Privacy Policy on the App and updating the "Effective Date" at the top of this Privacy Policy.

**8. Contact Information**

8.1. **Contact:** For questions or concerns regarding this Privacy Policy or our privacy practices, please contact us at [Contact Email].

By using the App, you acknowledge that you have read, understood, and agreed to this Privacy Policy. This Privacy Policy constitutes the entire agreement between you and [Your Company Name] regarding the use of the App.

[My Daily Therapy]

This Privacy Policy applies to all visitors, users ("You" or "User"), including individuals purchasing our services for teams ("Subscribers"). My Daily Therapy, operated by My Daily Therapy eServices Private Limited ("My Daily Therapy," "We," "Us," or "Our"), encompasses the website (MyDailyTherapy.com and associated domains), the My Daily Therapy mobile application, web-based widget, My Daily Therapy Software Development Kit (SDK), and web-based applications (collectively referred to as "My Daily Therapy App" or "App/s" or "Mobile Software/s"). By using our Apps and Services, you engage with one or more of our offerings collectively known as the "Service(s)" or "My Daily Therapy Service."

These services include but are not limited to:

AI chatbot ("TherapyBot").
Digital self-care tool-packs.
Emotional well-being Blogs.
Guided-group meditations.
Services available for purchase on our website and webpages.
Online controlled and real-world research studies.

Additionally, we may offer these and supplementary services on behalf of your Institution ("Institutional Services"), which may encompass enterprises, universities, hospitals, research institutions, and other public or private organizations. Institutional Services may involve the processing of information on behalf of the Institution. If applicable, you must agree to the Terms of Services and Privacy Policies of both My Daily Therapy and your Institution to utilize Institutional Services.

2. Information Collection and Usage

This page outlines our policies regarding the collection, utilization, and disclosure of your personal information when you interact with our App and Service. This Privacy Policy is designed to uphold our commitment to your Right to be Informed. We use your data to deliver and enhance our service, and we will not use or disclose your data except as outlined in this Privacy Policy. Our data protection practices adhere to the fundamental principles prescribed by the General Data Protection Regulation (GDPR) and other relevant Data Protection Laws (as defined below).

By utilizing our Apps and services, you agree to the use of your information in accordance with this Privacy Policy and our Cookie Policy. Unless otherwise specified, the terms used in this Privacy Policy have the same meanings as those outlined in our Terms of Service.

3. Updates

We may modify this privacy notice periodically to ensure it remains current. You will be informed of any alterations to the Privacy Policy via in-app notifications and on our policy webpage. We encourage you to regularly review these pages for the most up-to-date version of this notice.

4. Compliance with Data Protection Laws

My Daily Therapy adheres to the principles set forth by the General Data Protection Regulation (GDPR) and other Data Protection Laws where applicable. We are committed to safeguarding your privacy and ensuring the security of your personal information.

Please note that specific details regarding the collection, use, and disclosure of your personal information, as well as your rights related to data protection, are detailed in our full Privacy Policy available on our policy webpage.

Thank you for choosing My Daily Therapy for your well-being journey. If you have any questions or require further information, please contact us using the details provided on our website.

Initial Effective Date: September 11, 2023 (ET)
Do Note :

If in a crisis or emergency, please call the relevant emergency number in your country or the approved helplines provided by Your Institution.
The App and service is not to be used by children under 13 years. My Daily Therapy does not take responsibility for any misrepresentation of age and use.
If you are between 13 and 18 years, read the Privacy Policy and Terms of Service with your parents or legal guardian and agree before use. Where requested by us, ask them to provide their consent to use the services at MyDailyTherapyapp@gmail.com.
We do not require any personal identifiers or sensitive data hence we do not ask for it. We may collect personal data where your Institution asks us to do so. You have the option to not share your personal data, your medical data and any other sensitive data when you use the My Daily Therapy App and Services.
Your interaction with the TherapyBot is with an Artificial Intelligence system and not a human. Hence, TherapyBot is restricted in the means of response.
The intended use for providing evidence-based tools and techniques is to manage emotions and encourage mental well-being in a self-help and self-monitoring context.
The App is not intended to provide a diagnosis, prognosis, treatment or cure of a condition or disease.
The App will not offer medical or clinical advice and only suggest that you seek medical help. My Daily Therapy App is designed to offer general mental health advice and support and cannot offer condition specific advice for complex medical conditions such as complex long term illness, cancer, infertility or genetic disorders among others.
Your data is stored in databases maintained by us and third parties located in countries other than your country of residence. Some of them may have data protection laws that may be less stringent than those in your country.
The App and its services are primarily in the English language.

Changes in v5.4.0 | June 13, 2023

Additions

My Daily Therapy App is designed to offer general mental health advice and support and cannot offer condition specific advice for complex medical conditions
Data processing when the user participates and consents to My Daily Therapy commissioned controlled and real-world online research studies. Data processing details provided in “What additional personal data do we process when you participate in the online controlled or real-world studies?”.

Updates

Lawful basis of processing has been updated to reflect the most appropriate that applies to the processing.
We also provide Hindi and Spanish version apps for users in certain geographies.
Event Data processing- to analyze app event data for improving product and service quality.
Made minor grammatical corrections.
In addition to CCPA, also updated for CPRA related privacy requirements
Updated the Insights & Involvement data in “What data do we process after taking your Consent?”

You can read the full list of changes in the Changes Log

Definitions

TherapyBot is the text-based AI service provided in a conversational messaging mode by My Daily Therapy Apps.

Anonymization is the process of removing personal identifiers from data sets so that the person can no longer be identified.

Cookie is a small amount of data stored on your device (computer or mobile device).

Data or Information under this Privacy Policy means both personal and non-personal data or information.

Data Controller or Controller has meaning as defined in applicable data protection laws. It is a natural or legal body which, alone or jointly with others, determines the purposes of the processing of personal data.

Data Processor or Processor or Service Providers or Business Associate has meaning as defined in applicable data protection laws. It is a natural or legal body which processes personal data on behalf of the data controller.

Data Protection Laws here means in accordance with the Indian Information Technology Act and Reasonable security practices and procedures and sensitive personal data or data rules, including but not limited to requirements of EU General Data Protection Regulation 2016/679 (GDPR), the UK Data Protection Act 2018 (UK GDPR), California Consumer Privacy Act (“CCPA”), California Privacy Rights Act (“CPRA”) and other USA privacy laws. Where applicable USA’s Health Insurance Portability and Accountability Act (HIPAA) and applicable Legal and Statutory requirements.

Data Subject (or User/You) means any living individual who is using our service and is the subject of Personal Data

Encryption is the process of transforming data into unreadable text so that it is only eligible to those possessing an encryption key.

Personal data or Personal Information has meaning as defined in applicable data protection laws. It is data about a living person who can be identified from the data and/or other information either in our possession or likely to come into our possession.

Processing means any operation or set of operations which is performed on personal data or on sets of personal data and as defined in applicable data protection laws.

Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific user without the use of additional information.

Non-Personal data or Non-Personal Information means any data that is made anonymous and does not reveal user specific identity.

Sub-Processor/s is a data processor who is sub-contracted some of the personal data processing.

Special Category data or Sensitive data has meaning as defined in applicable data protection laws. It includes personal data revealing or concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, sex-life or a person's sexual orientation.

