WHO WE ARE: 

Our website address is https://thewiny.co and it’s subdomains/directories/files.

Winy Privacy Policy 

Effective Date: September 21, 2020 

Winy (“Winy,” “thewiny,” “we,” “us” and “our”) provides virtual mental health care services aimed to increase access to emotional and social support and to practice early detection of mental health symptoms. We make your data more confidential. We here at Winy allow total privacy to all of our users and we have taken several steps to do the same and make your data more personal and confidential.

This privacy policy (“Privacy Policy”) describes how we collect, use,  disclose and store Personal Information provided by the users through the website and mobile application tools that provide the services described above (collectively, the “Services”). Please review this Privacy Policy carefully and in its entirety. If you have questions about this Privacy Policy,  you can contact us at info@thewiny.co

This Privacy Policy describes: 

The Personal Information we collect when you interact with the Services; How we use and process the Personal Information that we collect; How we may share Personal Information with third parties; and The security of your Personal Information. 

Acceptance of the Privacy Policy 

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you submit your Personal Information to or through the Services, you consent to the collection and processing of your Personal Information as described in this Privacy Policy. By using the Services, you accept the terms of this  Privacy Policy and our Terms of Use.

Effective Date and Changes to Privacy Policy 

The Effective Date of this Privacy Policy is set forth at the top or end of this  Privacy Policy. We may update this Privacy Policy from time to time at our discretion and when required by law, we will notify you of changes to this  Privacy Policy. Material changes will be posted to this page and will be emailed to registered users. Your continued use of the Services after the  Effective Date constitutes your acceptance of the amended Privacy Policy.  The amended Privacy Policy supersedes all previous versions. 

Personal Information We Require 

We require certain Personal Information to allow access to our Services to you. “Personal Information” may include contact information such as your first name, last name, email address, location, phone number, certain demographic information such as age, gender, race-ethnicity, the primary language is spoken, sexual orientation, disabilities, and veteran status, also we would require information about your health and medical history that you may input while using or communicating through the Services, and information about how you interact with and use your device. Personal  Information that has been anonymized is not Personal Information as it does not allow for a specific individual to be identified. 

Winy reserves the right to remove or edit any content on our public forum that we believe may be offensive to our audience and/or which violates our family-oriented standards.

Listening and Therapy Chat Transcripts

While we generally do not monitor transcripts of chats between users and Listeners and Therapists,  we may occasionally review the chat transcripts to conduct quality control,  address potential safety issues, and prevent misuse of our platform, if any certain suspicious or potentially harmful activity is detected. We may also use aggregated data from chat transcripts to conduct research and development. In reviewing this information, Winy will maintain all applicable confidentiality/privacy standards.

Without providing your Personal Information you may not access Services through Winy, contact, or correspond with us, other users, therapists, or other health care providers via the Services, or utilize the therapy exercises and programs available on the Services. 

Account Setup

When you sign up for an account with us, we may ask for and collect Personal Information such as your name, a valid email address,  phone number, birth date/age, address, care taker’s name, and contact. We need this information to provide you with the Services. 

Surveys

From time to time we may collect Personal Information from users via surveys. This information is used to improve the content of our web pages, the quality of our Services. 

Log Data 

When you use our Services, we store, process, and transmit your information about how you use our Services to engage, educate, and suggest behavioral activation strategies to you. 

Paid Services

If you purchase paid services, such as therapy or other upgrades, Personal Information such as billing name, UPI, Paypal address, address, and credit/debit card payment information will be collected to process payment. 

Counselor and Therapist Applicants

If a visitor wishes to apply to be a  Counselor or Therapist on Winy’ App/portal, the visitor will be required to submit Personal Information as requested. Any Personal  Information supplied by or on behalf of a visitor for purposes of becoming a Counselor or Therapist will be maintained by Winy. Please note that Winy may have additional privacy terms that apply to Counselors or Therapists.  Such terms will be made available when an applicant applies to be a  Counselor or Therapist or otherwise accesses his or her account. 

Public Forums, Chats, Health Updates, Feedbacks, or Other Features

Depending on how you interact with the Services, you may share your Personal Information with other Users, such as peers and other users who participate in a chat, forums, or other non-private locations. Anything users post in the public forums,  chats, or other features will be accessible to other users and may not be able to be deleted. Accordingly, Winy strongly discourages posting any  Personal Information in these places and it is your responsibility not to share Personal Information in such a non-private location.

Mental Health Services

We collect your Personal Information when you access mental health services through our Services when you contact or correspond with us, therapists, or other health care providers via the  Services, or when you utilize the therapy exercises and programs available on the Services. 

