General Statement

Journey Starts Here LLC is Advertising and Matching platform between practitioners and clients.

Journey Starts Here’s mission is to create an environment where practitioners can thrice, leaving behind the distractions of marketing and advertisement, whilst dedicating their energy to what truly matters- providing exceptional care and guidance to clients.

This Privacy Policy applies to all Services, applications and websites that are offered and provided by Journey Starts Here, its divisions and its affiliates.

If you are located in the European Union, a data controller will responsible for your information.

If you are a California resident, the collection, use and disclosure of your personal information, as well as your individual rights, are subject to our Privacy Statement – California.

This Privacy Policy (“Privacy Policy”) discloses the privacy practices for Journey Starts Here (sometimes referred to as “Journey Starts Here”, “we”, “our” or “us”) with regard to your (“You” or “Your”) use of the website ([]) (the “Site” or “Sites”). This Privacy Policy has been updated for the European General Data Protection Regulation in force (“GDPR”)

Please read this Privacy Policy carefully so You understand how Journey Starts Here processes and protects Your information and also in order to ensure that the benefits and obligations of membership are understood. We also encourage members talk to us with any questions, comments or suggestions having read this Privacy Policy.

Our Privacy Policy

In the course of providing You a high quality Journey Starts Here experience and through Your interactions with us, Journey Starts Here collects information about You and about Your use of our Site.

Journey Starts Here takes your privacy and its obligations under data protection laws very seriously, and we strive to be transparent at all times about our treatment of your information.

Information Collection and Use

Registration Information

Before You can register for Journey Starts Here, You will need to provide Your name, identification documents (passport, etc.) address, email address and, in case of a professional offering its services through the Sites, a copy of your license or professional credentials. We will use this information to set-up, validate and administer your account. You must also consent to the privacy practices set out in this Privacy Policy, as well as agree to our Terms of Use and Code of Conduct in order to register.

We may use your information to send you information about our Services, and provide you with information about other goods and services we offer that are similar to those that you have already used or enquired about to market to you. We may also use this information to provide you, or (based on your explicit consent, if and when required under applicable law) permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will primarily contact you by electronic means (email or SMS) with information about goods and services similar to those which you have expressed interest in.

Your information may also be used to help prevent spam, fraud, or abuse. You may use your settings for email and mobile notifications to control notifications you receive from our Services. You may also unsubscribe from a notification by following the instructions provided with the notification or instructions available via the Site.

Personal Account Information

Once a registered member of Journey Starts Here, You may provide additional information in Your personal account profile which describes You, including Your birth date, social network username, school, institutional affiliations, credentials, professional experiences, memberships, academic background and biography. Providing additional information in Your personal profile is not required and entirely optional, but it may allow You to derive greater benefits from using Journey Starts Here, such as receiving profile-targeted invitations to participate in surveys, if you choose to provide it. This information can be updated or removed by You at any time, and You may choose whether to make some of this information publicly visible to other social network participants

Information We Receive From You

A key part of Journey Starts Here involves encouraging the free flow of ideas, opinions and content between mental health professionals, and most of this information provided by users is available to be viewed by other Journey Starts Here users and third parties with whom we are conducting business. However, regardless of the nature of your posts, we ensure your opinion will remain anonymous if you wish it to be.

When You post content such as articles, comments and photos on Journey Starts Here, we may also receive additional data (or metadata) related to the content.

We also collect information when you navigate the Journey Starts Here site, for example, when You visit a Journey Starts Here page, send or receive a message, click on or otherwise interact with content, post content, view or click on ads we display, perform a search, or participate in polls. We may use this information to make inferences, such as about the content, subjects and ads You may be interested in. If You have agreed to our use of cookies (see our Cookie section and policy below) and one of our cookies on your device identifies You, Your usage information and the log data described below, such as your IP address, will be associated by us with Your account. Further, if You email us, we will keep the email message, etc. However, if You send a message to a practitioner, we will have their email address and name, so we can send You back a feedback form. We will not see the message You send to the practitioners. Moreover, if You enter their email address at any point, we will keep this information for future use.

We also receive and use Your information when You decide to contact us. If You email us, we may keep Your message, email address and contact information. We need this to categorize Your enquiry, respond to it and, if applicable, investigate any breach of our Terms of Service, Code of Conduct or this Privacy Policy. We may also use this information to customise and improve our services over time. We do not use this information for external advertising.

To set-up and run Your Journey Starts Here account, we may ask you to provide some financial information in order to allow You to receive and effect payments. We may also need to send the information set out in this section to trusted third parties that we appoint to process and administer such payments.

