Third-party sharing and live-session recording have consent limits
The policy says therapist messages are not shared with a defined Third Party and live sessions are not recorded unless you expressly consent; message/session timing is also not shared with a Third Party. Its definition excludes service providers, therapists and other specifically named parties, so this is not a promise that nobody else can access correspondence. Internal quality/safety review and legally required disclosures remain separately described.
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Messages with your Therapist are not shared with any Third Party2, and your live sessions are not recorded, unless you expressly consent. We also do not share when you send a message, or have a session with your Therapist, with any Third Party.
For the purposes of this Policy, a Third Party means an entity that is not BetterHelp, not a Service Provider, not a Therapist or any other parties that are specifically called out in this Policy.
Your data may be shared to comply with applicable laws.
Qualifications & exceptions
Third Party is a defined, limited class; internal review and legal disclosure provisions still apply.
Cross-references
contrast (model-proposed): Therapy correspondence can be reviewed internally, with differing consent language — Promises limiting defined Third Party sharing coexist with internal review of therapy correspondence. These are different recipients; the quality-review passages’ differing consent language is disclosed, not resolved into a universal rule.
California readers can decline advertising-cookie sale sharing
The notice says readers need not opt into a sale of their personal information and points to withdrawing advertising-cookie consent through the opt-out page. It also says the websites are designed to implement a do-not-sell privacy preference. It does not identify a specific browser signal or promise a particular implementation here.
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As noted above, you do not need to opt in to the “sale” of personal information about you by withdrawing your consent to accept cookies used for advertising here. Our websites are also designed to implement a do-not-sell privacy preference.
Not stated here
The linked opt-out page is not supplied; a specific preference-signal protocol and detailed steps are not stated here.
Sharing & Disclosure · Company practice
EU data goes to US servers; other transfers require safeguards or derogations
BetterHelp says EU data is transferred to US servers on its EU-US Data Privacy Framework certification. It may also transfer data to organizations in countries without a GDPR adequacy decision, using appropriate safeguards such as standard contractual clauses or specific derogations, with contract necessity and informed specific consent given as examples. The statement of certification is the policy’s own, not an independent verification.
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We transfer data from the EU to the U.S because our servers are located in the US.
The legal basis for this transfer is the EU-U.S. Data Privacy Framework (DPF), which has been recognized by the European Commission as providing adequate protection for personal data transferred to participating US companies.
Our company is certified under this framework
Additionally, we may transfer your data to organizations based in countries that have not been granted an adequacy decision under the General Data Protection Regulation.
Where data is transferred to such countries, we shall ensure that appropriate safeguards are used to do that (such as by using standard contractual clauses with those vendors) or specific derogations have been established (for example where the data transfer is necessary in order to fulfill a contract between us and yourself, where we have received your specific consent after having made you aware of any risks involved, etc).
Qualifications & exceptions
Transfers to countries without adequacy require safeguards or established derogations.
Sharing & Disclosure · Company practice
The non-US/UK/EU notice describes predominantly US processing
The supplementary notice for residents outside the US, UK and EU says data is transferred out of many visitors’ home countries and predominantly used, accessed and processed in the US. BetterHelp considers its safeguards substantially similar to or exceeding non-US privacy requirements, cites DPF certification and says specific safeguards are established for vendors outside the US. This is the company’s assessment, not a finding of equivalent protection everywhere.
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As a part of our standard business practices, data is transferred outside of many visitors' countries of residence and predominantly used, accessed and processed within the U.S.
BetterHelp considers that this has the effect of protecting user information in a way that, overall, is at least substantially similar or in many ways exceeds non-US data privacy legal requirements.
To the extent we contract with vendors who are outside of the U.S, we ensure that specific safeguards have been established to protect that data.
Sharing & Disclosure · User right or choice
Therapist profiles may be promoted through an optional Profile Boost program
Profile Boost shares the client-facing therapist profile with Google Search Ads and directory partners to drive prospective clients to that profile. Therapists can opt out at any time; details and a self-service opt-out are on the Expertise and Preferences page of their dashboard after signup.