Who are we?

My Daily Therapy is a comprehensive mental health application designed to serve as a versatile tool for stress management, enhancing mental well-being, and providing relief from anxiety.

Our application is meticulously crafted to empower individuals on their path to a more healthful and harmonious life.

Our overarching objective is to offer support not only during scheduled therapy sessions but also to provide a means for individuals to address their mental health needs proactively at any moment."

What personal data do we process and how do we use it?

We only use your personal data for the purposes for which we collected it. We will use it for another reason, only if compatible with the original purpose. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. We may process your personal data without your knowledge and consent, where this is required or permitted by law.

The table lists the data processing that we perform when you use the TherapyBot, Digital self-care tools, well-being service, services purchased from our website or multi-lingual offerings.

Source	Data Types	Processing Purpose	Lawful Basis
Collected from your device	Android or Apple identifier (app-device identifier)	To recognize you as a new or existing user. To create a random user identifier. Perform deletion of identifier before sharing data for analytic purposes. To associate users to their provided data to provide uninterrupted App and services. To migrate your data to a new device. To process subscription-related requests. To administer your account. To process for addressing your data rights. To comply with applicable law or regulation.	To perform our contract with you (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy)
Created by My Daily Therapy	Random user identifier	To recognize you as a new or existing user. To provide App and services. To create a random truncated identifier to provide minimal data for internal analytics. To provide additional security during data transfers. To administer your account. To process your data rights.	To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy)
Created by My Daily Therapy and entered by you.	Access or referral code	To send deep links to directly access the App and Institutional Services. To register you as an Institution user. To authorize access to Institution-agreed services. To provide customized App and services for referred and Institution users. To aggregate data at Institution or cohort or user level for analytics purposes. To administer your account. To process your data rights.	To perform our contract with you and with your Institution. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy)
Provided by you.	Nickname	To personalize content on the App and services. To administer your account.	To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy)
Collected from your device	Device data (Operating system, OS version, device make and model, time-zone)	To detect and prevent fraudulent use of or abuse of the service. To resolve issues. To improve App experience and use. To provide service-related information. To remind users of upcoming sessions and events.	To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Legitimate Interest to troubleshoot, ensure security and user experience.
Voluntarily provided by you.	Conversation data (free text messages, accidental identifiers submitted, Clinical questionnaires/assessment and scores, wellness data, voluntary SOS data) (Clinical questionnaires are a proven way to track progress of your mental well-being. You have the option to not respond to these assessments) (Wellness data include voluntarily provided special category health data. You have the option to not share any sensitive physical or mental health-related data.)	To apply our AI algorithms to wellness data to derive new data to indicate mood and emotional state. To detect context and ensure continuity in conversation. To detect medical or emergency terms to ensure safe conversations. To provide the right tool, technique and content. To provide and process the CBT Programs and send program use reports back to your Institution. To detect any SOS or self-harm triggers in messages and to signpost to safety resources. To improve AI algorithm safety. To improve product and service quality and customer experience. To anonymise reports. To anonymise research and analytics data. To share app use reports back to your Institution.	To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Additional Condition for any Special Category data: Reasons of substantial public interest. For safeguarding of children and individuals at risk.
Voluntarily provided by you.	Conversation data (Hindi or Spanish language free-text messages with TherapyBot, wellness information)	To use 3rd party translation APIs to chat with Hindi or Spanish language TherapyBot modules and tools. To apply our AI algorithms to derive new data to indicate mood and emotional state. To ensure continuity in conversation. To provide the right tool, technique and content. To improve the safety of our algorithms. To improve product and service quality and customer experience. To provide aggregated and anonymous analytics reporting. To perform anonymous research and analytics. To share app use reports back to your Institution.	To perform our contract with you and in our legitimate interest. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Additional Condition for any Special Category data: Reasons of substantial public interest. For safeguarding of children and individuals at risk.

Voluntarily provided by you.	Inadvertent submitted personal identifiers (names, location, contacts, email identifiers)	To take reasonable steps to detect and anonymise personal identifiers in end-user messages in English language Apps.	Legitimate Interests
provided by your Institution or subscriber and on your behalf.	Institution or Subscriber provided data (Institution or subscriber name, inquiry messages, email identifiers, names, phone number, Institution or subscriber user personal data)	To respond to the Institution or subscriber raised business and operational inquiries. For sending you an SMS or email on order confirmation and with access to our App. To inform you about our campaigns, product and services or Institution informed messages.	To perform our contract with your Institution or subscriber. To perform our contract with you (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy)
Events created during your use of App	Event Data (text button events, app screen events, tool events)	To share anonymised event data with 3rd party providers for analytics purposes. To obscure the event data to not reveal sensitive information. To analyze app event data for improving product and service quality.	Legitimate Interests
Voluntarily provided by you.	Communication Information (name, email Identifier, email messages, subscription receipts, feedback messages)	To respond to your inquiries, requests and feedback. To troubleshoot your issues. To provide and improve customer support services. To improve App and Services quality, safety and performance based on your feedback.	Legitimate Interests
Voluntarily provided by you.	Safety Plan Information (life anchors, safe places, support networks, warning signs, calming activities)	To allow end-users to create their own safety plan. To ensure availability of safety and support resources in time of need.	To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Additional Condition for Special Category data:Reasons of substantial public interest. For safeguarding of children and individuals at risk.
Voluntarily provided by you.	Other personal information (age-range, gender)	To provide age appropriate content, tools and techniques. Where applicable, to provide gendered languages. To identify children entering the system. To inform children to read and agree to My Daily Therapy Terms and Privacy Policy with their parents or legal guardian.	To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Legitimate Interest to identify children in the system.
Collected from your device by My Daily Therapy’s Content Delivery Networks (CDN)	Network Data (Internet protocol address)	To store in the CDN database and network logs. To enable access to all images, media and tools provided within the App during use. To enable secured access to both the app and website.	To perform our contract with you. As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy Legitimate Interest to maintain security (IP address is not linked to the app user identifier and not stored in the App database)

What data do we process when you use the My Daily Therapy Digital Front Door Service?

My Daily Therapy Digital front door application allows your Institution to triage you and your dependents to authorized care and support resources. The service redirects you to authorized support resources based on your country, service group, language choice, support choice and self-reported mood assessments. Support resources include the Institution’s EAP, the My Daily Therapy App and other Institution provided services. Access to the My Daily Therapy front door service will be via your Institution provided Single Sign-on (SSO) mechanism. Where required and on behalf of your Institution, we may integrate our App and Services with your Institution’s authentication mechanism such as Single Sign On (SSO). SSO enables you to use your Institution credentials to sign-in and access authorized My Daily Therapy App and Services and other third-party services. My Daily Therapy App will redirect you to your Institution’s SSO web page during your first access. The SSO processing is done by your Institution to verify your identity and direct you to the My Daily Therapy App. Your personal information, submitted during sign-in, is not transferred or stored in the My Daily Therapy system. My Daily Therapy will receive a one-time unique and encrypted identifier, which will be used to generate a random user identifier to associate you to the App and Services. My Daily Therapy will keep track of your login status and inform your Institution of any change to allow your Institution to manage future SSO requests. If you have any questions about your use of SSO please contact your Institution directly. No personal data is collected or processed during your use of the My Daily Therapy digital front door application and service. My Daily Therapy shall share population-level and aggregated analytics on App engagement and use with your Institution. You can delete your data at any time by selecting the “Reset my data” option available within the App.