Journey Starts Here does not collect personal health information about individuals. Journey Starts Here does not collect or maintain information that would associate a submission with a specific patient. So please ensure that You do not disclose anything that would allow a patient to be identified. Note also that Journey Starts Here does not possess a data-based key to re-identify patient data. We will have access to Your name and email in case you decide to contact a practitioner.

Information To/From Third Parties

We reserve the right to instruct trusted third parties to process Your information in order to verify Journey Starts Here user identities and ensure that members are mental health professionals and to protect the integrity of Journey Starts Here by preventing fraud.

We may obtain data from our affiliates or our advertising partners, customers and other third parties, which help us (or them) deliver sponsored content onto Journey Starts Here, understand online activity, and generally improve Your Journey Starts Here experience. Such third parties may share information about You which includes a browser cookie ID, website URL visited, mobile device ID, or cryptographic hash of a common account identifier (e.g. usernames or email address), which enables Journey Starts Here to provide ads on the Site and monitor Your preferences and Your interest in them. However, You can choose to block certain ads by enabling an ad blocker to Your web browser so that Your information will not be matched to information shared by ad partners for this purpose. The information generated by the cookie about Your use of the website will generally be transmitted to and stored on servers outside your country.

Cookie Information

A cookie is a small piece of data that is sent to Your browser from a Web server and stored on Your computer’s hard drive. A cookie cannot be used to read data off Your hard disk, nor can it read cookie files created by other sites. We use cookies to improve Your experience on the Site; for example, by setting a cookie on Your browser, You would not have to log in a password more than once, thereby saving time. You can choose whether to accept cookies or not by changing the settings of Your browser. You can reset Your browser to refuse all cookies or allow Your browser to show You when a cookie is being set. If You reject the cookies on the Site, You may still be able to use the Site, but Your use may be limited in some areas or limited to certain functions of the Site.

The Journey Starts Here Site uses session cookies and persistent cookies to better understand how you interact with the Site, to monitor aggregate usage by and web traffic, to enable You to access surveys and to make improvements the Site. You can learn more about the use of cookies in our Cookie Policy.

Log Information

When you use our Site, Journey Starts Here may use information such as Your IP address, browser type, operating system, referring web page, pages previously visited, location (see below), mobile carrier, device and/or application identifiers, search terms, and cookie information to align our services with changes in Your device usage patterns, to administer the Site and to gather certain demographic information for aggregate use. We may also receive log information when You view or interact with links on the Journey Starts Here site, including sites operated by third parties.

Location information

We may receive information concerning your location if, for example, You choose to post content which reveals this information. We may also determine Your location using information from Your device, such as GPS data, information about wireless networks or cell towers near Your device, or IP address. Subject to your explicit consent, we may use this to improve and customize our service to You, for example by making you aware of content, people and ads more relevant to Your location. You can choose to turn off location services on Your device if you prefer, however if You do so You will not benefit from such tailored content.

How And Why We Share Your Information

We will only process the information we collect about You in accordance with this Privacy Policy or where You have otherwise authorized us to do so by granting us your explicit consent.

We may direct You to pages which contain commercial content or You may be presented with the opportunity to engage with sponsored content. We may then provide our partners with engagement effectiveness metrics that include the sharing of some minimal personal data for performance assessment purposes. To the extent required by law, we will collect your explicit consent prior to providing such identifiable information.

We engage service providers to perform certain functions on our behalf and help us provide our services. We may share Your information with such service providers, who are carefully selected by us, where we impose legal obligations on them which are consistent with this Privacy Policy, and on the condition that they act only on our instructions and keep Your information secure. We may also share Your information with other entities within the Journey Starts Here group and we have implemented technical and contractual measures to help ensure that Your information is secure through-out the Journey Starts Here group.

Subject to implementing relevant safeguards under GDPR, the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our service providers. We will take all steps necessary to ensure that Your information is subject to the required technical and organizational measures as required under law and are treated in accordance with this Privacy Policy.

Users of the Site are prohibited from revealing any information that might identify another user; and doing so will constitute grounds for immediate termination of that members’ account. However, if You have chosen to reveal personal data on the Site it is possible that other users may make reference to it. As such, please consider carefully what information You choose to make public on the Site.

Legal Requests

Journey Starts Here takes Your right to privacy very seriously and has taken measures to safeguard Your personal data. Journey Starts Here will only disclose Your personal data other than as set out above in the event we are required to do so by law, rule, regulation, law enforcement, governmental official, legal authority or similar requirements.