Technical Support Requests

If you need technical support related to  Winy’ Services, you may need to complete a form/email to define and clarify your technical support request. When submitting a  technical support request, you will be asked to provide Personal  Information, including an email address/contact and a description of the issue.  When you contact us, we keep a record of the email and chat communications to address and resolve any issues you are facing. 

Assessments or Other Tests

Periodically, Winy will offer the opportunity to assess your emotional wellness based on questionnaires where you will be asked to provide Personal Information. It is your choice to participate in these assessments; not participating will not prevent you from participating in any other aspect of the Services offered. 

Users can request a download of their Personal Information that Winy currently stores, and also request deletion of their account and associated  Personal Information. We reserve the right to prevent a User from exercising such rights in certain circumstances, as permitted by law. For example, if the user in question has broken the terms laid out in the  Terms, caused harm or has abused our Services, or has negatively impacted other members. In this case, we retain the right to keep some of your  Personal Information to provide more security and safety to our members.

Requests for Information, News, and Other Content

You may sign up to receive information, news, and other content related to new and existing products and services related to Winy’ Sites, Winy’ Listening Platform and events, and other information related to Winy that may be of interest to you. When signing up to receive such information, you will be asked to provide Personal Information, including your name, email address,  address, and phone number.

Browser Information and Cookies

We use browser information (e.g., IP  addresses and browser types), cookies, and pixel tags to determine what data or information should be shown on your browser when you are visiting Winy’ Site or using Winy’ App/Portal. We may also use browser information, cookies, and pixel tags: to determine how you arrived at Winy’ Site or Listening Platform, to determine whether you are a return visitor, to help us improve our product and service offerings, for quality assurance and training purposes, to help diagnose problems with our servers, to gather broad demographic information, to administer and optimize our services, and for other lawful purposes. Please refer to the  “Cookies” section below for more information. 

Cookies and other tracking technologies 

Cookies are small files, typically of letters and numbers, downloaded onto your computer or mobile device when you visit certain websites. 

How We Use Cookies. 

Generally, we use first-party and third-party cookies for the following  purposes: 

  1. To make our Services function properly; 
  2. To provide a secure browsing experience during your use of our  Services; 
  3. To collect passive information about your use of our Services;
  4. To help us improve our Services; and 
  5. To remember your preferences for your convenience. 

Types of Cookies on Our Services. We use the following types of  cookies on our Services: 

  1. Strictly Necessary Cookies. These cookies are essential because they enable you to move around and use our Services. For example,  strictly necessary cookies allow you to access secure areas on our  Services. Without these cookies, some services cannot be provided.  These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled. 
  2. Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services. 
  3. The performance or Analytic Cookies. These cookies collect anonymous passive information about how you use our Services,  including web-pages you visit and links you click. We use the information collected by such cookies to improve and optimize our  Services. We do not use these cookies to target you with online marketing. You can disable these cookies. 
  4. Third-Party Cookies. These are cookies that are provided by third-party service providers and belong in one of the cookie categories described above. These third-party providers process your Personal 

Information on our behalf is according to our instructions and obligations consistent with this Privacy Policy. 

How to Manage Cookies

Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps: 

  1. First-Party Cookies. You can enable, disable, or delete our cookies through the browser you are using to access our Services. To do this,  follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our Services, and/or parts of the Services may not work properly for you. You can find more information about how to change your browser cookie settings at  http://www.allaboutcookies.org.
  2. Third-Party Cookies. Modern browsers also allow you to block third-party cookies using the steps described above. 
  3. Pixel Tags. We also use pixel tags throughout or Services. Pixel Tags are small graphic images that are embedded in a web page or email for purposes of tracking activity on web pages or whether a user has opened or accessed an email. A pixel tag may be set to identify on what browser and computer it was viewed, whether that browser has cookies received from a server associated with the pixel tag, and whether the web page or email with the pixel tag was forwarded or copied.

Why we require your Personal Information 

We may use Personal Information that we collect about you for various  purposes, including: 

  1. To operate, provide and improve our Services; 
  2. To communicate with you regarding our Services, and promotions; 3. To ensure network and information security; 
  3. To provide customer support and respond to your inquiries; and 
  4. To protect you, us, and other users. 

Personal Information We Share 

We may share and disclose Personal Information as follows: 

Welfare Assurance. We may disclose your Personal Information directly to law enforcement or local authorities if it has been reasonably determined that your safety or the safety of others may be at risk. 

Business Transfer. In the event of a merger, reorganization,  consolidation, restructuring, bankruptcy, sale of substantially all interests or assets, or other similar transaction, we may transfer your Personal  Information to the subsequent owner or operator of the Services. 

