Soulgood counsellingLimited (the “Company”) respects the privacy of its online visitors andcustomers of its products and services (including, but not limited to Soulgood)and complies with applicable laws for the protection of your privacy.
1. Definitions
Wherever we talk aboutPersonal Data below (“Personal Data“), we mean anyinformation that can either itself identify you as an individual (“PersonallyIdentifying Information“) or that can be connected to youindirectly by linking it to Personally Identifying Information, forexample:
(i) your accountregistration information on our website and in our App;
(ii) when you requestany support from us or report any problem to us;
(iii) informationprovided from using certain services or features;
(iv) information fromcompletion of survey or questionnaire;
(v) technicalinformation, including the Internet protocol (IP) address used
(vi) and your log-ininformation, browser, time zone setting, browser plug-in types and versions,operating system and platform;
(vii) details of anytransactions, purchases and payments you made;
(viii) your generalinteraction with the website, including the full Uniform Resource Locators(URLs), clickstream to, through and from our site, products you viewed orsearched for, page response times, download errors, length of visits to certainpages, page interaction information;
(ix) informationreceived from third parties, such as business partners, sub-contractors,payment and delivery services, referrals by other users.
(x) Session Transcripts, Chatroom messages, journals and reportsduring counselling
(xi) information collected during the useof self help tools
(xii) Your personal contact information andemergency contact details
The Company alsoprocesses anonymous data, aggregated or not, to analyze and produce statisticsrelated to the habits, usage patterns, and demographics of customers as a groupor as individuals. Such anonymous data does not allow the identification of thecustomers to which it relates. the Company may share anonymous data, aggregatedor not, with third parties. Please be aware that the Company may choose topermit third parties to offer subscription and/or registration-based servicesthrough the Company’s site. The Company shall not be responsible for anyactions or policies of such third parties and you should check the applicableprivacy policy of such party when providing personally identifiableinformation.
By using the Company’swebsite, you signify your assent to the Company’s privacy policy. If you do notagree to this policy, please do not use the Company’s website(s).
2. Why the Company Collects and Processes Data
The Company collectsand processes Personal Data for the following reasons:
(a) performing ouragreement with you to provide content and services, including providing, improvingand developing our services;
(b) researching,designing and launching new features or products;
(c) providing you withalerts, updates, materials or information about our services or othertypes of information that you requested or signed up to;
(d) collecting overdueamounts;
(e) responding ortaking part in legal proceedings, including seeking professional advice,or for the purposes of the legitimate and legal interests of the Company or athird party (e.g. the interests of our other customers);
(f) compliance withlegal obligations that we are subject to;
(g) communicating withyou and responding to your questions or requests;
(h) direct marketing -we require your consent specifically for this purpose and you may opt out anytime;
(i) purposes directlyrelated or incidental to the above; or
(j) where you have given consent to it.
These reasons forcollecting and processing Personal Data determine and limit what Personal Datawe collect and how we use it (section 3. below), how long we store it (section4. below), who has access to it (section 5. below) and what rights and othercontrol mechanisms are available to you as a user (section 6. below).
3. What Data We Collect and Process
Soulgood collectsde-identified data in a HIPAA compliant manner. All de-identified data,meta-data and research data collected by Soulgood through your use of theServices remains the sole property of Soulgood. Soulgood may share some or allof this research data with third parties in connection with joint or outsideresearch, analytics, or similar purposes. Research data is used innon-identifiable aggregate form, but not in a manner that would identify youpersonally. You shall not request that Soulgood remove or delete any of such data.
You consent to Soulgood using “MetaData” and other search terms to scan de-identified transcripts to searchfor trends and patterns that may affect the quality of the Services provided toyou or the practices of the Providers. If your particular complaint requires areview of Session Transcripts in the original form, you consent to Soulgood toaccess your account only to respond to your particular complaint or raisedissue.
The collected datawould be summarized below.
3.1 Basic Account Data
When setting up anAccount, the Company will collect your email address and country of residence.You are also required to choose a user name and a password. The provision ofthis information is necessary to register a User Account. You are responsiblefor keeping this password confidential. We ask you not to share a password withanyone.
During setup of youraccount, the account is automatically assigned a number (the “ID”)that is later used to reference your user account without directly exposingPersonally Identifying Information about you.
3.2 Transaction and Payment Data
In order to make atransaction online, you may need to provide payment data to the Company toenable the transaction. If you pay by credit card, you need to provide typicalcredit card information (name, address, credit card number, expiration date andsecurity code) to the Company, which the Company will process and transmit tothe payment service provider of your choice to enable the transaction andperform anti-fraud checks. Likewise, the Company will receive data from yourpayment service provider for the same reasons.
3.3 Other Data You Explicitly Submit
We will collect andprocess Personal Data whenever you explicitly provide it to us or send it aspart of communication with others, e.g. in forums, chats, or when you providefeedback or other user-generated content. This data includes:
(a) Information thatyou post, comment or follow in any of our Content and Services;
(b) Information sentthrough chat;
(c) Information youprovide when you request information or support from us or purchase Content andServices from us, including information necessary to process your orders withthe relevant payment merchant or, in case of physical goods, shippingproviders;
(d) Information youprovide to us when participating in competitions, contests and tournaments orresponding to surveys, e.g. your contact details.
