Privacy Policy

1. About Your Privacy and This Privacy Policy

This document is our “Privacy Policy”, and it contains details on issues related to your privacy when using our services. This Privacy Policy applies to visitors to the public websites owned and operated by WellBe, https://wellbe.club/ (the “Platform”), and to the Counselors that provide the Counselor Services (“Counselors”). It is intended to inform you of our policies, procedures, and practices regarding the collection, use and disclosure of any information that you provide through the Platform.
The Privacy Policy does not apply to the collection and use of certain employment-related information for employees of WellBe.

The Privacy Policy is part of our Terms and Conditions. The terms in the Privacy Policy (such as, but not limited to, “We”, “Our”, “Us”, “Platform”, and “Counselor Services”) have the same meaning as in our Terms and Conditions document. When you use our Platform, you accept and agree to both the Terms and Conditions and to the Privacy Policy. By accessing and using our Platform or providing the Counselor Services, as applicable, you affirm that you have read the Terms and Conditions and the Privacy Policy and that you understand, agree to and acknowledge all the terms contained in both of them.

2. Definitions

For the purposes of this Privacy Policy:

  1. Account means a unique account created for you to access our Service or parts of our Service;
  2. Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy) refers to WellBe;
  3. Cookies are small files that are placed on your computer, mobile device or any other device by a website, that contain the details of your browsing history on that website, among its other uses;
  4. Device means any device that can access the Service (as defined) such as a computer, a cell phone or a digital tablet or similar device;
  5. Information refers to all the information shared by you, directly or indirectly including but not limited to, during the course of the use of our platform, provided that, such information does not constitute information shared during the course of availing our services including but not limited to Counselor notes, suggested treatments, chats, sessions and other information that is deemed as personal and confidential
  6. Personal Data relates to information that identifies an individual, or makes an individual identifiable;
  7. Platform refers to this Website

3. Interpretation

Save where the context otherwise requires in this Policy:

(i) Words importing the singular include the plural and vice versa where the context so requires;

(ii) References to any law shall include such law as from time to time enacted, amended, supplemented or re-enacted;

(iii) References to the words “include” or “including” shall be construed without limitation; headings and titles in this Policy are indicative and shall not be deemed part thereof or be taken into consideration in the interpretation or construction of this Policy.

4. Information Collection, Use, and Disclosure

4.1 Categories of Information Collected

To let us operate the Platform effectively and to let you use the Platform, including the Counselor Services, we may collect, use, and store the information described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Platform. The data we collect is not used for marketing or any other purposes except as specified in this Policy.

  1. Visitor Data: WellBe collects, uses, and stores data regarding user visits to its website (“Visitor Data”), including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to WellBe’s FAQ page, and information about the browser or device used to access the website, such as the user’s mobile device ID and IP address. These practices apply to users who visit pages for prospective new customers as well as those who visit pages for prospective Counselors.
  2. Onboarding Data: In addition to the questionnaire responses provided by users (including Counselors) in the process of initial registration, WellBe collects, uses, and stores certain additional data from users during the onboarding process (“Onboarding Data”). This data includes the pages viewed by the user, whether the user clicks the “Get started” link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.
  3. Account Registration Data: WellBe collects, uses, and stores certain information in connection with the account registration process, such as whether users registered using their Facebook or Google profiles, and whether a user verifies their reported email address or phone number (“Account Registration Data”). WellBe also assigns each user (including Counselors) who creates a WellBe account an anonymized, sequentially-generated client ID.
  4. Transaction Data: WellBe collects, uses, and stores certain information regarding payment for its services by users and related transactions on its website, such as whether a user completed payment for WellBe’s services, completed a request to receive financial aid for WellBe’s services, etc. (“Transaction Data”).
  5. Counselling Session Data: WellBe collects, uses, and stores certain general data regarding user counselling sessions such as whether a session has been scheduled by the user, whether a Counselor or user joins a scheduled session, when a counselling session began and ended, and whether a counselling session was cancelled or re-scheduled.
  6. Customer Data: WellBe collects, uses, and stores certain data from users that have signed up for its services such as a user’s self-reported name or nickname, age, e-mail address, phone number, and emergency contact information (“Customer Data”).
  7. Counselor Data: In order to identify, credential, re-credential, run checks, and pay Counselors, WellBe collects, uses, and stores certain data from Counselors. This data includes information such as the Counselor’s name, bank account information, governmental identification numbers, e-mail address, phone number, address, and education and job history (“Counselor Data”).
  8. Communications Data: WellBe collects, uses, and stores communications between users and Counselors on the Platform, and communications between users and WellBe’s customer service team (“Communications Data”).This data is inclusive of but not limited to any communication in an electronic, oral form between users and Counselors such as Whatsapp chats, calls, emails, short message services such as(SMS) etc.

Protecting this information is important to us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless requested by you or you approved us to do so.

