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Privacy Policy

Journey Starts Here LLC, on behalf of itself and its affiliates/group companies (“Journey”), is
the author and publisher of the internet resource WWW.[] and the mobile application [ ]
(together, “Website”).

1. Nature And Applicability of Terms

Please carefully go through these terms and conditions (“Terms”) and the privacy policy
available at https://www.________________________ (“Privacy Policy”) before you decide to
access the Website or avail the services made available on the Website by Journey. These Terms
and the Privacy Policy together constitute a legal agreement (“Agreement”) between you and
Journey in connection with your visit to the Website and your use of the Services (as defined
below).
The Agreement applies to you whether you are -
i. A mental health professional or other mental care provider or other professionals in
the mental health or wellness fields wishing to be listed, or already listed, on the
Website, including designated, authorized associates of such practitioners or
institutions (“Professional(s)”, “you” or “User”); or
ii. A person, his/her representatives or affiliates, searching for Professionals through the
Website (“End-User”, “you” or “User”); or
iii. Otherwise a user of the Website (“you” or “User”).
This Agreement applies to those services made available by Journey on the Website, which are
offered free of charge to the Users (“Services”), including the following:
iv. For Professionals: Listing of Professionals and their profiles and contact details, to be
made available to the other Users and visitors to the Website;
v. For other Users: Facility to (i) create and maintain ‘Accounts/Profiles’, (ii) search for
Professionals by name, specialty, and geographical area, or any other criteria that
may be developed and made available by Journey, (iii) to make appointments with
Professionals and (iv) make testimonials about their experience using the Website
and/or the relevant Professionals.

The Services may change from time to time, at the sole discretion of Journey, and the Agreement
will apply to your visit to and your use of the Website to avail the Service, as well as to all
information provided by you on the Website at any given point in time.
This Agreement defines the terms and conditions under which you are allowed to use the Website
and describes the manner in which we shall treat your account while you are registered as a
member with us. If you have any questions about any part of the Agreement, feel free to contact us at support@Journey.com.

By downloading or accessing the Website to use the Services, you irrevocably accept all the
conditions stipulated in this Agreement, and Privacy Policy, as available on the Website, and
agree to abide by them. This Agreement supersedes all previous oral and written terms and
conditions (if any) communicated to you relating to your use of the Website to avail the Services.
By availing any Service, you signify your acceptance of the terms of this Agreement.
We reserve the right to modify or terminate any portion of the Agreement for any reason and at
any time, and such modifications shall be informed to you in writing You should read the
Agreement at regular intervals. Your use of the Website following any such modification
constitutes your agreement to follow and be bound by the Agreement so modified.
You acknowledge that you will be bound by this Agreement for availing any of the Services
offered by us. If you do not agree with any part of the Agreement, please do not use the Website
or avail any Services.
Your access to use of the Website and the Services will be solely at the discretion of Journey.

2. Conditions of Use

You must be 18 years of age or older to register, use the Services, or visit or use the Website in
any manner. By registering, visiting and using the Website or accepting this Agreement, you
represent and warrant to Journey that you are 18 years of age or older, and that you have the right,
authority and capacity to use the Website and the Services available through the Website, and
agree to and abide by this Agreement.
The Professionals are independent providers who are neither Journey’s employees nor agents nor
representatives. The Website's role is limited to enabling the Services. The Professionals
themselves are responsible for the performance of the services they offer (“Professional
Services”). If you feel the Professional Services provided by the Professional do not fit your
needs or expectations, you may change to a different Professional who provides similar
Professional Services. While we have a large database of Professionals, you should note that
because of licensure requirements that differ from jurisdiction to jurisdiction, not all Professionals
available on our database will be available for you to match with, or at any particular time, or for
any set period of time.
While we hope the Professional Services are beneficial to you, you understand, agree and
acknowledge that they may not be the appropriate solution for everyone's needs and that they may
not be appropriate for every particular situation and/or a substitute for certain mental health
needs.
IF YOU ARE THINKING ABOUT SUICIDE OR IF YOU ARE CONSIDERING HARMING
YOURSELF OR OTHERS OR IF YOU FEEL THAT ANY OTHER PERSON MAY BE IN
ANY DANGER OR IF YOU HAVE ANY MEDICAL EMERGENCY, YOU MUST
IMMEDIATELY CALL YOUR LOCAL EMERGENCY SERVICES NUMBER AND NOTIFY
THE RELEVANT AUTHORITIES. THE WEBSITE IS NOT DESIGNED FOR USE IN ANY
OF THE AFOREMENTIONED CASES.
END-USERS AND PROFESSIONALS AGREE THAT BY MAKING AN APPOINTMENT OR
ACCEPTING AN APPOINTMENT OR SOLICITING/OFFERING PROFESSIONAL
SERVICES (AS THE CASE MAY BE), A DIRECT CONTRACT (AND THEREFORE LEGAL
RELATIONSHIP) IS CREATED SOLELY BETWEEN THE RELEVANT END-USER AND
THE PROFESSIONAL AND JOURNEY IS NOT PARTY TO THIS LEGAL RELATIONSHIP
IN ANY WAY WHATSOEVER.

