Privacy Policy

About this document:

Privacy policies can be overwhelming. We aim to make ours easy to understand. If you have questions, email us at privacy@soulwhispers.online

“Data” includes information like your name, email, phone number, device ID, and communications with Therapists on our Platform. This may be considered “personal data” or “sensitive personal data” in some places. By using our app or website, you agree to our Terms and Conditions and Privacy Policy, including sharing data with Service Providers. We may update this Privacy Policy; whenever we make significant changes to this Policy, we will notify you through our website or app when you log in to your account. We encourage you to periodically review this page for the latest information.

What specific data we process?

The data we process depends on how you use our website, app, or Platform. We collect and process “Therapy Data,” which includes health and treatment information necessary for therapy. This data helps us operate the Platform and provide services. We may also use it to send you emails or texts, including marketing communications, which you can opt out of anytime. If you opt in, we may share some data with third parties for advertising. More details are available in the relevant sections of our Policy.

General Purposes and Use of Data Collection Processing

  • Personalizing your web or app experience
  • Communicating with you
  • Connecting you with therapy services
  • Facilitating therapy tools for you and your Therapist
  • Monitoring and improving therapy quality
  • Understanding and improving our services
  • Complying with laws
  • Protecting your safety
  • Sending promotions, updates, and reminders about our services and your account
  • Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features

The categories of data which we Process1 are listed below.

  1. Visitors’ Data

When you visit our website, app, or Platform, we process information such as pages visited, features used, time spent, errors, device and browser type, and IP address. If you opt in to Advertising, we may also process and share your IP address, hashed email, and other identifiers with third parties.

  1. Sign-up Data

To create an account on our Platform, users complete a questionnaire. Once a user creates an account with the Platform, we Process data such as the account name the user selects, and other demographic and contact information, such as email, age, phone number, emergency contact details, and whether a user verifies their email address.

  1. User ID

We assign each user (including Therapists) who create an account a sequentially-generated user ID. User IDs are unique to each account and are required in order to enable the Platform to function.

  1. Transaction Data

We Process data about payment transactions on the Platform such as whether a user completed payment for our services, signed up for services using a trial offer, canceled or ended a trial, received a discount or financial aid, or received any extensions or refunds. We also process whether a visitor has registered to create an account.

  1. Engagement Data

We Process usage data about how you interact with emails we send and different features when you’re logged into the platform. For emails we send, we collect usage data including whether you receive an email, open it, and click any links it contains. When you log onto the Platform, we also collect usage data about activity conducted during that logged in session such as when a user logs in, the login timing, number and length of messages received or sent through the Platform, received or sent message timing, number and duration of live session scheduled or conducted, the number and timing of use of other features such as worksheets, journals, and goals. This category does not include Therapy Data like the content of any messages sent or received by users, the content of any live sessions, or the content of journal entries, worksheets, or goals.

  1. Therapy Data

We Process written communications and related information users share with their Therapist to facilitate the therapy. This includes messages with Therapists, worksheets, and journal entries. Users may also choose to send audio messages which are automatically transcribed. We do not record the video or audio sessions with Therapists.

  1. Therapy Quality Data

We Process client feedback about their Therapist including, ratings and reviews of their Therapist, actions regarding switching Therapists or quitting therapy, and the reason selected by the client. We Process Therapist session availability, session cancellations and no-shows.

  1. Therapist Data

In order to engage with Therapists who express an interest in working with us (such as individuals who provide information at in-person or online recruitment events), follow up with Therapists who applied to work with us on the status of their applications, to identify, match, credential, re-credential, run checks, issue 1099s and pay Therapists, we process Therapist information such as the Therapist’s name, bank account information, gender, date of birth, governmental identification numbers (SSN/FEIN), e-mail address, phone number, address, NPI number (if applicable), license information, CAQH number (if applicable), and areas of interest/expertise, education, and job history. Therapists may also separately and outside of this Policy, consent to using facial scans to assist logging them in and verifying their identity.

  1. Therapist Engagement Data

For Therapists, we process such data as number/times of Therapist logins to the Platform, the number of live sessions conducted by a therapist, number of messages and words exchanged by a Therapist, number of worksheets shared by a Therapist, and number of journal entries shared with a Therapist.

  1. Clinical Health Record

We process your “Clinical Health Record,” which contains essential information for your therapist to identify you and document the services you receive. This record includes:

  • Onboarding data: Questionnaire answers
  • Account data: Account name, phone number (if provided), email address, emergency contact details
  • Therapy data: Dates of service, messages with your therapist, shared worksheets and journal entries, therapist’s internal notes.
  1. Customer Service & Communication Data

We Process communications users have with our Customer Service team to smoothly communicating with you.

