PSYCHFRAME PRIVACY POLICY

M/s Psychframe Mental Health Solutions LLP, herein referred to as "we," "us," or "Psychframe," acting on behalf of itself and its affiliated/group companies operating under the brand "Psychframe," is the creator and distributor of the online resource www.psychframe.com and the mobile application 'Psychframe', collectively referred to as the "Website."

This Privacy Policy encompasses both online activities (such as web and mobile services, including any websites operated by us or the Mobile Application, regardless of access method, whether through personal computers, mobile devices, or otherwise) and offline activities (such as data collection via mailings, telephone, or in-person interactions) owned, operated, provided, or made accessible by the Company. Additionally, this Privacy Policy extends to your utilization of interactive features or downloads that:

i) We own or have control over;

ii) Are accessible through the Services; or

iii) Interact with the Services and incorporate or reference this Privacy Policy.

CONSENT AND ASSENT

You acknowledge that this Privacy Policy is a part of the Terms of Use of the Website and the other Services, and you unconditionally agree that becoming a User of the Website and its Services signifies your:

i. assent to this Privacy Policy, and

ii. consent to Psychframe using, collecting, processing and/or disclosing your Personal Information in the manner and for the purposes set out in this Privacy Policy.

Your visit to the Website and use of the Services is subject to this Privacy Policy and the Terms of Use.

BY ACCEPTING THE TERMS AND CONDITIONS, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. Please review the following carefully.

1. PRIVACY POLICY

This Privacy Policy delineates the following:

• The categories of information collected from Users, encompassing Personal Information and Sensitive Personal Data or Information, as defined below, pertaining to an individual;
• The purpose, methods, and channels of collecting, utilizing, processing, retaining, and disposing of such information;
• The manner and recipients to whom such information is disclosed.

This Privacy Policy is published in adherence to:

• The Information Technology Act, 2000;
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (referred to as the "SPI Rules");
• The Information Technology (Intermediaries Guidelines) Rules, 2011.

2. PERSONAL INFORMATION

Sensitive Personal Data or Information or “SDPI” of a person includes any personal information such as a) password, b) financial information – bank account, debit card, credit card or any other payment information c) physical and mental health history, d) sexual orientation, e) medical history, f) biometric, g) any details related to the above points.

When you access the Services, or through any interaction with us via emails, telephone calls or other correspondence, we may ask you to provide us with certain information that personally identifies you or could be used to personally identify you. You hereby consent to the collection of such information by Psychframe. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:

1. contact data (such as your email address and phone number);
2. demographic data (such as your gender, your date of birth and your pin code);
3. data regarding your usage of the services and history of the appointments made by or with you through the use of Services;
4. insurance data (such as your insurance carrier and insurance plan);
5. other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters) including any images and other documents/files.

3. USE OF COLLECTED INFORMATION

1. Our primary goal in collecting your information is to provide you with an enhanced experience when using our Services. We use your SDPI in order to match you to the Practitioner best suited to your needs.
2. Your mental health related data is shared with the Practitioner with your consent so that the Practitioner can effectively cater to your needs.
3. We use your email id and mobile number to send you reminders about upcoming sessions and other information related to your account. We might also use it for marketing and promotional purposes.
4. We use your Internet Protocol (IP) address to help diagnose problems with our computer server, and to administer our web site(s). Your IP address is used to help identify you but contains no personal information about you.
5. We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email.
6. All information (and copies thereof) collected by Psychframe, including without limitation SPDI, Usage information and other information related to your access and use of the services offered by Psychframe, may be retained by Psychframe for such period as necessary, including but not limited to, for purposes such as compliance with statutory or legal obligations, tax laws and potential evidentiary purposes and for other reasonable purposes such as to implement, administer, and manage your access and use of our services, or resolution of any disputes.
7. To ensure a seamless experience at the Website for you and to ensure your maximum benefit and comfort, we use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to:

a) Remember information so that you will not have to re-enter it during your visit or the next time you visit the site; b) Provide custom, personalized content and information, including advertising; c) Provide and monitor the effectiveness of our Services; d) Monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Services; e) Diagnose or fix technology problems; and f) Otherwise to plan for and enhance our service.

8. We employ specific third-party analytics tools to aid in gauging traffic and usage patterns for the Services. These tools gather non-personal or sensitive data transmitted by your device or our Services, encompassing the web pages visited, add-ons utilized, and other relevant data that aids in enhancing the Services. We gather and utilize this analytics data alongside information from other Users, compiled in the form of anonymized logs, ensuring it cannot reasonably identify any particular individual User.

4. SHARING OF COLLECTED INFORMATION

1. We may share Personal Information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Psychframe is part of, or that become part of that group (“Affiliates”). Our Affiliates may only use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences).

2. Additionally, we may disclose your Personal Information along with data obtained from tools such as cookies, log files, device identifiers, and location data to third-party entities that assist us in delivering the Services to you. Our service providers will only be granted access to your information to the extent reasonably required to render the Services. All service providers and third parties contracted by Psychframe are obligated by sufficient confidentiality agreements to safeguard the Confidential Information and Personal Information of the User, ensuring that such information is not utilized in a manner beyond its intended purpose.

3. While sharing any information with any third party, we will remove parts of data that can identify you and share only anonymous data with other parties.

4. Kindly note that only Personal Information or content voluntarily disclosed by you for posting to the Website or any social media account owned and operated by Psychframe becomes accessible to the public. No other information provided by you is disseminated to the public. Once such information is shared or made public, it may be re-shared by others, re-posted by Psychframe, or utilized by Psychframe for analysis, research, or studies.