3. Terms of Use Applicable to All Users Other Than Professionals

The terms in this Clause ‎3 are applicable only to Users other than Professionals, except as
expressly otherwise provided.

3.1 End-User Account and Data Privacy

3.1.1. The terms “personal information” and “sensitive personal data or information” are
defined under the UK Data Protection Act 2018, the Protected Health Information of
the United States of America which is subject to Health Insurance Portability and
Accountability Act (HIPAA) Privacy Rule and Electronic Communications Privacy
Act (ECPA), and are reproduced in the Privacy Policy.
3.1.2. Journey may by its Services, collect information relating to the devices through
which you access the Website, and anonymous data of your usage. The collected
information will be used only for improving the quality of Journey’s services and to
build new services.
3.1.3. The Website allows Journey to have access to registered Users’ personal email or
identification documents, for communication purpose so as to provide you a better
way of booking appointments and for obtaining feedback in relation to the
Professionals and their practice.
3.1.4. The Privacy Policy sets out, inter-alia:

i. The type of information collected from Users, including sensitive personal
data or information;
ii. The purpose, means and modes of usage of such information; and,
iii. How and to whom Journey will disclose such information.

3.1.5. The User is expected to read and understand the Privacy Policy, so as to ensure that
he or she has the knowledge of, inter-alia:
i. the fact that certain information is being collected;
ii. the purpose for which the information is being collected;
iii. the intended recipients of the information;
iv. the nature of collection and retention of the information; and
v. the name and address of the agency that is collecting the information and
the agency that will retain the information; and
vi. the various rights available to such Users in respect of such information.
3.1.6. Journey shall not be responsible in any manner for the authenticity of the personal
information or sensitive personal data or information supplied by the User to Journey
or to any other person acting on behalf of Journey.
3.1.7. The User is responsible for maintaining the confidentiality of the User’s account
access information and password, if the User is registered on the Website. The User
shall be responsible for all usage of the User’s account and password, whether or not
authorized by the User. The User shall immediately notify Journey of any actual or
suspected unauthorized use of the User’s account or password. Although Journey will

not be liable for your losses caused by any unauthorized use of your account, you
may be liable for the losses of Journey or such other parties as the case may be, due
to any unauthorized use of your account.
3.1.8. If a User provides any information that is untrue, inaccurate, not current or
incomplete (or becomes untrue, inaccurate, not current or incomplete), or Journey has
reasonable grounds to suspect that such information is untrue, inaccurate, not current
or incomplete, Journey has the right to discontinue the Services to the User at its sole
discretion.
3.1.9. Journey may use such information collected from the Users from time to time for the
purposes of debugging customer support related issues.
3.1.10. You have the option to call Journey on the number displayed on the Website, and the
records of such calls may be recorded and stored in Journey’s servers. Such records
may be accessed by Journey for quality control and support related purposes and are
dealt with only in accordance with the terms of the Privacy Policy. Such call facility
provided to you by Journey should be used only for general inquiry purposes in
relation to the Services and the use of the Website, and not for consultation on mental
health-related issues. Journey accepts no liability if the call facility is not used in
accordance with the foregoing.

4. 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.

5. 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.

6. 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.

7. 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.

8. 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.

9. 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.

10. 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

11. 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.

12. 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.

13. 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.

14. 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.

15. 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.

16. 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.

17. 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.