Use of Data

Journey Starts Here uses the collected data for various purposes:

• To provide and maintain the Service

• To notify you about changes to our Service

• To allow you to participate in interactive features of our Service when you choose to do so

• To provide customer care and support

• To provide analysis or valuable information so that we can improve the Service

• To monitor the usage of the Service

• To detect, prevent and address technical issues

How We Secure Your Information

We are committed to protecting the security of Your information. We use a variety of industry-standard security technologies and procedures designed to help protect Your information from unauthorized access, use, or disclosure. Despite these measures, You should know that we cannot fully eliminate security risks associated with information and transmission of data over the internet, it can never be completely secure. In the event of a data security breach, we will take all essential actions as required under applicable laws.

The Site may contain links to other sites. The linked sites are not necessarily under the control of Journey Starts Here. Please be aware that Journey Starts Here is not responsible for the privacy practices of such other sites. Journey Starts Here encourages You to be aware when You leave this Site and to read the privacy policies of each and every web site that collects personal information. If You decide to access any of the third-party sites linked to this Site, You do this entirely at Your own risk. Any links to any partner of the Site is responsibility of that partner and Journey Starts Here shall not be responsible for notification of any change in name, or location of any information on the Site.

Your Rights

You also have a legal right under the GDPR and other relevant data protection laws to: (i) access the information we hold about you and (ii) to a copy of any information about You held by us. Upon request, we will provide You with access to and a copy of this information. You also have a right to (iii) correct any errors in this information, (iv) request its deletion or (v) to object to any processing operations (provided we are not under legal obligations to retain certain information) and (vi) to revoke any given consent at any time.

We reserve the right to decline requests that are (i) unreasonably repetitive, (ii) that jeopardize the privacy of others, (iii) the validation facility, (iv) the interests of justice, (v) or where we are otherwise required to retain Your personal data by law.

You can exercise Your rights to access, edit and delete your information in accordance with the GDPR or other relevant local privacy laws at your location – at any time by Contacting Us or emailing us at support@journeystartshere.com. Lastly, if you are a European Union resident, you also have the right to submit a complaint to the relevant data protection authority in your European Union member state.

Update And Deletion of Personal Information

If Your personal information changes (such as Your address), You can update Your profile on the Profile page of the Site. Journey Starts Here will correct, update or remove Your personal data as directed or You can do so Yourself via the self-service Profile page mentioned above.

If You no longer desire to use the Site, you may permanently delete your Journey Starts Here account. The time to deactivate Your account will vary according to your prior history with Journey Starts Here. In the simplest cases, deactivation will be prompt following the receipt of a “cooling off” communication reminding you of the results of deactivation.

You have given consent to the processing of Your information for one or more specific purposes. For example: clicking “I agree” to a cookie alert while browsing a page on the internet or consenting to a specific information processing request contained within an online survey.

Processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of You prior to entering into a contract.

Processing is necessary for compliance with a legal obligation to which Journey Starts Here is subject. For example: accurately reporting taxes, complying with financial transparency or reporting pharmacovigilance adverse events information.

Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Journey Starts Here. This legal base will probably not be used by Journey Starts Here.

Processing is necessary for the purposes of the legitimate business interests pursued by Journey Starts Here or by a related third party, except where such interests are overridden by Your interests or fundamental rights and freedoms.

Notification of Changes

We may update this Privacy Policy at any time, with or without advance notice. In the event of any change in the way we treat Your personal data, or in the Privacy Policy document itself, we will display a notice on the Journey Starts Here website (www.journeystartshere.com) or send You an email, so that You may review the changed terms prior to continuing to use the Site. As always, if You object to any of the changes to our terms, and You no longer wish to use the Site, You may contact Journey Starts Here Support to deactivate Your account. Unless stated otherwise, our current Privacy Policy applies to all information that Journey Starts Here has about You and Your account.

Site and Service Updates

As necessary, Journey Starts Here may send You Site and service announcement updates. You are not able to unsubscribe from service announcements, which contain important information about the Site, unless you delete your account. Journey Starts Here primarily communicates via e-mail with You to provide requested services and to resolve issues relating to Your accounts.

Children's Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Contact Us

Should You have questions about this policy or Journey Starts Here’s information collection, use and disclosure practices, feel free to Contact Us. You may also contact our interim Data Protection Officer and General Counsel by a written request at

Journey Starts Here,

support@journeystartshere.com

We will use all reasonable efforts to respond promptly to requests, questions or concerns You may have regarding our use of personal information about You. Except where required by law, Journey Starts Here cannot ensure a response to questions or comments regarding topics unrelated to this policy or Journey Starts Here’s privacy practices.