10 of 85 cards in Use & Processing
Use & Processing · Context
The User ID row lists performance of contract and legitimate interest as legal bases; it does not allocate each basis to a particular listed purpose.
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Performance of Contract
Legitimate Interest
Use & Processing · Company practice
You and your therapist can see messages and submitted worksheets; the therapist sees shared journals on opt-in. A licensed Clinical Operations therapist may review correspondence for quality assurance, such as care concerns. This section does not state a consent condition, while the later quality-monitoring example says “If you consent.” The policy does not expressly reconcile these formulations, so this analysis does not infer that all quality review is either unconditional or always requires separate consent. Trust and Safety or Legal teams may review specific accounts for suspected security, legal or fraud issues.
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You and your Therapist are able to see the messages you send, the worksheets you submit. Your Therapist can also see the journal entries you submit if you opt in to sharing journal entries.
A licensed Therapist who is employed as part of the BetterHelp Clinical Operations Team may review correspondence with your Therapist for quality assurance purposes.
In addition, our internal Trust and Safety or Legal teams may review correspondence for specific accounts if we have a reason to believe that there is a security, legal, or fraud issue occurring with that specific account.
If you consent, a licensed Therapist who is employed as part of the BetterHelp Clinical Operations Team may review correspondence with your Therapist for quality assurance purposes.
Use & Processing · User right or choice
European Area residents may object to direct marketing and continued processing based on consent. For legitimate-interest processing, give specific reasons: BetterHelp considers them but may continue for compelling legitimate grounds and says it will explain its decision. Objecting to some processing can affect service availability.
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You may object to your data being used for direct marketing. You may object to the continued use of your data in any circumstances where we rely upon consent as the legal basis for Processing it.
Where we rely upon legitimate interests as the legal basis for Processing your data, you may object to us continuing to Process your data, but you must give us specific reasons for objecting.
We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to Process your data, we may continue to do so. In that event, we will let you know the reasons for our decision. In some instances, objecting to certain Processing may impact our ability to provide you with services.
Use & Processing · Restriction or exception
The definition limits provider data use to contracted services or reasonably necessary legal/regulatory/process compliance, fraud/security prevention, debugging and internal technological research/demonstration of BetterHelp products/services. Research must be reasonably necessary and proportionate to the data-sharing purpose. Directed processing and restricted onward disclosure to bound subcontractors remain applicable.
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Data that is Processed on our behalf is required to be done only at our direction - no other person or company can authorize it.
The data obtained by Service Providers from their relationship with us must only be used for performing the services specified in our agreement with them, or as reasonably necessary to perform one or more of the following:
Comply with applicable law, regulation, or legal process;
Detect, prevent or mitigate fraud or security vulnerabilities;
Debug to identify and repair errors impairing existing intended functionalities; and/or
Conduct internal research for technological development and demonstration of our products or services, if such use is reasonably necessary and proportionate to achieve the purpose for which the data was shared.
Use & Processing · Company practice
BetterHelp processes data to operate the platform and send service messages. Marketing communications depend on applicable law and can be opted out of at any time. Third-party advertising processing and sharing requires opt-in. The collected data depends on use and, in the US, insurance versus subscription membership. Therapy Data includes health and treatment information needed for therapy. The advertising-sharing rule excludes activity while logged in after therapy starts and/or PHI. Advertising opt-in still excludes retargeting and sharing member names/phones, diagnoses, questionnaire answers or private therapist communications with Third Party advertisers.
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Other times, if permissible under applicable law, they are to provide marketing communications. You can opt out of receiving texts or marketing communications at any time. Additionally, provided you opt in, we may Process and share some data with Third Parties2 for advertising purposes.
What data we Process depends on how you're using our website, app, or the Platform and, if you are in the US, whether you are an Insurance Member or Subscription Member.
As highlighted in the table below, we collect and Process “Therapy Data“, which includes health and treatment information that is required to facilitate therapy.
If you opt in to Advertising cookies and web beacons (previously "Targeting cookies") some Visitor Data, excluding activity when you're logged in and have started therapy and/or PHI, may be shared for advertising purposes.
Even if you do opt in, we still do not engage in "retargeting" advertising.
Even if you opt in to Advertising cookies and web beacons, we still don't share information with Third Party advertisers like Member names, phone numbers, clinician diagnosis, questionnaires answers, sessions data, journal entries, messages, worksheets, or any other type of private communication you have with your Therapist on the Platform.
