Privacy Policy

(Updated February 1, 2024)

What is this document?

Privacy policies can be full of legalese and inaccessible. You may prefer to have your question answered quickly without having to navigate pages of text. With this document, we hope to make that easier. We tried our best to make our Privacy Policy as easy to navigate and understand as possible. If you have any questions while reading it, please don’t hesitate to reach out to info@PAIRS.com.

For purposes of this Policy and unless otherwise specified, “data” includes information that is linked to one person or household including things like name, email address, phone numbers, device ID, Third Party identifiers, contact information, and communications with Coaches using our digital communication platform (the “Platform”) to provide services (“Coaches”). Some jurisdictions might consider this to be “personal data,” “personally identifiable information,” or “sensitive personal data” in certain circumstances. When you use and access our app or website, you accept and agree to both the Terms and Conditions and this Privacy Policy, including that we’ll share certain data with Service Providers.

Will this document be updated?

We may update this Privacy Policy. When 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.

How to navigate this document

This document is broken into seven sections divided by topic. To navigate to a section, reference the list below which provides examples of the types of questions that will be answered in that section. When you find a section that interests you, just click on it and you’ll be automatically directed there.

Section One

Do you collect, store, or process my data?

The categories of data which we Process are listed below. We Process this data to do things like operate the Platform and make sure you are able to use our services effectively. We may also Process data to send you periodic emails or text messages. In some cases, these communications are to help provide services. Other times, they are to provide marketing communications. You can opt out of receiving texts or marketing communications at any time. Additionally, provided you opt in, we may Process and share some data with Third Parties for advertising purposes. You can find more details in the relevant sections of this Policy.

What specific data are you Processing and why do you collect it?

What data we Process depends on how you’re using our website, app, or the Platform. We explain in the section below the specific data we collect and Process and, in the section following this, the business purpose for collecting and Processing this data.

"Visitor data”

What is collected:

When you visit the website, app, or Platform, we Process information like the particular pages visited or which features you interacted with, the amount of time on the website or app, site/app/Platform errors, information about the type of device and browser you’re using, and IP address. We may Process your Third Party identifier or advertising ID (if available based on the settings of your device) and will share the information with Third Parties, if you opt in to Advertising (previously “Targeting cookies”) and web beacons.

What it is used for:

• Communicating with you5
• Monitoring and improving services
• Personalizing your web or app experience
• 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
• Complying with laws
• Protecting your safety and the safety of others10
• Sending you opportunities, promotions, news, updates and reminders about our services and your account

“Onboarding data”

What is collected:

To create an account with the Platform, the user first fills out a questionnaire. We Process the information used to complete this questionnaire.

What it is used for:

Connecting you with services

• Monitoring and improve service quality
• Personalizing your web or app experience
• 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
• Complying with laws
• Sending you opportunities, promotions, news, updates and reminders about our services and your account

“Account Data”

What is collected:

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.

What it is used for:

• Facilitating services
• Personalizing your web or app experience
• 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
• Complying with laws
• Protecting your safety and the safety of others

“User ID”

What is collected:

We assign each user 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.

What it is used for:

• Connecting you with services
• Communicating with you
• Monitoring and improving service quality
• Personalizing your web or app experience
• 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
• Complying with laws
• Protecting your safety and the safety of others
• Sending you opportunities, promotions, news, updates and reminders about our services and your account

“Customer Service and Communications Data”

What is collected:

We Process communications users have with our Customer Service team.

What it is used for:

• Communicating with you
• Complying with laws
• Protecting your safety and the safety of others

Do you Process location data?

We process your IP address to determine your rough location so that we can personalize the platform for you. For example, we show you relevant information about our service that applies to visitors from your country.

Data Sharing

What are the purposes for sharing my data?

Here’s some more information about the purposes for which we share your data:

• Your data may be shared to comply with applicable laws.
• Occasionally, your data may be handled by a select number of employees who are part of our parent company for support services. These employees are under strict duties of confidentiality.
• We may share certain data with Service Providers¹² that provide limited services that help us operate the Platform. Examples include:
• Data hosting and storage providers: For example, cloud hosting providers such as Amazon Web Services (AWS).
• Technology Service Providers: For example, we sometimes integrate tools into our Platform which give our Platform more functionality, like technology that helps us provide live audio, video and group meetings.
• Customer Service Providers: For example, we use a tool that helps keep track of requests and questions from our visitors in a secure way.
• Reporting and analytics Service Providers: For example, we might use a service to help us keep track of which pages and features are most used on our site.
• We may share some of your data with Service Providers to ensure the safety and security of the Platform and that of our users.
• For users who receive services in connection with an employer, organization, or other business partner, we may share group-level usage data, which cannot be directly connected to you, with your organization. In the instance of users who receive services through an Employee Assistance Program (“EAP”), your EAP will provide notice for any individual-level data which is shared with the EAP, if you are utilizing one and have provided them with consent for us to do so. If you have any questions on how your data will be used by or shared with your EAP, please reach out to your EAP directly.
• We may share some of your data in connection with an asset sale, merger or bankruptcy.

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

If you opt in to "Analytics (previously "Performance cookies")", we may use analytics cookies from trusted Service Providers to Process¹ data for activities including but not limited to analyzing traffic sources, visits, and site interactions. This analysis helps us to improve our products and services.

If you opt in to "Advertising (previously "Targeting cookies")" and web beacons, information regarding your activity on our websites, excluding activity when you’re logged in and have started therapy, may be shared for advertising purposes. To learn more, see section: "Are you using my data for advertising?"

How do you use my data to comply with the law?

When required by law, we cooperate with government agencies. This is not unique to PAIRS and is applicable to other service providers as well.

We aren’t paid by anyone for any data. However, in California, the laws define “sale” broadly to include the sharing of personal information in exchange for anything of value. If you opt in to our use of Advertising cookies and web beacons, this use may be considered a “sale” of personal information under that specific California law. For specific information on your data rights as a resident of California, see the additional notice for California residents.

Are you using my data for advertising?

In order to reach people who may be looking for support, we advertise on some Third Party² web properties such as Third Party websites and apps. In order to minimize advertising costs related to this process and downstream costs to you, we strive to deliver ads that are relevant, interesting, and personal.

Therefore, if you opt in to Advertising cookies and web beacons, your IP address, Third Party identifier (if applicable), hashed User ID (if applicable), and some Visitor Data, excluding activity when you’re logged in and have started services, may be shared for advertising purposes. As a result, you may see ads for our services on some Third Party websites.

Even if you do opt in, we still do not engage in “retargeting” advertising. Retargeting advertising is a type of advertising whereby advertisers leverage the fact that you viewed a page or took an action on their site to advertise to you again on third party properties in the hope that you will see the ad and return to their site.

To be clear, we don’t share any data or information you share with your Yodi with any Third Party advertisers. Even if you opt in to Advertising cookies and web beacons, we still don’t share information with Third Party advertisers like user names, email addresses, phone numbers, clinician diagnosis, questionnaires answers, sessions data, journal entries, messages, worksheets, or any other type of private communication you have with your Therapist on the Platform.

For additional information regarding Third Parties that PAIRS may share data with, please reference our Third Party Partners Disclosure List.