(e) information you provide through ourself help tools.
(f) Contact information including your owncontact information and emergency contact information
3.4 Your Use of the Websites
We collect a variety ofinformation through your general interaction with the websites, Content andServices offered by us. Personal Data we collect may include, but is notlimited to, browser and device information, data collected through automatedelectronic interactions and application usage data. Likewise, we will trackyour process across your websites and applications to verify that you are not abot and to optimize our services.
3.5 Your Use of Services and other Subscriptions
In order to provide youwith services, we need to collect, store and use various information about youractivity in our Content and Services. “Content-Related Information”includes your ID, as well as information about your preferences, progress, timespent, as well as information about the device you are using, including whatoperating system you are using, device settings, unique device identifiers, andcrash data.
3.6 Tracking Data and Cookies
We use”Cookies”, which are text files placed on your computer, to help usanalyze how users use our services, and similar technologies (e.g. web beacons,pixels, ad tags and device identifiers) to recognize you and/or your device(s)on, off and across different devices and our services, as well as to improvethe services we are offering, to improve marketing, analytics or websitefunctionality. The use of Cookies is standard on the internet. Although mostweb browsers automatically accept cookies, the decision of whether to accept ornot is yours. You may adjust your browser settings to prevent the reception ofcookies, or to provide notification whenever a cookie is sent to you. You mayrefuse the use of cookies by selecting the appropriate settings on yourbrowser. However, please note that if you do this, you may not be able toaccess the full functionality of our websites. When you visit any of ourservices, our servers log your global IP address, which is a number that isautomatically assigned to the network your computer is part of.
3.7 Third Party Services
This website uses Thirdparty services (“Third Party Service“). ThirdParty Service uses “cookies”, which are text files placed onvisitors’ computers, to help the website operators analyze how visitors use thesite. The information generated by the cookie about the visitors’ use of thewebsite will generally be transmitted to and stored by Third PartyService on servers . Please be aware that Company cannot or does notcontrol the use of cookies or the resulting information by the Third PartyService.
On behalf of thewebsite operator, Third Party Service will use this information for the purposeof evaluating the website / location / credentials for its users, in order tocompile reports on website activity, and to provide other services relating towebsite activity and internet usage for website operators.
Third Party Servicewill not associate the IP address transferred with any other data held by the Company. You may refuse the use ofcookies by selecting the appropriate settings on your browser. However, pleasenote that in this case you may not be able to use the full functionality ofthis website.
3.9 Content Recommendations
We may processinformation collected under section 3 so that content, products and servicesshown on the pages and in update messages displayed when launching the servicecan be tailored to meet your needs and populated with relevant recommendationsand offers. This is done to improve your customer experience.
Subject to yourseparate consent or where explicitly permitted under applicable laws on emailmarketing, the Company may send you marketing messages about products andservices offered by the Company to your email address. In such a case we mayalso use your collected information to customise such marketing messages aswell as collect information on whether you opened such messages and which linksin their text you followed.
You can opt out orwithdraw your consent to receive marketing emails at any time by eitherwithdrawing the consent on the same page where you previously provided it orclicking the “unsubscribe” link provided in every marketing email.Notwithstanding any opt out of promotional or marketing emails by you, wereserve the right to contact you regarding account status, changes to the useragreement and other matters relevant to the underlying service and/or theinformation collected.
3.9 Information Required to Detect Violations
We collect certain datathat is required for our detection, investigation and prevention of fraud,cheating and other violations of the applicable laws (“Violations“).This data is used only for the purposes of detection, investigation, preventionand, where applicable, acting on such Violations and stored only for the minimum amount of timeneeded for this purpose.
If the data indicatesthat a Violation has occurred, we will further store the data for theestablishment, exercise or defence of legal claims during the applicablestatute of limitations or until a legal case related to it has been resolved.Please note that the specific data stored for this purpose may not be disclosedto you if the disclosure will compromise the mechanism through which we detect,investigate and prevent such Violations.
4. How We Store Data
4.1 Period of Storage
We will store yourinformation as long as necessary to fulfil the purposes for which theinformation is collected and processed or — where the applicable law provides for a longer storage and retention period— for the storage and retention period required by law. In particular, if youterminate your User Account, your Personal Data will be marked for deletionexcept to the degree legal requirements or other prevailing legitimate purposesdictate a longer storage. Allyour data and credits will be lost after deletion.
4.2 Deletion of Data
In caseswhere Personal Data cannot be completely deleted in order to ensure theconsistency of the system, the user experience or the community, yourinformation will be permanently anonymized. Please note that the Company isrequired to retain certain transactional data under statutory commercial andtax law for a period of upto ten (10) years. Also, You acknowledge that we may not delete medicalrecords data including but not limited to therapy chatroom transcript, journalsand reports even upon your direct request.