4.2 Purposes for Which Information Is Used

We may use the information we collect for one or more of the following purposes:

4.2.1 Communication with you

  1. To create your account on our Platform and let you log in to your account and use the Platform;
  2. To manage your account, provide you with customer support, and ensure you are receiving quality service;
  3. For billing and transaction processing purposes;
  4. To match users with Counselors and facilitate the Counselling Services;
  5. To match users with Counselors and facilitate the Counselling Services;

4.2.3 Administration and improvement of services

  1. To supervise, administer and monitor the Platform;
  2. To measure and improve the quality, effectiveness, and delivery of our services.

4.2.4 Customization

  1. To personalize the website experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads.

4.2.5 Compliance with law

  1. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  2. To comply with applicable laws, including, but not limited to laws related to protecting client and public health and safety;
  3. To allow Therapists to comply with the licensure, legal and quality requirements in their jurisdictions.

4.2.6 Other uses with consent

  1. Any other purpose with your consent.

4.3 Purposes for Which Information Is Disclosed to Third Parties

Information about you may be disclosed to third parties for one or more of the following purposes:

  1. For business purposes: We may share a user’s information with a Counselor and a Counselor’s information with a user. We may also share your information with vendors and service providers, including our data hosting and data storage partners, analytics and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms. We do not share information related to your ongoing Therapy services with us, including but not limited toCounselor notes, sessions etc. unless required by applicable law.
  2. With your direction or consent: We may share your information with third parties if you request or direct us to do so after signing an authorization form in that regard..
  3. With affiliates within our corporate group: We may share your information with any subsidiaries or parent companies within our corporate group. Our affiliates will be required to also honor this Privacy Policy.
  4. For advertising: If you opt-in to the use of targeting cookies and web beacons, information regarding your activity on our websites, excluding activity when you are logged in and have started Therapy, may be disclosed to our advertising partners to optimize marketing. We do not share with any advertising platform private information like member names, email addresses, phone numbers, diagnosis, session’s data, journal entries, messages, worksheets, or any other type of communication you have with your therapist. If you want to opt-out of these cookies and web beacons, manage your options here.
  5. Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a court order, to comply with applicable laws or any obligations thereunder.
  6. In the context of a transaction: We may share your information in connection with an asset sale, merger, bankruptcy, or other business transaction.
  7. For other business reasons: We may share your information to enforce any applicable Terms and Conditions and Terms of Use, and to ensure the safety and security of the Platform and our users.

Note that if you make any information publicly available on the Platform, anyone may see and use such information.

5. Cookies and Web Beacons

Like many websites, we use “cookies” and “web beacons” (also known as pixels) to collect information. We collect cookies that are necessary for the Platform to function, cookies that enhance the Platform’s performance, and cookies used for third-party tracking. Web beacons are typically used by third parties to monitor the activity of users at a website for the purpose of web analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.

5.1. You can change your browser’s settings so it will stop accepting cookies and web beacons or to prompt you before accepting a cookie or web beacon. Opt-out options for cookies and web beacons are located here.Use of Cookies, Web Beacons, and Similar Technology for Analytics

We may use third party cookies or web beacons for the purposes of web analytics, attribution, and error management. Our Platform may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, and your response as to the referral source to the Platform.

Our Platform also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our websites for purposes of analytics and analysis of certain Platform usage.For more information about the cookies we use and your choice regarding cookies, please visit our Cookies policy.

5.2. Use of Cookies, Web Beacons, and Similar Technology for Advertising Networks

If you opt in to the use of targeting cookies and web beacons, you and others may see certain ads for our services or for the Platform on other websites because we participate in ad networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track individuals’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show advertisements that may be tailored to an individual’s interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant ad networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and assists other websites and advertising partners to find you or people like you on different platforms, including social media websites. As mentioned above, you can opt-out of cookies and web beacons by visiting this link here.

6. Social and General Information Tools

We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, and others (collectively “Social and General Information Tools”). Any information you provide or share while using Social and General Information Tools may be read, accessed, and collected by that site and users of that site according to their Privacy Policy.

7. Phishing

Online identity theft and account hacking, including the practice currently known as “phishing”, are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

  1. Links

The Platform may contain links to other websites, services, or offers that are owned, operated, or maintained by third parties. If you click on a third-party link, you will be directed to that third website or service. The fact that we link to a website or service 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 have control over third-party websites and services, and we do not have control over their privacy policies and terms of use.

  1. Security of Information

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built, and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable laws and regulations regarding data privacy.

  1. Service Providers

We may employ third-party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational, or other services for us. These tasks include, but are not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.

  1. Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 3 without the written consent of their parent or legal guardian.

  1. Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal processes (including but not limited to court orders), and to prevent or stop activity that may be illegal or dangerous. Counselors may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.

  1. Changes to the Privacy Policy

We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the beginning of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using the Platform.

  1. Contacting us

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by clicking the “Contact” link on any page in our website.