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The Profile Boost Program is an optional feature which shares the client-facing profile of BetterHelp Therapists with Google Search Ads and Directory partner websites, for the purpose of driving users to your profile and bringing you new clients. This Program is optional, and Therapists may opt-out at any time.
Additional information about the Profile Boost Program, and the self-serve opt-out feature, is available on the Expertise and Preferences page of your Therapist Dashboard once you sign-up.
Sharing & Disclosure · Restriction or exception
Opt-in advertising sharing excludes post-therapy logged-in activity and PHI
BetterHelp shares operational data with service providers and certain data with third parties when sharing is opted into. Its advertising-cookie/web-beacon rule permits some Visitor Data to be shared for advertising on opt-in, excluding activity while logged in after starting therapy and/or PHI. This is narrower than a permission to share all user data. 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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In addition to processing, we also share some data with Service Providers12 in order for us to operate the Platform and to perform necessary website and application functions. Additionally, when you opt into sharing, we share certain data with Third Parties.
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.
Qualifications & exceptions
Advertising opt-in does not permit retargeting or disclosure of listed member and therapist-private information to advertisers.
Applicable law may require disclosure, generally with therapist decisions on therapy records
BetterHelp may share data to comply with applicable law, such as subpoenas. As a general rule it defers to the chosen therapist on producing psychotherapy notes or messages, and encourages early discussion of disclosure obligations. This is not an absolute confidentiality promise or a statement that every request requires production.
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Your data may be shared to comply with applicable laws.
Keep in mind that, as a general rule, we defer to your chosen Therapist to decide to produce (or not produce) any psychotherapy notes or messages you have had with them.
Qualifications & exceptions
Deferral to the therapist is described as a general rule.
Selected parent-company employees may handle data for support
A select number of parent-company employees may occasionally handle data for support, under strict confidentiality duties. An example is routing subpoenas or legal correspondence to BetterHelp’s legal team.
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Occasionally, your data may be handled by a select number of employees who are part of our parent company for support services. These employees are under strict duties of confidentiality.
Sharing & Disclosure · Company practice
Service providers receive data to operate and support the platform
BetterHelp may share certain data for limited operational services: hosting such as AWS, audio/video/group tools, customer support, email communications, marketing agencies, billing/payments such as Stripe, analytics, advisers/lawyers and safety/security. Stripe may receive therapist email, name and tax-ID information for payments and tax documents. Providers are described as using data only at BetterHelp’s direction and disclosing identifiable data only to BetterHelp or their own subcontractors bound to processing terms no less restrictive. These restrictions distinguish provider marketing work from optional third-party advertising sharing. The definition also permits reasonably necessary legal compliance, fraud/security prevention and debugging, plus internal technological research/demonstration that is reasonably necessary and proportionate to the sharing purpose.
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Supporting quotations
that provide limited services that help us operate the Platform. Examples include:
Data hosting and storage providers: For example, cloud hosting providers such as Amazon Web Services (AWS).
Technology Service Providers: For example, we sometimes integrate tools into our Platform which give our Platform more functionality, like technology that helps us provide live audio, video and group meetings.
Customer Service Providers: For example, we use a tool that helps keep track of requests and questions from our Members, visitors and Therapists in a secure way.
Email management and communication Service Providers: For example, we may use a tool that makes reaching out to you easier for us and more convenient for you.
Remember that Service Providers can only legally use data at our direction - no other person or company can authorize how they use it and they cannot disclose data that is individually identifiable to any other person or company, other than to us or the Service Providers' own subcontractors provided that they're bound to data Processing terms that are no less restrictive than the Service Provider's terms.
Marketing and advertising Service Providers: For example, we may partner with an agency to run a marketing campaign or to help us better understand how to run our own campaigns to reach more people who may be interested in starting therapy.
