We at Jimini Health, Inc. (“Jimini Health,” “we,” “us,” or “our”) are committed to protecting the privacy of your personal data. This Privacy Policy explains how we process personal data collected through the Jimini Health website and mobile application available in the app stores (together, the “Platform”) as well as all relevant content and functionality associated with the Platform.

This Privacy Policy does not apply to “protected health information” that is subject to the Health Insurance Portability and Accountability Act (“HIPAA”) that we collect on behalf of Jimini Health Psychotherapy, P.C. and Jimini Health Psychology Professional Corporation (collectively, “Jimini Health Group”). We handle protected health information in accordance with the Jimini Health Group Notice of Privacy Practices and our agreements with Jimini Health Group. Please review the Jimini Health Group Notice of Privacy Practices for more information.

Privacy Policy Updates
We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates.

Contact Us
If you have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact us at support@jiminihealth.com. We appreciate your feedback.

1. Sources of Personal Data

We collect personal data about you from the following sources:

• Directly from you. For example, we may collect personal data from you when you contact us through the Platform, communicate with us, or sign up for an account.
• Automatically and through tracking technologies. For example, we may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with the Platform. This may include information about how you use and interact with the Platform, information about your device, and internet usage information.
• From third parties. We may collect personal data from third parties, such as service and content providers, business partners, social media companies, or other parties who interact with us.

We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use and disclose the combined information for the purposes identified below.

2. Personal Data We May Collect

We may collect the following types of personal data:

• Identifiers, such as your name, email address, physical address, telephone number, other business contact information, and device identifiers (e.g., cookie IDs and IP address).
• Demographic information, such as age (including birthdates) and gender.
• Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Platform. For more information about cookies and other device data, please see Section 5 (Cookies and Other Tracking Technologies).
• Non-precise geolocation data, such as your approximate location based on your IP address.
• Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
• Sensitive personal data, such as information about your health.

3. How We Use Your Personal Data

We may use personal data for the following purposes:

• To provide the Platform to you;
• To fulfill our obligations to you under the Terms of Use;
• To communicate with you about and manage your user account;
• To provide announcements and communicate with you, including for marketing purposes
• To properly store and track data within our Platform;
• To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings and court orders;
• To protect our rights, privacy, safety, or property, and/or that of you or others by providing proper notices, pursuing available legal remedies, and acting to limit our damages;
• To handle technical support and other requests from you;
• To address any complaints;
• To enforce and ensure your compliance with our Terms of Use or the terms of any other applicable services agreement we have with you;
• To manage and improve the Platform, including the development of additional functionality;
• To support machine learning model training and analytics;
• To analyze how the Platform is being used so we can improve the Platform and the user experience;
• To evaluate the success of our marketing campaigns;
• To manage payment processing;
• To evaluate and control quality of the Platform, identify usage trends, and improve your user experience;
• To find and prevent fraud, and keep the Platform safe and secure;
• To send you information about changes to our terms, conditions, and policies;
• To conduct research and analysis (for additional information see below), internally and with approved research partners, using your information, which may be subject to your separate written authorization;
• To report permissive reporting of expressed threats of violence towards an ascertainable victim;
• To allow us to pursue available remedies or limit the damages that we may sustain; and
• For other purposes for which we provide specific notice at the time the information is collected.

4. How We May Disclose Personal Data

We may share your personal information with the following categories of individuals/entities:

• Providers: Jimini Health will make your personal data available to its affiliated healthcare therapists and providers (“Providers”) for the purposes of providing the Services, and to oversee and direct your mental health care.
• Service Providers: We share personal data with a limited number of partners, service providers, and other persons/entities who help run our business (“Service Providers”). Specifically, we may employ third-party companies and individuals to facilitate our Services, provide Services on our behalf, perform Service-related functions, or assist us in analyzing how our Services are used and improve the Platform and user experience. Our Service Providers are contractually bound to protect your personal data and to use it only for the limited purpose(s) for which it is shared. Service Providers’ use of personal data may include, but is not limited to, the provision of services such as data hosting, IT services, customer services, order fulfillment, and payment processing.
• Business Partners: We share non “protected health information” personal data with business partners, including advertisers, ad platforms, and networks, social media platforms, third parties whose cookies and other tracking technologies we use (see the “Cookies and Other Tracking Technologies” section below for more details), and partners who work with us on promotional opportunities. These Business Partners may use personal data we share with them for their own purposes. Where required by law, we will obtain your consent prior to disclosing your personal data to our business partners. Where recipients use your personal data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.
• Our Advisors: We may share your personal data with third parties that provide advisory services to Jimini Health, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively, “Advisors”). personal data will only be shared with Advisors if Jimini Health has a legitimate business interest in the sharing of such data.
• Third Parties Upon Your Direction or Consent: You may direct Jimini Health to share your personal data with third parties. Upon your request and consent, we may share such personal data with those third parties that you identify.
• Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Jimini Health’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may share your personal data with a third party.
• Government and Law Enforcement Authorities: If reasonable and necessary, we may share your personal data to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Privacy Policy or the Terms of Use; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of Jimini Health or any third party, including other users of our Services.

5. Cookies and Other Tracking Technologies

Jimini Health and authorized third parties may collect personal data using the following tracking technologies:

• Cookies are small files that a web server sends to your computer or device when you visit a web application that uses cookies to keep track of your activity on that site. Cookies also exist within applications when a browser is needed to view or display certain content within the application. Cookies hold a small amount of data specific to a web application, which can later be used to help remember information you entered in the application (like your email or username), preferences selected, and movement within the application.
• Pixels, web beacons, and tags are types of code or transparent graphics. In contrast to cookies, which are stored on a user's computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages or emails.
• Session replay tools record your interactions with our Services, such as how you move throughout our Platform and engage with our webforms.
• Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences on the Platform.

We use cookies and other technologies to, among other things, personalize your experience using our Services, better serve you with more tailored information, analyze how our Services are used, conduct advertising, provide you with offers and online content that may be of interest to you, measuring the effectiveness of advertising campaigns, and to facilitate efficient and secure access to the Services.

We may disclose information to third parties or allow third parties to directly collect information using these technologies, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Platform.

The analytics services we use may include but are not limited to: Google Analytics, Squarespace, and Meta. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners.

Your Choices Regarding Cookies and Other Tracking Technologies

If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. If you configure your browsers to prevent us from collecting cookies, you will need to reenter your login information each time you visit the login page. You may also be unable to take advantage of some of the Services.
Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. We adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You may also click on the AboutAds icon on a Company advertisement and follow the instructions on how to opt out.

Do Not Track Disclosure

Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. At this time, Jimini Health does not support or honor DNT signals.

6. Data Security and Retention

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.

Your personal data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your personal data to provide you with the products and services requested and interact with you; maintain our business relationship with you; improve the Platform and our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you terminate your relationship with us, we may retain your personal data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, in order to demonstrate our business practices and contractual obligations, or to provide you with information about our products and services in case of interest.

7. Updating Your Information and Deleting Your User Account

You may change your email address and other contact information by contacting us at support@jiminihealth.com.
You may delete your user account entirely, you may do so by emailing support@jiminihealth.com. By terminating your user account, you agree that you will not be able to access any information previously contained in your user account. You further understand that it may not be technologically possible to remove all of your personal data from our systems. While we will use reasonable efforts to remove your personal data, the need to back up our systems to protect information from inadvertent loss means a copy of your personal data may exist in a non-erasable form that will be difficult or impossible for us to locate or remove. We may also need to retain personal data as required by law.

8. Children's Privacy

The Platform is intended for individuals 18 years of age and older. The Platform is not directed at, marketed to, nor intended for, children under 18 years of age. As a general rule, we do not knowingly collect any information, including personal data, from children under 18 years of age. If you believe that we have inadvertently collected personal data from a child under the age of 18, please contact us and we will take prompt steps to delete the information.

9. External Links

The Platform may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

10. California Shine the Light

If you are a California resident, you may opt out of sharing your personal data subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties’ direct marketing purposes by emailing us at support@jiminihealth.com.