If you exercise a right to object to theprocessing of your Personal Data, we will review your objectionand delete your Personal Data that we processed for the purpose to which youobjected without undue delay, unless another legal basis for processing andretaining this data exists or unless applicable law requires us to retain thedata.
4.3 Location of Storage
The data that wecollect from you may be transferred to, and stored at Hong Kong, or adestination outside of your jurisdiction. It may also be processed by thirdparties who operate outside of your jurisdiction. By submitting your personaldata you agree to this transfer, storing or processing of data outside of yourjurisdiction. We will take all steps reasonably necessary to ensure that yourdata is treated securely in accordance with this privacy policy.
5. Who Has Access to Data
5.1 The Company and itssubsidiaries may share your Personal Data with each other and use it to thedegree necessary to achieve the purposes listed in section 2 above. Thisincludes our overseas offices, affiliates, business partners and counterparts(on a need-to-know basis only). In the event of a reorganization, sale ormerger we may transfer Personal Data to the relevant or proposed transferees ofour operations (or a substantial part thereof) in any part of the world.
5.2 We may also shareyour Personal Data with our third party providers that provide customer supportservices in connection with goods, Content and Services distributed via us.Your Personal Data will be used in accordance with this Privacy Policy and onlyas far as this is necessary for performing customer support services.
5.3 We may also shareyour information with our personnel, agents, advisers, auditors, contractors,financial institutions, and service providers in connection with our operationsor services (for example staff engaged in the fulfilment of your order, theprocessing of your payment and the provision of support services); personsunder a duty of confidentiality to us; or persons to whom we are required tomake disclosure under applicable laws and regulations in any part of the world.
5.4 In accordance withinternet standards, we may also share certain information (including your IPaddress and the identification of content you wish to access) with our thirdparty network providers that provide content delivery network services andserver services in connection with us. Our content delivery network providersenable the delivery of digital content you have requested, by using a system ofdistributed servers that deliver the content to you, based on your geographiclocation.
5.5 The Company mayallow you to link your User Account to an account offered by a third party. Ifyou consent to link the accounts, the Company may collect and combineinformation you allowed the Company to receive from a third party withinformation of your User Account to the degree allowed by your consent at thetime. If the linking of the accounts requires the transmission of informationabout your person from the Company to a third party, you will be informed aboutit before the linking takes place and you will be given the opportunity toconsent to the linking and the transmission of your information. The thirdparty’s use of your information will be subject to the third party’s privacypolicy, which we encourage you to review.
5.6 The Company may disclosePersonal Data to comply with court orders or laws and regulations that requireus to disclose such information. Personal Data may be disclosed to thirdparties in the following situations to protect the safety of Users and others:
5.6..1. If the client isinvolved in a medical emergency, Personal Data may be given to medicalpersonnel.
5.6.2. If an appropriate courtorder is received to disclose information
5.6.3. If the clientintends to harm himself or herself or someone else.
5.7 We make certaindata related to your User Account available to other users. This informationcan be accessed by anyone by querying your ID. At a minimum, the public personaname you have chosen to represent you is accessible this way. The accessibility of any additionalinfo about you can be controlled through your user profile page; data publiclyavailable on your profile page can be accessed automatically. While we do notknowingly share Personally Identifying Information about you such as your realname or your email address, any information you share about yourself on yourpublic profile can be accessed, including information that may make youidentifiable.
5.8 The communityincludes message boards, forums and/or chat areas, where users can exchange ideasand communicate with each other. When posting a message to a board, forum orchat area, please be aware that the information is being made publiclyavailable online; therefore, you are doing so at your own risk; and that suchinformation can be collected, correlated and used by third parties and mayresult in unsolicited messages from other posters or third parties and theseactivities are beyond our control. If your Personal Data is posted on one ofour community forums against your will, please use the reporting function andthe help site to request its removal.
6. Your Rights and Control Mechanisms
You have the right to:
(a) check whether wehold personal data about you;
(b) access any personaldata we hold about you;
(c) require us tocorrect any inaccuracy or error in any personal data we hold about you
7. Children
The minimum age tocreate a User Account is 18. the Company will not knowingly collect PersonalData from children under this age. Insofar as certain countries apply a higherage of consent for the collection of Personal Data, the Company requiresparental consent before a User Account can be created and Personal Dataassociated with it collected. The Company encourages parents to instruct theirchildren to never give out personal information when online.
8. Contact Info
You can contact theCompany’s data protection officer at the address below.
While we review anyrequest sent by mail, please be aware that to combat fraud, harassment andidentity theft, the only way to access, rectify or delete your data is throughlogging in with your User Account at enquiry@soulgood.io.
9. Revision Date
This privacy policy was last updated on 08 September 2023 (“Revision Date“). If you were a user before the Revision Date, it replaces the existing Privacy Policy. TheCompany reserves the right to change this policy at any time by notifying the users of the existence of a new privacy statement. This policy is not intended to and does not create any contractual or legal rights in or behalf of anyparty.