What personal data do we process and handle as a Processor or Sub-processor?

My Daily Therapy may be a Processor where we are asked to process your data on behalf of the Institution. We will collect, transfer, store and use your data to provide the Institutional Services. Where required, My Daily Therapy will integrate with your Institution authorized information systems to process and transfer contracted data. We will maintain appropriate agreements with your Institution before any data processing or sharing.

We will also generate reports for your Institution. Only aggregated and anonymised data, at a population or cohort level, will be used for the Institution’s reporting needs. These reports will be generated and shared with your Institution as downloadable files via secure analytic dashboards. Your individual insights will never be shared with your Institution without your consent.

Where required by your Institution, we may guide you to appropriate support and crisis resources. These would be both within and external to the App including Institution provided helplines, EAP, offline care services and therapist support. This processing is not intended to be an emergency response and is performed to safeguard individuals at-risk.

What additional personal data do we process when you use our WhatsApp-based business service?

My Daily Therapy’s TherapyBot service delivered over WhatsApp business app is currently available as a pilot and only in the India geography. My Daily Therapy’s TherapyBot on WhatsApp business is limited to improving sleep efficiency. The service does not offer medical or clinical advice and only suggests that you seek medical help.

We may place ads online to test take-up of a specific Service or to market a specific Service using only authorized ad managers. Alternatively, you may obtain access to this service through your Institution. No personal identifiers will be collected and stored by us when you interact with these ads. When we run ads to test service take-up, we may provide access to limited tools or techniques on a standalone web-view. Your engagement on the web-view will be collected and shared with google analytics to identify level of usage. No personal data will be collected or processed from such web-views. Please read our Cookie Policy. We will not share your identifiable usage data with ad platforms for profiling or re-targeting by a third-party.

You will need to initiate this service from your WhatsApp account. My Daily Therapy will never use your messages to contact you for marketing purposes. My Daily Therapy processes the following data when you use this service.

Data Types	Source	Processing Purpose	Lawful Basis
Mobile phone number, WhatsApp profile name	Provided by the user during service initiation	To recognize you as a new or existing user on WhatsApp. To associate users to their provided data to provide uninterrupted services. Use WhatsApp profile name to personalize the communication with you. To process data for addressing your data rights. To respond to your inquiries, requests and feedback. To troubleshoot your issues. To provide and improve customer support services. To process To comply with applicable law or regulation.	To perform our contract with you (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Legitimate Interest to troubleshoot, ensure security and user experience.
Random user identifier	Created by My Daily Therapy	To provide additional security by pseudonymization of personal identifiers. To associate users to their provided data to provide uninterrupted services. To administer your account. To create a random truncated identifier to provide minimal data for internal analytics. To process your data rights.	To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy)
Conversation data (free text messages, accidental identifiers, sleep-related assessment, wellness data, voluntary SOS data)	Voluntarily provided by the user.	To apply our AI algorithms to wellness data to derive new data to indicate mood and emotional state. To detect context and ensure continuity in conversation. To detect medical or emergency terms to ensure safe conversations. To provide the right tool, technique and content. To provide and process the sleep or CBT programs and send program use reports back to your Institution. To set reminders and notifications. To detect any SOS or self-harm triggers in messages and to signpost to safety resources. To improve AI algorithm safety. To improve product and service quality and customer experience. To anonymise reports. To anonymise research and analytics data.	To perform our contract with you. (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Additional Condition for any Special Category data: Reasons of substantial public interest. For safeguarding of children and individuals at risk.
Engagement data (use of service features)	Captured during use of service	To group users as cohorts for cohort-level analysis. To analyse user engagement to help improve the services.	Legitimate Interests
Demographic data (age-range, city, interests, language)	Collected from user’s click on ads	Use Meta Ads manager to create ad campaigns, send ads about the service, analyze and improve the ad campaigns. To group users as cohorts for anonymous and aggregated cohort-level analysis.	Legitimate Interests
Inadvertent submitted personal identifiers	Voluntarily provided by the user	To take reasonable steps to detect and anonymise personal data within My Daily Therapy servers.	Legitimate Interests

Your messages on WhatsApp business are always end-to-end encrypted. As per WhatsApp Privacy Policy, your messages are typically stored on your device(s) and not on WhatsApp global servers. WhatsApp will temporarily store your messages in encrypted form while they are being delivered. Once your messages are delivered, they are deleted from WhatsApp global servers. We do not share the random user identifier with Whatsapp.

We use Twilio’s secure services to establish communication between our TherapyBot service and WhatsApp business. Twilio APIs assist transfer of encrypted messages between WhatsApp business and My Daily Therapy. Your messages are deleted from Twilio immediately after successful transfer to our servers. Your phone number and profile name are however retained in Twilio as long as connectivity of service is required. Read more about Twilio in the third-party service provider section.

Note: WhatsApp allows you to send attachments or voice messages. This is not required by us to provide our service. Please avoid sharing such information with us. Any inadvertent attachment and voice messages submitted by you gets deleted immediately from Twilio and our servers.

You can change your WhatsApp profile name at any time from your WhatsApp account. Clearing the WhatsApp messages will only delete your conversations on WhatsApp and as per WhatsApp data retention policies. To delete your data from My Daily Therapy servers please send us a request on My Daily Therapy@My Daily Therapy.io. Once deleted the data cannot be restored. Please read WhatsApp Privacy Policy and Terms of Service to understand what information WhatsApp collects and processes from you. You can block or delete our business service from your contact list at any time from your WhatsApp account. You can also mute notifications from your chat settings. You can always safeguard your information on WhatsApp using the privacy and security features provided by WhatsApp. Learn more about WhatsApp’s end-to-end encryption and Privacy and Security for business messages.

What additional personal data do we process when you participate in the online controlled or real-world studies?

You may voluntarily register or opt-in to participate in any of our online controlled or real-world studies from our web pages or social media posts. You will be asked to verify your contact to access our web-based widget App. We will provide you with study related information and seek your informed consent.

We will collect and process the following personal data from you at the time of study selections (enrollment data). This enrollment data will be used for the purpose of shortlisting participants for the study.

Data Types	Source	Processing Purpose	Lawful Basis
Email ID	voluntarily provided by you.	To authenticate and authorize you via OTP. To recognize you as a new or existing user on the App. To associate users to their provided data to provide uninterrupted services. To communicate study qualification. To communicate about the study prior to and during study period. To process data for addressing your data rights. To respond to your inquiries, requests and feedback. To troubleshoot your issues. To provide and improve customer support services.	To perform our contract with you (As an end-user, our contract is your agreement to Terms of Service and this Privacy Policy) Legitimate Interest to troubleshoot, ensure security and user experience.
Demographic data (country, gender, socio-economic status, age-range)	provided by you.	To apply study inclusion and exclusion criteria to qualify and recruit study participants.	Your Informed Consent for study participation
Health and wellness data (ethnicity, alcohol/substance use concerns, use of medication, any mental disorder diagnosis or treatment, about hallucination, validated assessment responses like PHQ-9, GAD 7, WSAS)	provided by you.	To apply study inclusion and exclusion criteria to qualify and recruit study participants.	Your explicit consent for study participation Additional Condition: Article 9 (j) archiving, research and statistics

You will be notified about your study qualification. If not selected or on drop out, your enrollment data will be permanently deleted from our systems within 60 (sixty) days. If selected for the study, your enrollment data will be retained by us for upto 1 year after study completion, after which they will be permanently deleted. You will receive a link or study referral code to access our mobile App for the study.

