Last Updated: July 2, 2018
2. No Health or Medical Records. Sophia operates independently from your therapist and other medical professionals, and while it may share some of information described herein with such professionals, it does not in turn obtain any information about you from those professionals. The obligations imposed by medical records privacy laws, including but not limited to the Health Insurance Portability and Accountability Act of 1996 and subsequent amendments, do not govern Sophia. Instead, Sophia follows this Policy on how it collects, uses, and discloses information.
3. Information Collected. We collect several types of information from users of our Services. We collect this information directly from you when you provide it to us, and automatically as you use or access the Services.
a. Voluntarily disclosed information. When you use the Services, you will have the opportunity to provide us with some information directly. For example, we will collect information that you directly give us as you fill out our intake form on the Services, including but not limited to your name, email address, demographic information, questionnaire responses, and phone number. As another example, we may also collect feedback from you regarding your experience using our Services.
Please note that as set forth in Section 4 below, we may use your email address to facilitate an introduction to the therapist, doctor, or other healthcare professional whom we recommend through the Services. Please note that we will be able to view any content that you share while its email address is still copied in that communication. Please use this conversation solely to schedule an appointment, and do not share any sensitive information until after Sophia is no longer copied in the communication.
In order to use our Services, you may be asked to provide billing information to a service that we use as a third-party payment processor, so that we may collect charges owed due to use of the Services. Please note that your financial information will be collected and your payments will be made through our choice of third-party payment processor, and we will not have access to your financial information except as those platforms make them available in order to process transactions.
b. Automatically collected information. Whenever you interact with our Services, we may automatically receive information from your browser or device that is generated or transmitted during your use. This may include your IP address, geolocation data, device identification, operating system, the name of your internet service provider, “cookie” information, the type of browser and/or device you’re using to access our Services, the page or feature you requested, and any other information that may be included as part of a standard request for a website.
“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of the Services.
4. Use of Collected Information. The data collected by Sophia is used in identifying and addressing user interests, communicating to users about the Services, personalizing users’ experience with the Services, and for operating, developing, and improving the Services. The data collected may also be preserved by Sophia for archival, restorative, or research purposes. For example, this data can tell us how often users use a particular feature of the Services, and we can use this knowledge to make the Services interesting to as many users as possible.
If you provide us with your email address, we may use that address to connect you with a therapist, doctor, or other healthcare professional whom we recommend through the Services, and to facilitate payment through our third-party payment provider. If you no longer wish to receive such emails, please indicate so by using the unsubscribe feature at the bottom of the email.
5. Disclosure of Information. Except as set forth in this Policy, Sophia does not share user information with third parties without the user’s consent. Nevertheless, some amount of information sharing is necessary in order for Sophia to provide and develop these Services. Sophia may disclose user information in the following circumstances:
a. Referral to Healthcare Professional. As part of our referral to a therapist, doctor, or other healthcare professional, we may share some of the information that you voluntarily disclose to us as provided in Section 3.a above with the healthcare professional. This may include your name or an abbreviation of your name, the general nature of the healthcare services you request, the answers to your referral questionnaire, your age, gender identity, availability, and how you intend to pay for your healthcare services. We do not share this information until you agree to a referral to the healthcare professional that we identify for you.
b. Third-Party Service Providers. As part of our provision of these Services, we work with other companies and people to perform tasks on our behalf. These third-party service providers may be granted access to your information as part of their ability to provide such services. Unless we tell you differently, we share your information with these third-party service providers only to the extent necessary to assist us in providing you the Services.
c. Data Analysis. Sophia may use, transfer, sell, and share aggregated, de-identified data derived from user information for any business purpose. For example, we may provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Services. If you are using the Services as part of an enterprise account that Sophia has with your employer, we reserve the right to share aggregated, de-identified data derived from users associated with this plan with your employer.
d. Business Transfers. If Sophia is acquired, goes into dissolution, enters bankruptcy, sells or transfers its assets to another company, or goes through some other change of control, Sophia may transfer any user information in its possession to the other company as a part of the transaction.
e. Legal Compliance. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with any court order, law, or legal process, including to respond to any government or regulatory request; enforce or apply our Terms of Service and other agreements, including for billing and collection purposes; or protect the rights, property, or safety of Sophia, our employees, our users, or others.
6. Security Disclaimer. We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
7. Age of Users. The Services are intended for persons who are at least 13 years old. Those between the ages of 13 and 18 may only use the Services under the supervision of their parent or guardian. If you are a parent or guardian using the Service on behalf of your child, you hereby agree to have your child’s data handled in the manner described in this Policy. If you are not at least 13 years old, you may not use the Services.