Plus Guidance Privacy Policy
Plus Guidance Limited (“Plus Guidance”) knows that you care about how your personal information is used and shared and takes your privacy seriously.
Plus Guidance is a telehealth platform that we offer to connect clients with our network of affiliated mental health professionals (“Specialists”) to obtain online counselling and therapy services. “Specialists” includes employees, agents, or independent contractors of Specialists. “Plus Guidance” or the terms “we” or “us” or similar terms refer to Plus Guidance Limited “You” or “your” or similar terms refer to you as a user of our Platform (defined below).
THIS PRIVACY POLICY IS BOTH AN AGREEMENT HEREBY ENTERED INTO BY YOU AND PLUS GUIDANCE, AND THE POLICY OF PLUS GUIDANCE IN MAKING THE SERVICES AVAILABLE TO YOU.
1. Our Promise to You.
We know you are entrusting us with some of your most personal and valuable information, including your personal health information. Your trust is built, in part, on our commitment to respect the privacy and confidentiality of your health information. We are committed to safeguarding and protecting your personal information, including health information.
We are providing this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of the information that we collect and receive from users of our telehealth platform at and through our website, www.plus guidance.com (the “Platform”).
The Plus Guidance telehealth platform includes, without limitation, the following services (collectively, the “Platform”):
(a) the facilitation of electronic communications with Specialists,
(b) the provision of appointment scheduling and reminders and other services related to online counselling and therapy for both our registered users and Specialists, and
(c) the provision of other information about Plus Guidance and our products and services through the Platform.
This Privacy Policy applies only to information that you provide to us through the Platform.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service (the “Terms”).
By accepting our Privacy Policy during registration, or by visiting the Platform and/or using the Platform, you expressly consent to our collection, use, and disclosure of your Personal Information (as defined below) in accordance with this Privacy Policy.
As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including, without limitation, collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within our organization or among our affiliates or with Specialists within the United Kingdom or internationally.
2. Collection and Use of Information – In General.
We collect Personal Information in the form of an email address, for the purposes of creating a profile and for contacting you about your account. We collect information you provide voluntarily in free-form text boxes on the Platform and through responses to surveys, questionnaires and the like. If you communicate with us by, for example, email, facsimile or letter, any information provided in such communication may be collected as Personal Information.
The main reason we collect Personal Information from you is to provide you a safe, smooth, efficient, and customized user experience. The collection of Personal Information also enables our users to establish a user account and profile that can be used to interact with Specialists and other users through the Platform. We only collect Personal Information we consider important to achieve that goal. You always have the option not to provide some, or any, Personal Information.
You are under no obligation to provide us with this Personal Information. We use your Personal Information to provide the Platform and administer your inquiries. You may change some of the information that you provide. Please see “Changing or Deleting Your Information” below for further information.
3. How We Use Your Non-Medical Personal Information.
Some of the Personal Information we collect from you is unrelated to your receipt of counselling and therapy services through the Platform. Examples of how we may use your Personal Information include, but are not limited to, the following:
· Enable you to easily navigate the Platform
· Resolve service and billing problems via telephone or email
· Troubleshoot technical problems
· Bill any amounts due from you
· Better understand users’ needs and interests
· Personalize your experience
· Detect and protect us against error, fraud, and other criminal activity
· Enforce our Terms
· Provide you with system or administrative messages, and as otherwise described to you at the time of collection
· Provide you with further information and offers from us that we believe you may find useful or interesting
If you decide at any time that you no longer wish to receive certain communications from us, please follow the unsubscribe instructions provided in any of the communications or select the appropriate option in your user profile. (See “Changing or Deleting Your Information,” below.)
You cannot elect to unsubscribe some administrative communications, such as notification of new messages from your Specialists. To stop receiving these communications, you will need to deactivate your account.
4. How We Use Your Medical Personal Information (PHI).
We are dedicated to maintaining the privacy and integrity of your protected health information (“PHI”). PHI is information about you that may be used to identify you (such as your name or address), and that relates to (a) your past, present, or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care. In providing the Platform, we will receive and create records containing your PHI, and may use it to assist you in scheduling appointments, remind you of upcoming or follow-up appointments, inform you of cancelled appointments, bill amounts due for health care services provided by a Specialist under the Platform, develop and conduct surveys with you to assist in providing you better Platform, conduct our management and administrative activities, and otherwise as stated in this Privacy Policy. We may also use your de-identified PHI to run (or authorise third parties to run) statistical research on individual or aggregate health or medical trends. Such research would only use your PHI in an anonymous manner that cannot be tied directly back to you. We are required by law to maintain the privacy and confidentiality of your PHI, and we operate the Platform consistent with applicable laws governing health information privacy and security.