Data Types	Source	Processing Purpose	Lawful Basis
Study Referral Code	created by My Daily Therapy and assessed or entered by you.	To send deep links to directly access the App to qualified participants. To randomly authorize access to the control or intervention versions of the App. To aggregate data at Institution or cohort or user level for research and analytics purposes. To administer your account. To process your data rights.	Your explicit consent for study participation Legitimate Interest to support and process data rights.

We will collect and process your personal data when you use our mobile App as outlined here. At the end of the study period all users will be automatically considered as regular (non-study) users of our App. Only anonymised data (non-personal data) will be used for research, analysis and publication purposes. Your non-personal data will be retained as per our retention and deletion policy mentioned here.

Data Types	Source	Processing Purpose	Lawful Basis
Non-personal data (enrollment, engagement, resource utilization, safety triggers, assessment scores, feedback)	derived by My Daily Therapy for your provided study data	Derive and process non-identifiable data and assessment scores for research and study analysis. Process insights for the purpose of research publication.	Your explicit consent for study participation

You have the right to opt-out of research at any time after the study begins. You can either choose to opt-out from the app settings or write to us at My Daily Therapy@My Daily Therapy.io with the subject “opt-out of My Daily Therapy’s online controlled or real-data study”. On successful opt-out, we will delete your enrollment data within 1 (one) year of opt-out. Your data provided during use of mobile App will be retained as per our retention policy mentioned here.

Your data provided during the study will always be kept secure. Read more about our organizational and technical security safeguards here.

Do we use passive sensing or location data?

The App does not process any data from your mobile device sensors, including accelerometer, ambient light readings, screen on/off readings and call logs. The App does not process your geolocation at a level that makes your data identifiable. The App may infer your country or state based on your time zone to provide you appropriate resources, such as scheduled reminders.

How do we share your data with third parties?

To provide you with our services, we use third-party service providers to help store and process your data. We assess the service provider’s security and privacy practices. We strictly require that they comply with confidentiality and non-disclosure obligations and applicable laws and regulations including relevant Data Protection Laws. We also require that they or their providers (fourth parties) access your data only to the extent necessary to perform tasks on our behalf. We use the following third-party service providers.

Cloud Service Providers

To provide the service, we collect, transfer and store your data in secure servers provided by our authorized cloud service providers. You can find more on their security practices here, here and here. We maintain a Data Processing Agreement (DPA) with Standard Contractual Clauses (SCCs) and Business Associate Agreement (BAA) with our cloud service providers.

Other Service Providers

We use My Daily Therapy authorized third-party service providers to provide our services. List of our service providers include:

Service Providers	Purpose
Firebase, Google Analytics	To analyze App event data to understand user engagement and experience. No user conversation or personal data gets shared. Only a de-identified user identifier is shared along with the event data. All event data is made cryptic so that no medical or psychological profile gets created at the hands of the analytics provider. No direct advertising or direct marketing is performed. However, to measure the effectiveness of our social media or other marketing campaigns, we may use these tools to help us make improvements to our service. The third-party tool APIs may automatically collect some non-personal events. Google Analytics automatically collected events can be found here. The use of Google Analytics is governed by Google Data Policy and Data Safeguards. Firebase automatically collected events can be found here. The use of Firebase is governed by Firebase Terms of Service, and Crashlytics Terms of Service. We maintain Data Processing Agreements (DPA) with SCCs with these service providers
Strikingly	Our website is hosted on Strikingly. Strikingly uses your visit data to perform analytics. The use of Strikingly is governed by Strikingly’s Terms of Service, Privacy and Cookie Policy and GDPR Compliance Statement.
Branch.io	We use Branch.io to provide deeplink service for our Institution users that helps provide direct access to the App and services and is governed by branch.io’s Terms of Service, Privacy Policy and Security & GDPR Compliance. We have a signed Data Processing Agreement (DPA) with SCCs with Branch.io.
Mailgun	We use Mailgun to send confirmation messages to new users who subscribe to our services based on our promotions on Facebook/Meta, Google, Instagram or the App. We may request your personal name and institutional email ID and transmit this to Mailgun for the sole purpose of sending you the customized link to access the App basis agreement with your Institution. Your name and email ID will not be stored in our servers and will not be used for any other purposes. The services provided by Mailgun are based on their Terms of Service, Privacy Policy and Security & GDPR Compliance. We have a signed Data Processing Agreement (DPA) with SCCs with Mailgun.
Tawk.io	We use Tawk healthcare to provide assisted sessions by our therapyBot both within and outside the App. Tawk may collect additional personal information from you to provide their services. Please read their Terms of Service and Privacy Policy. You can read about Tawk security compliance here including HIPAA Security, Compliance certifications. We have signed a DPA with SCCs and Business Associate Agreement (BAA) with Tawk.
Google Workspace	We use Google Workspace to provide our corporate email service, to store Information received from our clients and end-users in google drive and google docs. We have a signed DPA with SCCs and BAA with Google Workspace.
3rd party Taggers and Translators	We may use third-party providers to tag, translate and test content in English and other languages. Minimal anonymised conversation data may be used for these purposes. This helps us improve the TherapyBot algorithm performance. We maintain confidentiality agreements with these contractors.
3rd party background verification consultants	We use consultants to perform background checks for shortlisted candidates. This includes reference checks and academic checks as part of hiring. We maintain confidentiality agreement with the consultants.
3rd party payment gateway providers	We use payment providers such as Stripe, PayPal, Razorpay and those provided by app stores to process payment when you purchase from us. Use of the Payment providers is governed by their terms of use and privacy policy. My Daily Therapy does not collect and store your credit card related information. We may collect your name, email Id to send you confirmations and for operational purposes.