5. Psychframe shall not ordinarily share the sensitive Personal Information of a User without their prior consent. You agree that Psychframe may share sensitive Personal Information of a User with any third party without obtaining the prior consent of the User in the following limited circumstances:

   a. When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing the Terms of Use, this Privacy Policy, or for complying with the applicable laws and regulations.

   b. Psychframe proposes to share such information within its group companies and officers and employees of such group companies for the purpose of processing personal information on its behalf. Psychframe also ensures that the recipients of such information agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

5. CONFIDENTIALITY

1. Any information disclosed by you during personal consultation ("Confidential Information") shall be exempted from the definition of Personal Information and shall not be collected or utilized in the same manner as Personal Information, as detailed above.

2. Your Confidential Information shall not be disclosed or shared by Psychframe, its employees, its agents, or any third-party contractors, including the counsellors; either orally or in writing; except only in the following circumstances:

   a. If Psychframe believes that there is a significant/ real/ imminent threat or risk to your health, safety or life or to the health, safety or life of any other person or the public

   b. If Psychframe is required to share such Confidential Information to any authority by law

   c. If you have claimed a health care insurance and such Confidential Information is required by the insurer.

   d. In case your Practitioner sees it fit to involve a Supervisor to best treat and tend to your needs, in such a case, only relevant and anonymized data is shared with the Supervisor

   e. In cases of group therapies the therapists and users alike are required to keep the information confidential.

Confidentiality relating to Minors

Psychframe is committed to protecting the privacy of minors by ensuring the confidentiality and security of their personal and mental health information. Information collected is strictly for providing and enhancing mental health therapy services, including diagnosis, personalized treatment planning, and progress monitoring. We adhere to Indian laws and guidelines on data protection and privacy, ensuring information is disclosed only with legal guardian consent, among our mental health professionals for service provision, or as required by law. We implement advanced security measures to safeguard minors' data against unauthorized access and breaches, in line with India's data protection standards. Parents or legal guardians have the right to review, correct, or request deletion of their child's information, in accordance with legal and ethical standards.

Confidentiality for Users

We commit to the strict protection of your personal and therapy-related information. Collected data is used solely for providing, improving, and personalizing your therapy and counseling experience. Your information will not be disclosed to third parties, except with your explicit consent, for internal use among our professional staff, or as mandated by law. Advanced security measures are in place to protect your data against unauthorized access. You have the right to review, correct, or delete your personal information. By engaging with our services, you acknowledge and consent to our confidentiality and privacy practices, designed to respect and protect your personal information.

6. CHILDRENS AND MINORS PRIVACY

Psychframe strongly advises parents and guardians to supervise the online activities of their minor children and consider utilizing parental control tools offered by online services and software manufacturers to foster a child-friendly online environment. These tools can also prevent minors from disclosing their name, address, and other personally identifiable information online without parental consent. While the Psychframe Website and Services are not intended for use by minors, Psychframe respects the privacy of minors who may inadvertently use the internet or the mobile application. In the event that Psychframe's services are utilized to treat a minor patient, any information shared is kept confidential unless disclosure is mandated under the terms outlined in Clause 5 above.

7. THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES

The Services provided by us may include content supplied by third parties, and these third parties may gather website usage information and your Device Identifier when web pages from any online or mobile Services are presented to your browser. Furthermore, while using the Services, you may be directed to other sites or applications operated and controlled by third parties that are beyond our control. We do not bear responsibility for the privacy practices employed by any of these third parties. For instance, clicking on a banner advertisement may redirect you from one of our websites to a different website. These external websites may issue their own cookies to you, independently collect data, or request Protected Information. They may or may not have their own published privacy policies. We encourage you to take note when exiting our Services and to review the privacy statements of all third-party websites or applications before disclosing any Sensitive Personal Data or Information to them.

8. CANCELLATION OF ACCOUNT

1. It is your responsibility to ensure the accuracy of the information you provide to us, including your contact details submitted during account registration. If there are changes to your Sensitive Personal Data or Information (SPDI), or if you no longer wish to avail our Services, you may rectify, delete inaccuracies, or modify the information by updating your user profile page or by contacting us via the email address provided on our website or Mobile Application. We will endeavor to promptly incorporate requested changes into our active databases to the extent reasonably practicable.

2. You also have the option to cancel or modify the communications you have chosen to receive from the Services. You can do so by following the instructions provided within email or by accessing your user account and adjusting your communication preferences accordingly.

3. If upon modifying or changing the information earlier provided to Us, we find it difficult to permit access to our Services to you due to insufficiency/ inaccuracy of the information, we may, in our sole discretion terminate your access to the Services by providing you a written notice to this effect on your registered email id.

4. If you desire to cancel your account or request that we cease using your information to provide you services, please reach out to us through the contact details provided on the website. Even following the termination of your account, we will retain your Sensitive Personal Data or Information (SPDI) and Usage Information as required to adhere to our legal and regulatory obligations, resolve disputes, conclude any activities related to the cancellation of an account, investigate or prevent fraud and other inappropriate activities, enforce our agreements, and for other legitimate business reasons. Over time, your data may be anonymized and aggregated, and subsequently retained by us for as long as necessary to effectively provide our Services, with the use of anonymized data being solely for analytical purposes.

5. The right to delete personal data: You have the right to request the deletion of your personal data, subject to certain exceptions. Upon receipt of your request via email at tncprivacy@psychframe.com and subsequent confirmation, we will proceed to delete (and instruct our service providers to delete) your personal information from our records, unless an exception applies. Psychframe reserves the right to revise or amend this Privacy Policy periodically to accommodate necessary future changes.

   Psychframe's utilization of User Data will remain consistent with the provisions outlined in the pertinent privacy policy under which the information was originally collected, irrespective of any new or conflicting provisions in an updated Privacy Policy