This Privacy Policy describes how we protect your privacy as a general user of the Platform, not as a client receiving mental health advice or consultation through the Platform from a Specialist. If you are a client receiving mental health advice or consultations through the Platform from a Specialist, you have other rights with respect to the access, use, and disclosure of PHI.
5. Log Data.
When you visit the Platform, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, or the webpage you were visiting before you came to our Platform, pages of our website and Platform that you visit, the time spent on those pages, information you search for on our Platform, access times and dates, and other statistics. We use this information to monitor and analyze use of the Platform and for the Platform’ technical administration, to increase our Platform’ functionality and user-friendliness, and to better tailor it to our visitors’ needs. For example, some of this information is collected so that when you visit the Platform again, it will recognize you and provide information appropriate to your interests. We also use this information to verify that visitors to the Platform meet the criteria required to process their requests.
Generally, our service automatically collects usage information, such as the numbers and frequency of visitors to our site and its components, similar to TV ratings that indicate how many people watched a particular show. Plus Guidance only uses these data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. These type of aggregate data enable us to figure out how often users use parts of the Platform so that we can improve the Platform.
6. Cookies.
We also use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we may utilize persistent cookies to save your user credentials for future logins to the Platform. Second, we may utilize session ID cookies to enable certain features of the Platform, to better understand how you interact with the Platform and to monitor aggregate usage by users of the Platform and web traffic routing on the Platform. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Platform and then close your browser. We may work with third parties that place or read cookies on your browser to improve your user experience.
You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Platform.
7. Web Beacons.
We may also occasionally use “web beacons” (also known as “clear gifs,” “web bugs,” “1-pixel gifs,” etc.) that allow us to collect non-personal information about your response to our email communications, and for other purposes. Web beacons are tiny images, placed on a Web page or e-mail, that can tell us if you have visited a particular area of the Platform. For example, if you have given us permission to send you emails, we may send you an email urging you to use a certain feature of the Platform. If you do respond to that email and use that feature, the web beacon will tell us that our email communication with you has been successful. We do not collect any PHI with a web beacon, and do not link web beacons with any PHI you have given us.
Because Web beacons are used in conjunction with persistent cookies (described above), if you set your browser to decline or deactivate cookies, Web beacons cannot function.
8. Emails.
We may use a third-party vendor to help us manage some of our email communications with you. While we may supply this vendor with email addresses of those we wish them to contact, your email address is never used for any purpose other than to communicate with you on our or your Specialist's behalf. When you click on a link in an email, you may temporarily be redirected through one of the vendor’s servers (although this process will be invisible to you) which will register that you have clicked on that link, and have visited our Platform. We also often receive a confirmation when you open an email from Plus Guidance if your computer supports this type of program. Plus Guidance uses this confirmation to help us make emails more useful to you.
Secure electronic messaging is always preferred to insecure email, but under specific circumstances, insecure email communication containing PHI may take place between you and Plus Guidance.
You should consider that standard email is not a secure means of communication. There is some risk that any PHI contained in email may be disclosed to, or intercepted, printed, or stored by, unauthorised third parties. Plus Guidance cannot ensure the security or confidentiality of messages sent by email.
Even if you have given us permission to send emails to you, you may revoke that permission at any time by following the “unsubscribe” information at the bottom of each such email.
9. Messages and Transactions.
Comments or questions sent to us using email or secure messaging forms will be shared with our staff who are most able to address your concerns. We will archive your messages once we have made our best effort to provide you with a complete and satisfactory response.
However, these communications will not become part of your medical record (or other appropriate treatment record) unless and until you use the Platform to obtain mental health advice or a consultation from a Specialist.
10. Information Sharing and Disclosure
We will not rent, sell, or share Personal Information about you with other people or non-affiliated companies except to provide the Platform, when we otherwise have your permission, or under the following circumstances:
· Specialists. When you use the Platform to access mental health services, you will be sharing your Personal Information with a Specialist via the Platform. By using the Platform, you expressly consent to sharing your Personal Information with your Specialist, and you understand that all information shared with your Specialist is subject to your Specialist’s professional and legal duties of confidentiality and responsibility, which Plus Guidance does not control. To increase coordination of care and reduce overhead for you, you authorise the sharing of this information with other Specialists on Plus Guidance who you elect to contact.
· User Profiles. User profile information, including your name, location, and other information you enter in your profile, may be displayed to your Specialists to facilitate user interaction with the Platform.
· Communications in Response to User Submissions. As part of the Platform, you may receive from Plus Guidance and other users email and other communications relating to your requests, mental health services, and other transactions. When you transmit information relating to your mental health services needs, Plus Guidance and the Specialists you select may send you emails and other communications that they determine in their sole discretion relate to your mental health services needs.
· Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose non-identifying Information and Log Data with third parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
· Service Providers. We may employ third-party companies and individuals to process your payments, facilitate our Platform, to provide the Platform on our behalf, to perform Platform-related services (including, without limitation, maintenance services, database management, web analytics and improvement of the Platform’s features), or to assist us in analyzing how our Platform is used. We do not store credit card details nor do we share customer details with any 3rd parties.