CloudFlare	We use Cloudflare for its CDN and DDoS protection. Cloudflare helps us to efficiently secure and provide our Services for you. Cloudflare has access to your IP address to provide the services. My Daily Therapy does not store or process your IP address beyond the CDN. Your IP address is never mapped to your conversation messages. Hence your conversations remain secure and private. Cloudflare may process your browser and operating system related information for logging and abuse prevention purposes. You can read Cloudflare’s terms of service, privacy policy and GDPR Compliance to know more about how they handle your data. We have a signed DPA with SCCs with Cloudflare.
Meta Ads Manager	We use Meta Ads Manager to create ad campaigns to spread awareness, generate interest and aid conversions of our product and services. These ad campaigns will be India region focussed and for defined categories of users. These campaigns will run on facebook and Instagram. Analytics will be performed on aggregated data in order to measure the performance and reach of advertising campaigns. You can read about Meta ads here including how to manage your ad preferences. You can read Meta’s Data Policy, GDPR to know more about how they handle your data. We do not collect and store any user specific personal identifiers from Meta.
Business Development and Marketing Tools	We use marketing tools for lead identification, lead generation and business operations, for communications in marketing campaigns and other marketing activities. To communicate with our existing or prospective business clients or users. We ensure appropriate consent and opt-outs are provided when we reach out to prospects. We perform vendor and tool security assessment and vulnerability checks before we onboard a tool. We sign required agreements along with appropriate data protection clauses with tool suppliers.
Salesforce / Pardot	We use Pardot on our website to process data that you or your Institution provide via our online web-forms. We collect consent and provide opt-out for the data processing. The Salesforce / Pardot published compliance statement can be read here. We have a signed DPA with SCCs with the service provider.
Zendesk	We use Zendesk for the purpose of collecting customer support requests and inquiries. Read about Zendesk security and privacy compliance here. We have a signed DPA, CCPA and BAA with the service provider.
Iterable	We use Iterable for the purpose of sending SMS and email to you on how to download the My Daily Therapy app based on information shared by your Institution. We may also inform you about upcoming campaigns or about our product and services. Where applicable we collect opt-in and provide an option to opt-out or unsubscribe. Read about Iterable compliance and trust here. We have a signed DPA and BAA with the service provider.
6Sense	We use 6sense for the purpose of driving sales and marketing alignment by giving sales reps access to the Institution's account data and insights. The services use anonymous buying signals to accurately predict potential sales and marketing campaigns to organizations. Use of 6Sense is based on their Terms of Use. Read their Privacy Policy to understand how they handle your data. We sign required agreements along with appropriate data protection clauses with the service providers.

Disclosure to Institutions

You may need an access code or link provided by us, or your Institution, to use the Institution version of My Daily Therapy App. Your Institution may also get access to app usage data for their analytic and research purposes based on the consent given by you to your Institution and to us. We may collect your country, division and in some cases your city information to provide aggregated analytics. We do not share your messages with the Institution. Any inadvertent identifiers get removed prior to the aggregated analysis.

If the App is integrated with your Institution system, your Institution may additionally share your assessment scores with us and likewise, we may share aggregated user data with them. Such assessment scores may be processed by us for providing services to your Institution. Your assessment responses will never be processed for diagnostic purposes or for giving clinical advice.

Processing of any of your personal data as per our Legitimate Interests

We may be required to process your personal data in our legitimate interests.. We will always weigh your rights and freedom before we process any such requests for purposes of legitimate interest. This processing includes:

For enforcing our policies or contractual obligations with your Institution;
For uses and disclosures required by law;
For disclosures for judicial and administrative proceedings such as court order or subpoena;
For disclosures for law enforcement purposes or national security requests;
For disclosure and assistance with an investigation or prosecution of suspected or actual illegal activity;
For disclosure and use of a litigation hold. To freeze specific data relating to imminent, pending or current legal action, thereby preventing potential evidence alteration or deletion.
For uses and disclosures for public health reporting purposes;
For uses and disclosures to prevent serious threat to health or safety;
For uses and disclosures for minimal research and analytics purposes to study how users use our products and services;
For any service communications relating to your use of App and services;
To prevent, detect and repair problems related to the security and the operations of the App;
For uses and disclosures to prevent fraudulent use of or abuse of the service;
For uses and disclosures to take adequate security and privacy safeguards;
For uses and disclosures to ensure App and service availability, accessibility and quality;
For uses and disclosures to protect your data protection rights;
For uses and disclosures to protect your, our and others data protection rights, property and safety;
To use anonymized, non-identifiable, non-confidential user data for benchmarking and marketing;
To develop new services, technologies and products;
To respond to your enquiries and requests.

My Daily Therapy will never share your conversation data without your explicit consent provided either to us or your Institution.

In the future, if we are involved in any merger, acquisition, sale of assets, business reorganization, bankruptcy, we may transfer or otherwise share some or all of our assets which may include your data. We will take reasonable steps to inform you about this using the following modes.

Public notice on our website and/or
Inform your Institution and/or
Where applicable, send in-app notification and/or
Changes to this privacy policy and in-app notice.

You can always email us at MyDailyTherapyapp@gmail.com to exercise your data protection rights.

However, in such an event of sale or transfer, we shall reasonably ensure that your data with us is stored and used by the transferee in a manner that is consistent with this Privacy Policy and applicable Data Protection Laws. Any such third-party to whom we transfer shall have the right to continue to use the data that you provide us immediately prior to such transfer or sale. On completion of the sale or transfer, the Privacy Policy of the third-party shall apply with respect to your data.

Data Usage for App Enhancement

We value your trust in My Daily Therapy and are committed to continually enhancing our services for your benefit. To achieve this, we may utilize the data collected, including but not limited to usage data and chat data, to improve the functionality, performance, and quality of the My Daily Therapy app.

This data may be analyzed to gain insights into user interactions, preferences, and overall usage patterns. By doing so, we can refine our app's features, offer more personalized experiences, and develop new capabilities that better serve your mental well-being needs.

Rest assured that this data is processed in a secure and confidential manner, adhering to industry-standard security practices and in compliance with relevant privacy laws and regulations. We prioritize your privacy and will never compromise the security of your personal information.

Our commitment to enhancing the My Daily Therapy app is driven by our dedication to providing you with the most effective and supportive mental well-being tools and resources.

If you have any concerns or questions regarding the use of your data for app improvement, please feel free to contact us at [insert contact information]. Your feedback is essential in helping us make My Daily Therapy even better for you.

How do we handle your App password?

For your privacy and security, you are advised to set your own App PIN to protect unauthorized access of your conversation messages. Your mobile device screen password is your PIN. To extend your device password, use the "Set Lock " feature under the App settings. You can also remove your PIN using the "Remove Lock” option under settings. The PIN that you use is personal to you, and you are responsible for maintaining the confidentiality and security of your PIN. Please keep your PIN safe and do not share it with anyone. The PIN you set remains in your device and is not collected, transferred and stored in our servers.

What data do we process after taking your Consent?

We take your consent to perform the following processing.