  1. Location Data

We process your IP address to determine your general location, allowing us to personalize the platform for you. For example, we show relevant information based on your country. We also use this location data to enhance your experience, such as auto-filling your state and country during the onboarding questionnaire.

  1. We do not request or process exact location data like GPS information from your phone.
  2. We process your address when you provide it as part of your emergency contact information. This is required to comply with therapy regulations and can be used if your therapist believes you are in immediate danger. We may use your general location to offer autocomplete suggestions for your convenience.

Use of Artificial Intelligence (AI)

Artificial Intelligence (AI) is used to enhance our services and improve quality and to help diagnose issues and match you with the best possible therapists, ensuring you receive the most suitable care. These improvements aim to enhance the experience for both Members and Therapists. To ensure fairness and accuracy, and to protect privacy, we thoroughly review or internally build our models. We do not use Therapy Data, like session data, journal entries, messages, or worksheets, to train AI or NLU models.
Our data processing includes both automated and manual methods. Automated processing helps complete repetitive tasks more efficiently, such as detecting security risks, synthesizing information for customer service, and assisting therapists in managing sessions.

Purpose of Data Sharing

  • Legal Compliance: We may share your data to comply with laws, such as responding to court subpoenas. This applies to both online and in-person therapy. Generally, your therapist decides whether to produce any psychotherapy notes or messages. Discuss any concerns about disclosure obligations with your therapist early on.
  • Support Services: Occasionally, a select number of employees from our parent company may handle your data for support services. These employees are bound by strict confidentiality. For example, a paralegal may receive subpoenas or legal correspondence on behalf of members and ensure they reach Soul Whisper’s Legal team.
  • Service Providers: We may share data with service providers that help us operate the Platform. Examples include:
    • Data Hosting and Storage: Cloud hosting providers like Amazon Web Services (AWS).
    • Technology Services: Tools integrated into our Platform for added functionality, such as live audio, video, and group meetings.
    • Customer Service: Tools to securely track requests and questions from members, visitors, and therapists.
    • Email Management and Communication: Tools that facilitate easier and more convenient communication with you.
  • Billing and Payment Processing: We use Stripe to securely process payments and assist in paying therapists and issuing tax documents. This may involve sharing therapists’ email addresses, names, and tax IDs with Stripe.
  • Reporting and Analytics: We use services to track which pages and features are most used on our site.
  • Advisors and Lawyers: To assist with business matters.
  • Safety and Security: We may share data with service providers to ensure the safety and security of the Platform and its users.
  • Therapist Recruitment: If you’re a therapist on our Platform or being recruited, we may share data with therapist recruiters to facilitate and track the recruitment process.
  • Employer or Organization Services: For members receiving services through an employer, organization, or business partner, we may share group-level usage data that cannot be directly linked to you. If you receive services through an Employee Assistance Program (EAP), your EAP will notify you of any individual-level data shared, provided you have given consent. For questions about data use by your EAP, please contact them directly.
  • Business Transactions: We may share data in connection with an asset sale, merger, or bankruptcy.
  • Public Information: Any information you make publicly available on the Platform, such as public posts, can be seen and used by anyone.
  • Analytics: If you opt in to “Analytics” (previously “Performance cookies”), we may use analytics cookies from trusted service providers to process data for activities like analyzing traffic sources, visits, and site interactions. This helps us improve our products and services.

Selling of data.

  • No Payment for Data: We don’t receive payment for any data. However, California law defines “sale” broadly to include sharing personal information for anything of value. If you opt in to Advertising cookies and web beacons, this may be considered a “sale” under California law.
  • Advertising Data Sharing: If you opt in to Advertising cookies and web beacons, some Visitor Data (excluding activity when logged in and receiving therapy) may be shared for advertising purposes. Consequently, you might see ads for our services on third-party websites.
  • App Tracking: If you use the app and allow tracking on iOS or opt into Advertising Cookies on Android, data like your mobile device identifier (IDFA and IDFV for iOS, and Android Advertising ID for Android) and app usage data collected by Google (via GA4) will be used to enhance our Google advertising. This is enabled through an integration between GA4 and Google Ads. To opt out, Android users can go to “Sharing Settings” in the app, and iOS users can select “Ask App Not to Track” when downloading the app or adjust privacy settings later. Even if you opt in, we do not engage in retargeting advertising, which involves showing ads based on your previous actions on our site.
  • Data Privacy: We do not share any data or information you share with your therapist with any third-party advertisers.