Effective Date: October 11, 2023
Table of Contents
- Introduction
- Contact Information
- Personal Data Collection & Usage
a. Account Data
b. Communications with Sintelly
c. Conversational Data
d. Concerning Language and Escalation Data
e. Hardware Diagnostic and Login Information
f. Survey and Assessment Data
g. Usage Data h. Note on Social Media Pages
- Sharing of Personal Data
a. Service Providers
b. Partner Programs
c. Interactions with Third-Party Services
d. De-Identified and/or Aggregated Data
e. Disclosures to Protect Us or Others
f. Transferring Personal Data Outside of the Country
g. Disclosure in the Event of Merger, Sale, or Asset Transfers
- Data Protection
- Data Retention
- User Rights
a. Right of Access
b. Right to Rectification
c. Right to Erasure
d. Right to Restrict or Object to Processing
e. Right to Data Portability
f. Right to Confidential Communications
g. Right to Limit Data Processing
h. Right to Receive Accounting of Disclosures
i. Right to Name a Personal Representative
j. Right to Withdraw Consent
k. Right to Receive a Paper Copy of this Privacy Policy
- User Control Over Personal Data
a. Requesting Personal Data
b. Opt-Out Options
c. Do Not Track (DNT)
d. Cookies and Similar Technologies
- User Responsibilities
- a. Safeguarding Personal Data
- b. Protecting Children’s Information
- c. Reading Third-Party Privacy Policies
- d. Reviewing this Privacy Policy Regularly
- Introduction
Sintelly is your companion on the journey to improved mental and emotional wellbeing. Sintelly is here to provide you with support, knowledge, and resources to help you navigate life’s challenges and enhance your overall sense of wellbeing while being dedicated to protecting and respecting your privacy. This privacy policy explains how we collect, store, use, and share personal data through our services, including the website, mobile application, and documentation (collectively referred to as the “Services”). The term “you” refers to the user of our Services. Sintelly manages your personal data as described below and in compliance with applicable laws. By using our Services, you acknowledge that you have read and understand this privacy policy.
- Contact Information
Sintelly is the controller of personal data processed under this privacy policy. For further information, to exercise your rights, or if you have any questions, please contact our Data Protection Officer at i[email protected].
- Personal Data Collection & Usage
Sintelly collects various types of personal data to provide, improve, and personalize our Services. The following sections detail the types of personal data we collect and how they are used:
a. Account Data Details:
- Email address
- Other personal data you provide to us, including any personal identifiers like your birthdate
- Password
- Personal data you’ve allowed one of our partners to share with us
- Referral or access code (if applicable)
- Time zone (from iOS and Android apps)
- What Sintelly should call you
How It Is Used:
- To provide our Services, including creating an account
- To improve our Services
- For identification and authentication purposes
- To address issues like malicious use of the Services
- To maintain and uphold your preferences
- To send you communications about our Services
- To invite you to participate in relevant user experience research
b. Communications with Sintelly (separate from conversational data)
Details:
- Email address
- Platform
- Operating system version
- Other personal data you provide to us, including any personal identifiers or attachments you share
How It Is Used:
- To provide our Services
- To improve our Services
- To invite you to participate in ad hoc opportunities, like product feedback
- To provide user support
- To invite you to participate in relevant user experience research
c. Conversational Data
Details:
- Your conversational interactions with Sintelly, like what you write or options you select during the conversation
How It Is Used:
- To provide our Services
- To improve our Services
d. Concerning Language and Escalation Data
Sintelly may detect certain inputs that may indicate you need more support than we can provide. Please note that Sintelly is not a crisis service.