Data types	Purpose	Lawful Basis
Website Cookies, web-based TherapyBot widget or web beacon Data (browser type, browser language, operating System, language settings, web page views and the link clicks, campaign clicks, IP address)	To understand website visits and engagement analytics. Use of AWS operational cookies. To share anonymised event data with 3rd party providers for analytics purposes.	Your consent to our Cookie Policy (We do not sell your provided data to any third-party)
My Daily Therapy Website Contact Form (Name, Email ID, inadvertent identifiers in messages)	To respond and provide support for your inquiries.	Your consent during form submission
App usage data and reports (derived using clinical questionnaires data, wellness data, app event data)	To process and share aggregated and anonymized analytics reports with your institution. To prepare and share custom analytics dashboard views.	Your informed consent with us and/or with your Institution (Agreements are signed with the researcher or Institution)
In-app push notifications	To notify you for reminders you have set. To remind you about upcoming sessions and events.	Opt-in and Opt-out in App settings or mobile device settings.
Session conversations with TherapyBot	To collect minimal anonymised data for research purposes.	Consent taken by TherapyBot from you.
TherapyBot activity and well-being assessment data	To share the data with your My Daily Therapy emotional well-being professional for your safety and support.	Authorize / unauthorize in app settings
Your conversation messages with the TherapyBot	To share your TherapyBot conversations with your My Daily Therapy emotional well-being professional.	Your consent given within the TherapyBot (opt-in and opt-out by typing #sharechat)
Recruitment data (name, contact, address, email id, resume, references, credentials, transcripts, government provided identification, compensation information, race or ethnic origin, opinions and beliefs, physical or mental health or condition, sexual orientation, memberships, social media handles)	To source, collect, store and process recruitment data from 3rd party recruitment portals. To evaluate your application. To make job offers. To enter into an employment agreement. To perform background checks. To perform reference checks. To convey application status. To consider you for other opportunities. To improve our hiring process.	Your consent. In our legitimate interest (to comply with laws, to protect your rights)
Promotion event data (email ID, name, phone number)	To process campaigns and surveys. To contact participants regarding campaigns and promotions. To send programme related information, send newsletters, webinar invites, set reminders. To enroll and onboard you to the programme or campaign. To correspond on programme or campaign matters.	Your consent given within the TherapyBot and campaign/survey/digital report enrollment forms.
Business data (customer name, email ID, contact details)	To communicate with business customers for lead generation, business development, business operations, account management or marketing purposes.	Communication is undertaken with appropriate expectation setting, consents or opt outs.
Insight and Involvement data (Contact Data: Name, email, phone, age-group, area of country, country, living experience with a medical condition. Demographic data: gender, sexual orientation, ethnicity, disability)	To contact you regarding Involvement opportunities, such as enrollment, attending meetings, sharing your opinion and experiences on our product or testing our product and services. To analyze your feedback and derive insight to improve safety, effectiveness of our product and services. Your Demographic data will be used to ensure our involvement remains fair and equitable. To ensure product testing is targeted to appropriate demographic groups.	Your Consent given during insight and involvement enrolment

How do we handle user incidents and requests?

There may be occasions where you wish to contact us to seek support or make inquiries. If you contact us directly over email, we will collect minimal personal information to service your request. Your communication data is securely stored in our Google Workspace account with access to only authorized users. We have signed agreements with Google Workspace. We will only use your data to investigate the issue or request asked. Your email will be retained within our system for a maximum of 10 years since last correspondence. We will not spam you or contact you for any direct marketing. We will not share or sell your personal data with any third-party disclosure.

Your issues or complaints or requests about the App and services are taken very seriously. You will need to send an email request from your Google or Apple email ID to MyDailyTherapyapp@gmail.com. We will respond to your complaints within 3 business days. Some of your complaints may take longer to resolve. We will continuously provide you with an update until your complaints are satisfactorily resolved.

How do we handle data provided during promotions, campaigns and surveys?

We do not promote third-party offers as a part of the App experience. Your promotion, campaigns and survey submissions will never be linked to your My Daily Therapy App account. Your promotion, campaign, survey submission will reside in our secure Google Workspace or marketing tool accounts. The Google Workspace and marketing tool account is protected by two step verification. You can opt out at any time from the programme by sending us an email request from your Google or Apple email ID to MyDailyTherapyapp@gmail.com. We will respond to your request within 3 business days. Your submissions will never be shared with a third-party.

How do we handle your payment data when you subscribe to our services?

[The Institution Version of My Daily Therapy App may carry a link to the institution EAP or health provider instead of or in addition to the My Daily Therapy emotional well-being professional. The EAP provider’s terms and privacy policy will apply to use such services.]

We do not collect, retain and store your personal and card information. Your card processing is handled by third-party payment agencies. We do not collect any personal data from the play stores post-purchase or from any of our third-party payment gateway providers. We may capture the enterprise name for business and operational purposes. Please read their terms and privacy policy before making a payment. The payment confirmation and subscription details are received and processed by us. This is to support you for your subscription-based requests.

What do we process when you follow us on Instagram or our other social media pages?

You have the option to follow us on Instagram using your Instagram account from the My Daily Therapy App settings. You can set up an Instagram account, if you do not own one and follow us at @_MyDailyTherapy. We do not associate your instagram account with your My Daily Therapy App account.

What do we process when you use the android speech-to-text feature?

During use of our voice TherapyBot, you may get an opportunity to talk with the TherapyBot apart from typing. For android phone users, you will need to give permission to activate your device microphone to speak to the TherapyBot. On microphone activation, the Google Android provided Speech Software Development Kit (SDK)/API within your device gets initiated. The Android SDK/API converts your speech to text and displays the text in your chat. The converted text data is securely transferred to our servers. We do not access nor collect nor store your voice data on our servers. No Personal data gets asked during use of this service. Please do not share your personal or sensitive information at any time during use of this service. The microphone is deactivated when you stop speaking and will not be always listening. The lawful basis for processing of your transcribed text is governed by this agreement. The processing of your voice for the purpose of converting to text is performed by Android SDK/API which is governed by Google’s Terms and Condition and Privacy Policy. Google may collect some identifiers and Information from you to provide their service. You can read Google’s Privacy Policy here. We do not access, receive or collect any identifiers and information that is collected by Google. Please speak close to the device microphone for improved translation. If you accidentally submitted any personal information, please write to us for any rectification at the contact provided here.

The same Android SDK/API plays back the TherapyBot response to you. Please ensure your mobile device volume is kept in optimal listening mode. Please note that you may experience some performance issues if you have low internet speeds.

How do we handle your data when used for research and analytics purposes?

We use minimal and only the required data for research purposes including aggregated data for any publications, to explore new technologies or to build new features or products. This data is completely anonymized using irreversible redaction of user identifiers prior to use. This helps us to improve our product and services and contribute to user-centered mental well-being best practices globally.

We never use your longitudinal conversation messages for research purposes and analysis. If at all, only limited messages get selected from specific TherapyBot endpoints and used.

You can always write to us at MyDailyTherapyapp@gmail.com to restrict processing and opt-out of your data for research purposes.

Additional information when you apply for employment or internship opportunities at My Daily Therapy.

We do not sell your Information to unauthorized third parties. Your data is stored in databases maintained by us or third parties located within India or globally. Where, privacy rules may differ and may be less stringent than those in your country. If you are successful in your application, we retain the information as part of your employee records. If you do not want us to retain your information or want us to update it, please contact us at MyDailyTherapyapp@gmail.com. Please note, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.

Please read here on your Privacy rights.

Your use of third-party weblinks

The App may carry links to third-party websites and resources. When you click on those links, you may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. We encourage you to read the privacy policy and Terms of use of every external link you visit.

What additional processing is performed?

We do not combine and process your personal data with any other third-party available data. Your data, messages or usage is not used for direct marketing nor is it sold to advertisers. We will always take your consent before using your name for social proof purposes.

We will update this Privacy Policy and inform you if we perform any additional processing.

How do we secure your data?

The security of your data is very important to us, and we work hard to secure it. We have implemented adequate technical and organizational safeguards to protect your data. Some of the steps we have taken to secure your data include:

Privacy by Design and Default

There is no user registration required. We don’t need it hence we don’t ask for it.
Only a nickname is sufficient to help us personalize our conversation with you.
We use pseudonymised identifiers to protect your data and identity.
No human eavesdrops during your conversation with the TherapyBot.
The TherapyBot will always check if it has understood you correctly before progressing.
We use algorithms that irreversibly redact any inadvertent personal identifiers entered in English.
You can opt-out at any time using the “reset my data” feature available in the App settings.
We adhere to the 7 key principles set out by GDPR (see here).
We perform Data Protection Impact Assessment (DPIA) for personal data processing.