· Compliance with Laws and Law Enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Plus Guidance or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. This includes, without limitation, exchanging information with Specialists and law enforcement in response to Specialists’ professional and legal responsibilities.
PLEASE NOTE THAT ANY INFORMATION, TEXT AND IMAGES THAT YOU POST OR DISCLOSE ON OR THROUGH PUBLIC PORTIONS OF THE SITE, OR ANY OTHER PUBLIC FORUMS, BECOMES PUBLIC INFORMATION AND MAY BE AVAILABLE TO VISITORS TO THE PLATFORM AND/OR SEARCHABLE VIA THE INTERNET. Information regarding your activities in such Platform may also be available for view by other users (for example, other users may be able to view a list of all postings you have made in all available forums). We urge you to exercise discretion and caution when deciding to disclose your Personal Information through a forum or otherwise through the Platform. PLUS GUIDANCE IS NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH A FORUM OR OTHERWISE THROUGH THE PLATFORM.
11. Changing or Deleting Your Information.
You may review, update, correct or delete some portions of your Personal Information in your registration profile by making the appropriate modifications in your user account settings or by contacting us at info@plusguidance.com. Some Personal Information, such as your answers to online assessments, may not be updateable or deleted once submitted. If you delete certain information required to receive Platform then you may no longer be able to receive Platform and your account may be deactivated. If you would like us to remove your records from our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the records.
Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which, irrespective of any efforts by us to delete information, will not be removed from them. We also reserve the right, from time to time, to re-contact former users of the Platform.
Finally, we are not responsible for removing information from the databases of third parties with whom we have already shared Personal Information about you.
12. Security.
We employ administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorised access, use, and disclosure. Except for appointment reminders, treatment referrals and prescription information, these measures include encrypting your communications by utilizing Secure Sockets Layer (“SSL”) software, and using a secured messaging service when we send your Personal Information electronically. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable laws, including, without limitation, HIPAA. Except when you have requested us to send emails to you outside of the secure section of our Platform, all electronic PHI will be encrypted when we store it or transmit it, and we will use secure servers that we will back up regularly.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted electronically stored “personal information” (including but not limited to PHI or “medical information” (as defined in applicable state statutes on security breach notification)). To the extent permitted by applicable laws, we will make such disclosures to you via email or conspicuous posting on the Platform in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Platform by Internet or email, or any electronic storage system, cannot be guaranteed. As a result, although we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Platform or that is stored by us. You acknowledge and agree that any information you transmit through the Platform or upload for storage in connection with the Platform is so transmitted or stored at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem). In addition, if you have privacy or data security related questions, please feel free to contact the office identified at the end of this document.
13. Our Employees.
We have clear policies in place in the event of a privacy or security concern regarding your Personal Information, so we can react quickly and resolve the issue appropriately. We will limit access to your Personal Information to personnel who have a need to know it for purposes of delivering our Platform.
All of our personnel must comply with our restrictions on access, use, and disclosure of PHI or face disciplinary action, up to and including termination.
14. International Transfer.
Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United Kingdom and choose to provide information to us, we may transfer your Personal Information to the United Kingdom or European Union and process it there. Your submission of such information represents your agreement to that transfer.
15. Links to Other Sites.
We may offer you the opportunity to access third-party content, services, or products by linking to a third party’s website. If you choose to visit an advertiser by “clicking on” a third party link, you will be directed to that third party’s website. The fact that we may link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other services follow different rules regarding the use or disclosure of the Personal Information you submit to them. Our Privacy Policy only applies to the Platform and we are not responsible for the privacy practices or the content of other websites. You should check the privacy policies of those sites before providing your Personal Information to them.
16. Children.
The Platform is not directed to children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of the Platform. We do not knowingly collect personally identifiable information from children.
17. Agreement and Changes.
By using the Platform, you agree to the current Privacy Policy and our Terms, into which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to modify, discontinue, or terminate the Platform or to modify this Privacy Policy at any time. If we modify this Privacy Policy, we will notify you of such changes by posting them on the Platform or providing you with notice of the modification. We will also indicate when such terms are effective below. By continuing to access or use the Platform after we have posted a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Platform.
18. Contacting Us.
We encourage you to contact us at info@plusguidance.com if you have any questions concerning our Privacy Policy or if you have any questions or concerns about our access, use, or disclosure of your Personal Information. Please note that email communications will not necessarily be secure; accordingly, you should not include credit card information, PHI, or other sensitive information in your email correspondence with us. If you would like to contact us via physical mail, our mailing address is: Plus Guidance, Unit 407, Bon Marche Centre, 241-251 Ferndale Rd, London, SW9 8BJ
Last Revised: 1st October, 2014