Third-Party Service Providers Performing Services on Our Behalf. We share Personal Information, with certain third-party service providers that assist us in providing the Services and which are bound by duties of confidentiality. For example, we may use third parties to host the Services, send out email updates about the Services, administrative services,  financial services, quality assurance, data aggregation or remove repetitive information from our user lists.

Counselors/Therapists. If you elect to consult with a counselor/therapist through Winy,  we may share your information with your counselor/therapist to enable and facilitate care. Adults who are in therapy provide Personal  Information that will only be disclosed to the counselor/therapist if they or someone else is in imminent danger. 

For Legal Purposes. We will disclose your Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a  data protection agency, legal process, governmental request, or another legal or regulatory process. We may also share your Personal Information as required to pursue available remedies or limit damages we may sustain. 

Healthcare Providers. If you have been referred to the Services as part of a care plan by your healthcare provider, we may share your Personal  Information with your healthcare provider to facilitate care. 

Anonymized Data. We may de-identify your Personal Information, in compliance with applicable law and aggregate such de-identified data with the de-identified data of other users. Such anonymized, aggregated data is no longer considered Personal Information. We may then share such anonymized aggregated data with the sponsors of programs that facilitate your access to the Services, such as government health agencies,  researchers, or healthcare providers. At Winy, we believe that global mental health is a collaborative effort. The sharing of anonymized data plays a key role in helping both Winy users and people worldwide to understand and better their mental health while maintaining a high level of privacy and anonymity to individuals. 

Security of your Personal Information 

We employ reasonable security measures designed to protect the security of information submitted through the Services. However, the security of information transmitted through the Internet can never be guaranteed. To protect you and your Personal Information we may suspend your use of the Services, without notice, pending an investigation, if any breach of security is suspected.

Your Responsibilities. Users of the Services are responsible for maintaining the security of any password, user ID, or other forms of authentication involved in obtaining access to password protected or secure areas of any of the Services. 

Unauthorized Access. Access to and use of password protected and/or secure areas of the Services are restricted to authorized users only.  Unauthorized access to such areas or information is prohibited. 

Encryption and Firewalls. All information, including but not limited to chat transcripts and personal information is encrypted during transmission.  We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All information received is maintained on secure servers in an encrypted format. Access to stored information is protected by multi-layered security controls including firewalls, encryption,  role-based access controls, and passwords. 

Retention Period 

Generally, we will retain your Personal Information for as long as your account or profile is active, or for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Private messages are stored for up to one year. Posts in community forums (including subcommunities) are maintained on community forums at the discretion of Community admins.  Winy will store your user account and associated Personal Information if your account is active. After a period of inactivity greater than 1 calendar year, Winy may, at its discretion, purge Personal Information related to inactive accounts.

Links to other sites 

The Services may contain links and widgets related to third-party websites and services (“Third Party Services”) with which we have no affiliation. A  link to any Third Party Services does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit any  Third Party Services, you are subject to its privacy policy and practices and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit. Users are prohibited from requesting offsite contact with other users. If a user is detected initiating offsite contact, Winy reserves the right to immediately terminate that account. 

Non-Discrimination 

Winy does not and shall not discriminate based on race, color,  religion (creed), gender, gender expression, age, national origin (ancestry),  disability, marital status, sexual orientation, or military status, in any of its activities or operations. 

Children’s Data 

Winy Site, Portal/app, and Services specify that users must be at least 18 years old. Children between the ages of 13-17 years old may only participate in our Services with parental consent. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent,  he or she should contact us at info@thewiny.co. If we become aware that a child under 18 (or between the ages of 13-17 years old without parental consent) has provided us with Personal Information, we will take steps to delete such information from our files. Separately, a child under 18 may request the deletion of information they posted on our Site or Services, which may be accomplished through anonymization. 

As a global entity, Winy may store, transfer, and otherwise process your  Personal Information in countries outside of the country of your residence,  including India and possibly other countries. Such countries may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services. 

 

Applicable Laws & Jurisdiction

In case of any dispute whatsoever, you agree and acknowledge that this privacy policy agreement shall be governed by the laws of India without any conflict of laws. Further, you agree and acknowledge that Indian courts located in the city of Udaipur, Rajasthan, India shall have jurisdiction for any matters. You further agree to resolve the conflicts, Winy may choose to go for arbitration by a sole arbitrator, and the cost of arbitration, which includes the fees of the arbitrator, arbitration premises, and any other ancillary cost, will be borne by you. If you don’t agree then you shall not use this website.

International Transfer and Uses

Winy operates in India only. We may store, transfer, and otherwise process your  Personal Information in countries outside of the country of your residence,  including India and possibly other countries. Such countries may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services. 

Notices 

Please send all questions, comments, and notices regarding this Privacy  Policy to Winy at info@thewiny.co.