Security by Design

We use TLS and SSL encryption during transfer and AES-256 protocol at rest.
Random identifiers are used for all data transactions between TherapyBot and our servers.
Our systems are secured with role-based access, strong passwords and two-step verification.
We enable endpoint security in all staff systems.
We review and maintain data processing agreements with our service providers.
We have a strict hiring and background verification process in place.
We provide regular awareness and training to our staff.
We conduct annual 3rd party compliance audits and data protection certifications.
We perform regular penetration tests of our Apps and Infrastructure.
We conduct regular checks to ensure compliance to our policies.

Certifications and Registrations

My Daily Therapy is registered with the UK Information Commissioner’s office (ICO)
Certified for Cyber Essentials
My Daily Therapy meets standards of the NHS Digital Data Security and Protection Toolkit (DSP Toolkit).
My Daily Therapy mobile App is registered with UK MHRA as a CE Class I medical device.
My Daily Therapy's Information Security Management System (ISMS) and Privacy Information Management System (PIMS) is certified for ISO 27001:2013 and 27701: 2019.

No method of electronic transmission or method of data storage is perfect or impenetrable. While we try our best to implement controls to protect your personal data, we cannot guarantee its absolute security. To ensure your data is secure, we require your cooperation as well. Please do not copy and share your conversations with unknown people.

How does the Artificial Intelligence chatbot work and is it safe to use?

At My Daily Therapy, we use proprietary Artificial Intelligence and Natural Language Processing/Understanding (NLP/NLU) algorithms (“AI”) to understand your messages. NLP/NLU algorithms are classification techniques that are used to understand what you write. This allows the AI to maintain a conversation with you and guide you to appropriate resources. Our values require that our AI used within the App is transparent, trusted, safe and privacy protecting. All the AI used in our Apps are “FIXED” or “CLOSED”, and all chatbot responses to the user are created with clinical input and subjected to detailed safety testing before being deployed. There are no generative (those that 'create' the response to the user on the fly) or adaptive models (i.e. those that continually adapt or learn every time on their own) in use. The algorithms run at conversational nodes within a decision-tree structure.

The primary purpose of the AI-based processing is

to provide an interactive safe-by-design approach to converse and journal via text with the chatbot.
to detect and retain limited context from your messages to personalize and provide empathetic and safe conversations.
to detect at-risk situations, such as any SOS, self-harm and abuse triggers, so as to signpost users to clinically validated supportive resources and helplines.

My Daily Therapy complies with UK NHS Digital’s DCB 0129 clinical risk management standards to ensure a safe-by-design approach to our AI-based services.

How long do we retain your data including personal data?

We have built proprietary algorithms that detect personal identifiers, that you may voluntarily submit in English during your conversation with TherapyBot. These detected identifiers get irreversibly removed within 24 hours within our system.

We may retain one copy of your data even after your subscription ends or Institution contract ends if it is reasonably necessary. This could be in any of the following situations:

to comply with applicable legal and statutory requirements;
at the request of a returning subscriber;
to respond to your requests
based on contractual obligations with your Institution;
in our backup for a time-bound period;
to fulfill processing that is in our legitimate interest.

Where not specified we retain your data for a maximum of 10 years since the last update and as per our internal information retention policies.

Your emergency contact information, if any provided, will be deleted after fifteen (15) days at the end of the My Daily Therapy emotional well-being professional subscription. If you renew the subscription within those fifteen (15) days, the emergency contact information will not be deleted.

You can also, at any point of time, delete all your conversation data and any emergency contact information provided by using the “reset my data” feature available in the App settings. Refer here in our policy for more details.

International transfer of personal data outside of the country you reside in or are currently located

You understand and agree that we may transfer, store and process your submitted data to a third-party processor. These processors may be based in countries other than the country where you reside. These could be countries where data protection laws may be less stringent than those from the originating country. We take additional steps in an effort to ensure our international transfer of data is consistent with applicable data protection laws.

Where we transfer data from the European Economic Area (EEA), Switzerland, and/or the United Kingdom we use appropriate safeguards. This includes use of EU / UK Standard Contractual Clauses and UK International Data Transfer Agreement (IDTA) within the Data Processing Agreements.

Minimal data may be transferred across My Daily Therapy company locations to provide our Services. We use appropriate technical and organizational measures to protect such transfers.

If you have additional questions about our international transfers of personal data, please contact us at Mydailytherapyapp@gmail.com.

What are your data protection rights?

You have certain rights under the Data Protection Laws in relation to your Personal data. To exercise any of your rights, you will need to send an email request to the contact information provided here. Please note that we may need to verify you before responding to any requests. After verifying you and examining your request, we will respond to you on the action taken within one calendar month from verification. We may at times be unable to address your request, if we are unable to correctly identify you.

Your individual rights requests may be limited, where:

denial of access is required or authorized by law;
grant of access would have a negative impact on other's privacy;
required to protect your, our or other’s rights property or safety;
the request is unjustified or excessive.

Right to be informed

This privacy policy explains and informs you about how we handle your data when you use our apps and services.

Right of access

You have the right to exercise a data access request to know what personal data we hold about you.

You have access to view your latest conversations or view your older conversation messages within the Journey tab of the App. You have access to your text-based messages with a My Daily Therapy emotional well-being professional in the TherapyBot tab of the App. If you exercise your right to delete and reset your data, you will lose the right to access your data as it will be permanently deleted in our system.

You can write to us at Mydailytherapyapp@gmail.com for any clarifications or make subject access requests. On receipt, we will review your request, make reasonable efforts to find and retrieve the requested information and respond to you within one month of your request.

Where Users have subscribed to a Service, you have the right to obtain your personal data that you provided as per our Agreement or where you consented to give us. After verifying, we will provide access to your personal data in a machine-readable format. We may at times be unable to address your request, if we are unable to correctly identify you or are limited due to one of the reasons mentioned earlier or any of the exemptions set out by the data protection laws.

Right to rectification

If your personal data is inaccurate or incomplete, you can write to us to correct or complete it. If we share your personal data with third parties, we will inform them about the correction where possible.

Right to restrict processing

You can write to us to restrict processing of your personal data, where you contest the accuracy of the data or object to our processing it. If we share your personal data with third parties, we will inform them about the restrictions where possible.

Right to object

You may write to us and object to the processing of your personal data where we apply our legitimate interest. We may stop unless we can demonstrate compelling legitimate grounds for the processing.

Right to data portability

If you are a paid subscriber of our services, you can place a request to transfer your data from your older device to your replaced mobile device. You can also request a copy of your messages to My Daily Therapy coach or therapist for your own purposes. If you are not a paid subscriber, we will need to accurately verify you, before we can process your request. We may at times be unable to address your request, if we are unable to correctly identify you.

Right to Erasure

When you use the service, you have the option to reset your data by using the “Reset my data” feature in the App settings. Reset my data deletes all your submitted data including your identifiers, past conversations, reminders, assessment responses and enabled settings. Post reset, you will not be able to recover your past data and you will be considered as a new user of the App. Hence, this feature is to be used at your discretion. If you are a paid subscriber, your transactional data and messages will be deleted on reset. However your active subscription, purchased through third parties like google play, iTunes, etc., will continue to exist post reset of data.