Details:
- How often you share concerning language and confirm that Sintelly has understood you correctly
- If you share that you’re considering harming yourself or others in a clinical survey
How It Is Used:
- To suggest more appropriate resources
- To provide our Services
- To improve our Services
e. Hardware Diagnostic and Login Information
Details:
- Certain login information stored on your device
- Crash reports and system error logs
- Operating system, hardware, and browser version (if applicable)
How It Is Used:
- To provide our Services
- To improve our Services
- To invite you to participate in relevant user experience research
f. Survey and Assessment Data
Details:
- Surveys and assessments about your health or experiences
- Surveys about our Services (if applicable)
How It Is Used:
- To provide our Services, including to provide a personalized experience based on your responses
- To improve our Services
- To invite you to participate in relevant user experience research
- To share de-identified and/or aggregated data about Sintelly, like trends for marketing and business purposes
g. Usage Data
Details:
- Information from analytics vendors, like website visitor or app user behavior and demographics
- Internal analytics information
- Log files
- Mobile device, browser type, browser language, operating system, and Internet Protocol address
- Cookies, pixel tags, and web beacons
- Usage information, like the time of day or how often you use each tool
How It Is Used:
- To provide our Services
- To improve our Services, including to assess the performance of our Services
- To invite you to participate in relevant user experience research
- To share de-identified and/or aggregated data about Sintelly, like trends for marketing and business purposes
h. Note on Our Social Media Pages
Sintelly may maintain social media pages. Any personal data you share on the public sections of our social media pages is public and, unless otherwise required by applicable laws, is not covered by this privacy policy. Please exercise caution before sharing information that may identify you on the public sections of our social media pages. In addition, our Services may contain social media buttons to “Share Sintelly.” Use of, or sharing personal data with a social media service will also be subject to the social media service’s terms of service and privacy policy.
- Sharing of Personal Data
a. Service Providers
Sintelly uses third-party service providers, like Amazon Web Services, that assist us in providing our Services. These third parties may have limited and controlled access to personal data for the services they provide, such as hosting or customer service. The use of personal data by service providers outside the agreed-upon service they provide is prohibited.
b. Partner Programs
In the future, Sintelly may partner with organizations to conduct research studies or provide you with the Services through separate programs. Potential program partners may include employers, hospitals, providers, or other medical and academic partners. Your participation in partner programs will be optional and will require your agreement with our partner for any personal data to be shared.
c. Interactions with Third-Party Services
Our Services may link to third parties, like helplines or other resources. Any information shared with or otherwise collected by third parties is subject to the third party’s terms and privacy policy. We are not responsible for the processing of personal data by third parties relevant to these resources.
d. De-Identified and/or Aggregated Data
We may use your personal data to create de-identified and/or aggregated data, like approximate location information, information about the device you use to access our Services, information about conversational trends, or other analyses we create. We never share your transcripts with Sintelly without your consent, even de-identified.
e. Disclosures to Protect Us or Others
Sintelly may access, preserve, and disclose any personal data associated with you to external parties if we, in good faith, believe doing so is required or appropriate to:
- Comply with law enforcement or national security requests and legal processes, such as a court order or subpoena
- Protect you, us, or others’ rights, property, or safety
- Enforce our policies or contracts
- Assist with an investigation or prosecution of suspected or actual illegal activity
f. Transferring Personal Data Outside of the Country
Your personal data may be transferred, stored, and processed in one or more countries outside of the country you reside in or are currently located, which may have data protection laws that are different from the laws where you reside or are currently located. When processing personal data outside of the country you reside in or are currently located, we take additional steps in an effort to ensure our international transfer of personal data is consistent with applicable law.
If we transfer personal data that originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
If you have additional questions about our international transfers of personal data, please contact [email protected].
g. Disclosure in the Event of Merger, Sale, or Asset Transfers
If Sintelly is involved in a merger, acquisition, financial due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
- Data Protection
Sintelly uses commercially reasonable efforts to implement security measures designed to avoid accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data. These measures may include (as appropriate):
- Adherence to organization-level security policies and procedures to safeguard sensitive user data, complying with the applicable privacy and security regulations, including relevant privacy and security rules
- Using cloud-enabled infrastructure designed to reduce our data footprint
- Encrypting all personal data at rest and in transit
- Securing sensitive personal data in a dedicated environment in a manner designed to ensure segregation and clear access control
- Using technical network controls like multi-factor authentication and deny-all/allow-by-exception in a manner designed to maintain controlled access
- Conducting and responding to penetration tests, vulnerability assessments, code reviews, and internal compliance reviews
- Maintaining our business continuity, disaster recovery, and incident response plans
- Allowing employees to access personal data only if required in connection with their job duties
Despite these efforts, no security measures are perfect, and no method of data transmission or storage is guaranteed to prevent unauthorized disclosure or misuse. As a result, we cannot ensure or warrant the security of any personal data you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal data.
- Data Retention
Sintelly stores personal data so that your experience with the Services is personalized based on your past interactions and for other reasons listed above. We retain the personal data we collect for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. For more information about our data retention practices, please contact us at i[email protected].