Use & Processing · Company practice
The unique sequential user ID is needed for platform operation. Its listed uses span therapy connection and tools, communications, quality monitoring, personalization and product improvement, legal compliance, safety, service promotions/reminders and platform security.
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We assign each user (including Therapists) who create an account a sequentially-generated user ID. User IDs are unique to each account and are required in order to enable the Platform to function.
Connecting you with therapy services
Facilitating therapy tools for you and your Therapist
Communicating with you
Monitoring and improving therapy quality
Personalizing your web or app experience
Helping us understand how you use our services, how we can improve our products and services to make them more effective and convenient, and offer you new features
Complying with laws
Protecting your safety and the safety of others
Send opportunities, promotions, news, updates and reminders about our services and your account
Monitor and protect the security of the Platform
Use & Processing · Company practice
For therapists and recruits, BetterHelp may process therapist, quality, engagement, user-ID, onboarding and account-registration data to recruit/onboard, operate and match clients based on preferences, facilitate communication, verify identity and secure accounts, run credentialing checks, pay and comply with tax laws, provide statistics and feedback, and send opportunities, reminders and updates by email, calls or SMS. The stated bases are legitimate interest, contract and consent.
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If you're a Therapist on our Platform, or being recruited to join us, in addition to the above, we may Process Therapist Data, Therapy Quality Data, Therapist Engagement Data, User ID, Onboarding Data, Account Registration Data to:
Assist in the Therapist recruitment process and onboard you to the Platform;
Operate the Platform, match clients to you based on your preferences, and facilitate the communication between you and your clients;
Verify your identity and secure your account;
Run background checks and other screening required for credentialing and re-credentialing purposes;
To pay you and comply with all relevant tax laws;
Provide you quality statistics, feedback from our BetterHelp Clinical Operations team, and feedback from clients.
Offer you information about new features, opportunities, perks and other incentives.
Send you email, calls or SMS reminders, notifications & updates about your application, profile or account.
The legal basis for processing the above data for Therapists on our Platform (or for the purposes of recruiting them) are legitimate interest, performance of a contract, and consent.
Use & Processing · Company practice
BetterHelp uses AI and natural-language-understanding algorithms alongside human processing to develop and support services, including detecting security risks, assisting support agents and helping therapists manage/document sessions. It says models are reviewed thoroughly or built internally, and Therapy Data such as session data, journals, messages and worksheets is not used to train AI/NLU models unless you agree otherwise. This is a training restriction, not a promise of no AI processing.
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We use Artificial Intelligence (AI) and Natural Language Understanding (NLU) algorithms to support and develop features to provide you services and improve the quality of the services.
For example, we may use AI features to detect security risks, synthesize information for customer service agents, and help therapists manage and document sessions more effectively.
To help ensure these tools remain fair and accurate, as well as protect the privacy of our Members and Therapists, we either thoroughly review a model or build it internally and, unless you agree otherwise, do not use any Therapy Data, such as sessions data, journal entries, messages, worksheets, or any other type of private communication you have with your Therapist in a session to train an AI or NLU model.
Use & Processing · Company practice
BetterHelp facilitates information sharing with the therapist and uses preferences, state and country to suggest a therapist according to licensing/accreditation requirements. After therapy starts, it processes data to enable journals, goals and worksheets. Communication processing supports answering platform questions; Business teams may contact organizational representatives professionally to service their organization’s account.
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We also Process data like your Therapist preferences, your state (if applicable), and your country to determine what Therapist to suggest to you based on applicable licensing or accreditation requirements.
Once you start therapy, we need to process certain data to enable therapy tools within the Platform such as journal entries, setting goals and providing relevant worksheets.
For example, we need to make sure that if you ask a question or have a concern about the Platform, we're able to respond to you and provide an answer.
Additionally, if you represent an organizational customer, such as a business or nonprofit, then the BetterHelp Business team may contact you in your professional capacity to service your organization's account, answer questions, and provide support.
Use & Processing · Company practice
Examples of personalization include matching LGBTQ+ members who request relevant expertise with an appropriate therapist, and recommending anxiety-related content/features when a member seeks anxiety support. These are examples of using supplied preferences/needs, not a claim that every user is assigned those characteristics.
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For example, if you identify as a Member of the LGBTQ+ community and would prefer a Therapist who has relevant expertise, experience, and training to provide therapy services for LGBTQ+ Members, we Process information to allow us to match you with an appropriate Therapist that can meet these needs.
Another example is if you state that you would like help with anxiety, we may recommend content and features that would be helpful to you, such as anxiety-related group sessions.