You can also write to us to delete or remove your personal data, such as when you withdraw your consent.

Right in relation to automated decision-making and profiling

You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, which may have a significant effect on your rights and freedom, unless such profiling is necessary for entering into, or the performance of our Agreement or with your explicit consent. You have a right to ask us to stop any automated decision making. We do not intentionally carry out such activities, but if you do have any questions or concerns, we would be happy to discuss them with you. You can contact us at MyDailyTherapyapp@gmail.com.

Right to non-discrimination

You have the right to not be discriminated against for exercising your CCPA (CPRA) rights or as required by other data protection laws. Use of our app and services is anonymous and hence We will never knowingly discriminate against you and your rights. You can also write to us for any clarification at MyDailyTherapyapp@gmail.com.

Right to opt-out of sale

You have the right to opt-out of the sale or restrict sharing of personal data with third-parties who intend to license or sell your personal data. For purposes of the CCPA (CPRA) and other applicable data protection laws, We do not sell any personal data, nor do we have actual knowledge of any sale of personal data of minors under the age of 16 years. You can also write to us for any clarification at MyDailyTherapyapp@gmail.com.

Confidentiality of Conversations

We understand the importance of privacy and confidentiality in mental health support. Conversations with our AI chatbot ("TherapyBot") are intended to be a safe space for self-expression and self-improvement. Your interactions with TherapyBot are treated with the utmost discretion and respect for your privacy.

However, it's essential to acknowledge that while we prioritize confidentiality, there may be circumstances where we are legally obligated to disclose certain information. These situations may include but are not limited to:

Legal Requirements: We may be required to disclose information in response to valid and enforceable legal requests, such as court orders, subpoenas, or government investigations.
Safety Concerns: If we become aware of any threat to your safety or the safety of others, we reserve the right to take necessary actions, which may include sharing relevant information with appropriate authorities or individuals.
Company Protection: We may retain and use data for the protection of our company's legal rights, including but not limited to defending against legal claims or complying with regulatory requirements.

While we strive to maintain the privacy and confidentiality of your interactions, we recommend that you refrain from sharing sensitive personal information in conversations with TherapyBot. My Daily Therapy cannot guarantee the complete confidentiality of any information shared.

Your trust is of paramount importance to us, and we are committed to protecting your privacy and complying with all applicable laws and regulations regarding data protection.

If you have any concerns or questions regarding the confidentiality of your conversations with TherapyBot, please do not hesitate to reach out to us at [insert contact information]. Your peace of mind is our priority.

Other important information

Withdraw Consent

To the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.

Breach notification

If the data breach is likely to result in a high risk of adversely affecting your rights and freedom, we will notify you as required by Data Protection Laws.

Concerns and Complaints

If you have any concerns or grievances about this Privacy Policy you will need to send an email to mydailytherapyapp@gmail.com with Attn. to the Data Protection Officer (DPO) and Grievance Officer. We will respond to you within 36 hours and help resolve your concerns or complaints. We assure you a time-bound resolution not exceeding one month from the date of your complaint.

If you are not satisfied with our resolution, you have the right to complain to a Data Protection supervisory authority in your country or state of residence. We will fully cooperate with the supervisory authority. You can raise a complaint with the UK ICO by following the process outlined here. Contact details for Data Protection Authorities in the EU are available here.

Do California residents have specific privacy rights?

There are certain disclosures required by the California Consumer Privacy Act (or “CCPA”) and California Privacy Rights Act (“CPRA”). This section supplements this Privacy Policy and applies to users who reside in the State of California.

Much of the Personal Information that We collect when you use our Services is not subject to the CCPA (CPRA). Personal Information for the purposes of the CCPA (CPRA) does not include protected health information (PHI or electronic PHI) that is subject to the HIPAA or medical information as defined in the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or publicly available information from government records. Personal Information also does not include de-identified or aggregated user data.

The following is the list of personal Information types which may have been collected from you within the twelve (12) months prior to the last updated date of this Privacy Policy.

Identifiers: such as android or apple identifier, nick name or any remaining identifiers voluntarily shared with us.
Conversation data: any residual identifiers remaining in your text messages post our adequate removal measures.
Communication data: such as name, email identifiers when you write to us.
Network data: such as IP address or information about your interactions with our website or Apps
Recruitment data: such as your current or past company name, dates of employment, and information that you may provide in a job application
Promotion event data: such as any email identifiers when you enrolled.
App Usage data: such as inferences and reports drawn from the above data types about you reflecting your preferences, characteristics, trends, or behavior
Safety Plan data: any inadvertent identifiers shared within the safety resources when you build or maintain a safety plan for your use in time of need
Institution or Subscriber provided data: identifiers (such as email identifiers, phone numbers) shared when you subscribe on behalf of your institution or group to our campaigns, promotions, product and services.
Business data: such as name, email identifiers and contact information shared and processed for lead generation, business development, account management and marketing.

We obtain the personal information types listed above from the following sources- when you use our App and Services, directly provided by you, as received from your Institution (where required), when you visit our website, from social networks where you participate, other third-party sources such as partners or recruiters. We will use your data for the processing purposes outlined in earlier sections of this Privacy Policy. We will not collect additional personal data types or use them for any materially different, unrelated, or incompatible purposes without providing you a privacy notice.

During the twelve (12) month period prior to the last updated date of this Privacy Policy, we may have shared your Personal Information with the following categories of third-parties- My Daily Therapy affiliates and subsidiaries, service providers under adequate data protection contracts.

Your data provided during use of the App will be retained as per our retention policy mentioned here.

Your data provided during the study will always be kept secure. Read more about our organizational and technical security safeguards here.

You can request a list of third parties with whom we share personal data for direct marketing purposes. Please note that My Daily Therapy does not share or sell your personal data with third parties as a matter of policy. Subject to certain exceptions, you can write to us to know about the personal information you shared and also exercise your data protection rights mentioned here. You can request to delete your personal information, to opt out of any “sales”, or to not be discriminated against by writing to us at Mydailytherpayapp@gmail.com.

We will respond to your request within 45 calendar days of verification. We may at times be unable to address your request, if we are unable to correctly identify you. We may be unable to address your request due to any of the limitations and exceptions provided within CCPA.

What are the controls for Do-Not-Track features?

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not respond to DNT signals transmitted by web browsers.

Can children under 13 use My Daily Therapy App?

The App is intended for a general audience and is not directed to or intended to be used by children under the age of thirteen years. My Daily Therapy does not take responsibility for any misrepresentation of age and use.

There is a special necessity to protect children's privacy on the App. We do not knowingly collect any personal data from children.

Write to us if you think we have collected any personal data of your child. We will respond to you within one calendar month from verification. We may at times be unable to address your request, if we are unable to correctly identify the user. We will deactivate the child’s account, if we find we have been collecting personal data from your child. Upon identification we will take reasonable measures to promptly delete such personal data from our records.

We encourage parents and legal guardians to monitor their children’s Internet usage. To help enforce our Privacy Policy by instructing their children to not provide any personal data without their permission. Do not share your credit/debit card or other payment instrument with your child to make any in-app purchase.

Why is Executive Function so Important?