- What personal data we collect through your use of the App and its content and tools (collectively, the “Services”)
- How we use the data
- With whom we may share the personal data
- Legal basis for processing the data
- Storage and security of your data
- Your Privacy Rights, Choices and Disclosures, including those for Europe and California
- Users outside the United States
Personal Data We Collect or Process
We collect information that you provide to us voluntarily if you choose to register with the App, although you do not need to set up an account to use the App. To create an account, we collect first and last name (or an alias) and an email address, and you will be asked to create a username and password. You may also upload a profile picture. Please note that the profile picture and your name or alias will be able to be viewed by other users in the App. You may change your information in your account profile at any time.
The App collects information, on a voluntary basis, on how users are feeling (and areas of struggle) (collectively, “Mood Data”). The App uses a color spectrum to match moods or feelings with causes. Users may submit notes to augment their selections. This data may be kept private or shared with the App’s user community.
Users may save content available on the App and also keep a journal through the App to track their moods and activity.
The App permits users to interact with an artificially intelligent mental health facilitator (“bot”) to discuss mental health issues.
Users in North America may also use the App to dial a suicide prevention hotline.
We also collect some information automatically utilizing background local storage and session storage technologies to authenticate you as a user and in order to improve the user experience, such as remembering your saved content. We use Google Analytics, a web analytics service, to analyze your use of the Services, compile reports on activity for us, and perform further services associated with use of the Services. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. You can deactivate Google Analytics using an if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.
We do not knowingly collect information from users of our Site under the age of 18 and/or their internet usage, and such persons are not authorized to use the Services. By using the Services, you represent that you are at least 18 years old.
How We Use the Data
We use the personal data we collect to provide or enhance the Services you request, provide updates and other important information related to your activity on and with the Services, inform you of new services or changes in Services, administer the Services, to fulfill legal obligations we have to governmental authorities or other third parties, and for other legitimate business purposes.
The App uses the Mood Data of users in order to cater content to their needs, to allow the users to track their moods, and, should the users wish, find others in the community who share similar feelings and/or struggles. We use push notifications to re-engage with our users in an effort to support their mental health.
The App may aggregate user data, including Mood Data, in order to better understand the groups of the App’s users, for example, based on region or common symptoms.
With Whom We Share Personal Data
The App and the Services are administered from the United States. We may share your personal data to third parties (within or outside your country of residence) who perform services on our behalf, including without limitation, our technology providers and professional advisors.
We have relationships with third parties. We may provide them some personal information such as your name and email so that they may contact you about products or promotions you may be interested in.
We may disclose any information we have about you (including your identity) if we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Services, or to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) the Foundation’s rights or property, or the rights or property of users of the Services. We reserve the right at all times to disclose any information that we deem necessary to comply with any applicable law, regulation, legal process or governmental request. We may disclose your information when we determine that applicable law requires or permits such disclosure, including exchanging information with other companies and organizations for fraud protection purposes.
Your information may be transferred to another company (within or outside your country of residence) in connection with a merger or in the event that our business is acquired in whole or part by another company.
We may share aggregated and de-identified information with third parties (within or outside your country of residence) for analytical, research or other similar purposes.
Grounds for Using Your Personal Data
We rely on the following legal grounds to process your personal information:
Performance of our Services. We may need to collect and use your personal information to perform Services that you request.
Compliance with Legal Obligations. We may use your personal information as necessary to comply with our legal obligations.
Storage and Protection of Your Personal Data
We retain the personal data we collect for so long as reasonably necessary for the purposes for which it was collected and to comply with our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store email addresses and account information until the user requests to be removed or the users remove themselves through any self-service tools offered to the user in the App.
We take reasonable administrative, physical and technical precautions to protect your personal data and communications between us. This includes, when required or as we deem appropriate and feasible under the circumstances, encryption and written commitments from third parties that may have access to your data that they will protect the data with safeguards that are substantially equivalent to those used by us.
No Internet or e-mail transmission is ever fully secure or error free, however. We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control. Users assume the risk of security breaches and the consequences resulting from them. Please be careful in deciding what information you send to us via email or over the Internet.
Your Rights, Choices and Disclosures
1. General. This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at firstname.lastname@example.org or make changes to any user profile information connected to your account.
You may opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication or contacting us at email@example.com. Some non-marketing communications may not be subject to a general opt-out, such as communications about transactions, disclosures to comply with legal requirements, software updates and other support-related information. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
2. Your European Privacy Rights and Choices. If you reside or otherwise find yourself in the territory of Europe, your privacy rights under the European data protection laws include:
- Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
- Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal, ethical and contractual obligations.
- Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
- Right to object at any time. You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal, ethical and contractual obligations. Some non-marketing communications are not subject to a general opt-out, such as communications about transactions and disclosures to comply with legal requirements.
- Right to data portability. You have the right to data portability of your own personal data by contacting us.
- Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.
- Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
3. California Disclosures
California “Shine the Light” Information-Sharing Disclosure: California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to firstname.lastname@example.org with “California Shine The Light Rights” in the subject line.
California Do Not Track Disclosure: The App is an installed mobile application and not a website delivered in browser.
California Consumer Privacy Act. The Chopra Foundation is a not-for-profit entity and therefore not a business subject to the California Consumer Privacy Act.
Users Outside the United States
The App and Services are controlled and operated from the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities. Personal data may also be transferred from the country of your residence to other countries, including the United States.
The App’s ability to place a call to a suicide prevention hotline is available only to users in North America.
Links to Content and Other Sites
Questions and Contact Information
The Chopra Foundation is located at:
1224 Prospect Street, #120
La Jolla, CA 92037