- User Rights
As a user of Sintelly, you have certain rights regarding your personal data. Your rights may vary depending on your location, but they typically include the following:
a. Right of Access
You have the right to request access to the personal data we hold about you.
b. Right to Rectification
You have the right to request rectification of inaccurate personal data about you, including completion of incomplete personal data.
c. Right to Erasure
You have the right to request the deletion of your personal data, also known as the “right to be forgotten.” Please note that Sintelly may not be able to fulfill all erasure requests for reasons such as legal obligations.
d. Right to Restrict or Object to Processing
You have the right to request the restriction or objection to the processing of your personal data in certain situations.
e. Right to Data Portability
You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format.
f. Right to Confidential Communications
You have the right to request that we communicate with you about personal data in a confidential manner, such as by contacting you at an alternative address or phone number.
g. Right to Limit Data Processing
You have the right to limit the processing of your personal data for specific purposes when you contest the accuracy of the data, the processing is unlawful, or you need the data to establish, exercise, or defend a legal claim.
h. Right to Receive Accounting of Disclosures
You have the right to receive a list of instances in which we have disclosed your personal data for third-party direct marketing purposes.
i. Right to Name a Personal Representative
You have the right to designate an authorized agent to make a request on your behalf. To do so, you must provide us with written permission from the authorized agent.
j. Right to Withdraw Consent
If you have provided your consent to the processing of your personal data, you may withdraw your consent at any time.
k. Right to Receive a Paper Copy of this Privacy Policy
You have the right to receive a paper copy of this privacy policy.
Please contact our Data Protection Officer at [email protected] to exercise any of the rights listed above.
Please note that Sintelly may request verification of your identity when fulfilling requests related to your rights.
- User Control Over Personal Data
a. Requesting Personal Data
You can request a copy of your personal data that we have collected at any time. Please contact our Data Protection Officer at [email protected].
b. Opt-Out Options
You can always opt out of receiving communications from Sintelly. To opt out, please follow the instructions included in the email or notification you receive from us.
c. Do Not Track (DNT)
At this time, Sintelly does not respond to Do Not Track signals.
d. Cookies and Similar Technologies
Sintelly may use cookies or similar technologies for various purposes, including user authentication, analytics, and personalization. You can manage the use of these technologies in your browser settings. Please note that blocking some types of cookies may impact your experience with our Services.
- User Responsibilities
We value your privacy, and your cooperation is important to ensure the protection of your data and the data of others. As a user of Sintelly, please adhere to the following responsibilities:
a. Safeguarding Personal Data
You are responsible for safeguarding your account data and other personal information. Please take appropriate measures to protect your personal data, such as choosing strong and unique passwords and keeping your login information confidential.
b. Protecting Children’s Information
Sintelly is not intended for children under the age of 13. We do not knowingly collect or solicit personal data from children under 13. If you are a parent or guardian and believe that your child has provided us with personal data, please contact our Data Protection Officer at [email protected], and we will take appropriate steps to remove such data.
c. Reading Third-Party Privacy Policies
We strongly encourage you to read and understand the privacy policies of third-party services and resources you may access through our Services. Sintelly is not responsible for the processing of personal data by third-party services.
d. Reviewing this Privacy Policy Regularly
Sintelly may update this privacy policy to reflect changes to our data practices or for other operational, legal, or regulatory reasons. We will post the updated privacy policy on our website, and the revised policy will take effect immediately upon posting. You are encouraged to review this privacy policy regularly to stay informed about how we collect, use, share, and protect your personal data.
Sintelly Ltd may collect your personal data for several purposes, including:
- To provide and maintain the Services
- To notify you about changes to our Services
- To allow you to participate in interactive features of our Services when you choose to do so
- To provide customer support
- To gather analysis or valuable information so we can improve our Services
- To monitor the usage of our Services
- To detect, prevent, and address technical issues
- To fulfill any other purpose for which you provide it
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
- To provide you with notices about your account, including expiration and renewal notices
- To provide you with information, products, or services that you request from us
- To send you marketing and promotional materials
- In any other way we may describe when you provide the information
- For any other purpose with your consent
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
Data Retention Policy
Sintelly Ltd will retain your personal data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Sintelly Ltd will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Your Data Protection Rights Under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Sintelly Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data.
If you wish to be informed what personal data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
The right to access, update, or delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your personal data.
The right of restriction. You have the right to request that we restrict the processing of your personal data.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Sintelly Ltd relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Service Providers
We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used.
These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics from sharing information about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: Privacy Policy – Privacy & Terms – Google
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 concerned that your child has provided us with personal data, please contact us, and we will take steps to remove such information from our systems.
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service before the change becomes effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us by email: [email protected] or by visiting this page on our website: Privacy Policy – Sintelly.