Stripe also assists us in paying Therapists and issuing tax documents to them. For this purpose, we may share email addresses of Therapists with Stripe and other data that is needed to pay Therapists such as a Therapist's name and tax ID.
Reporting and analytics Service Providers: For example, we might use a service to help us keep track of which pages and features are most used on our site.
Advisors and lawyers: To assist with business matters.
We may share some of your data with Service Providers to ensure the safety and security of the Platform and that of our users.
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.
Qualifications & exceptions
Providers are limited to directed use, with restricted onward disclosure to bound subcontractors.
Therapist information may go to recruiters, health plans and credentialing vendors
For therapists or recruits, certain data may be shared with recruiters to manage recruitment. For platform therapists, volunteered profile and professional information may also go to insurance payors/health plans for contracting and to vendors that certify or streamline credentialing.
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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 share certain data with Therapist recruiters in order to facilitate, monitor, and track the recruitment process.
If you are a Therapist on our Platform, we may also share certain data such as information you volunteer in or through the Platform including, but not limited to, your name, photograph, NPI (if applicable), information about your credentials, experience, specialties and qualifications with insurance payors or health plans for the purposes of contracting with them.
We may also share this information with vendors that accreditate/certify our therapist credentialing processes and otherwise help us streamline the credentialing process.
Sharing & Disclosure · Company practice
Organizations may receive group usage; EAP individual sharing requires consent
For members using an employer, organization or business-partner arrangement, BetterHelp may share group-level usage that cannot be directly connected to the member. For members using an EAP, the EAP provides notice of individual data shared with it where the member has consented. The policy directs questions about the EAP’s use to the EAP.
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For Members who receive services in connection with an employer, organization, or other business partner, we may share group-level usage data, which cannot be directly connected to you, with your organization.
In the instance of Members who receive services through an Employee Assistance Program ("EAP"), your EAP will provide notice for any individual-level data which is shared with the EAP, if you are utilizing one and have provided them with consent for us to do so.
Sharing & Disclosure · Permission or license
Data may be shared in a sale, merger or bankruptcy
BetterHelp may share some data in connection with an asset sale, merger or bankruptcy. Insurance-member PHI is separately limited to NPP purposes in accordance with HIPAA.
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We may share some of your data in connection with an asset sale, merger or bankruptcy.
For Insurance Members: If you are an Insurance Member, your PHI will only be shared for the purposes outlined in the NPP in accordance with HIPAA.
Qualifications & exceptions
Insurance-member PHI follows the NPP/HIPAA limitation.
Not stated here
The linked NPP is not supplied; its permitted PHI-sharing purposes cannot be itemized here.
Sharing & Disclosure · Restriction or exception
Public platform information can be seen and used by anyone
If you make information publicly available on the platform, such as a public post, anyone may see and use it. This statement concerns information you make public, not all private therapy communications.
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Note that if you make any information publicly available on the Platform, such as with a public post, anyone may see and use such information.
Sharing & Disclosure · Company practice
Opt-in analytics uses trusted providers to analyze service interactions
On analytics opt-in, BetterHelp may use cookies and other tracking technologies to share data with trusted service providers for traffic sources, visits and interactions to improve services. This is distinct from optional third-party advertising.
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If you opt in to "Analytics (previously "Performance cookies")", we may use analytics cookies and other tracking technologies to share your data with trusted Service Providers that assist us to Process1 data for activities including but not limited to analyzing traffic sources, visits, and site interactions. This analysis helps us to improve our products and services.
Sharing & Disclosure · Company practice
Advertising on third-party properties uses opt-in visitor data with exclusions
BetterHelp advertises on third-party sites and apps. If advertising cookies/web beacons are opted into, some Visitor Data may be shared for advertising, excluding activity while logged in after therapy starts and PHI; users may consequently see BetterHelp ads elsewhere. The website-activity rule likewise excludes logged-in activity after therapy starts. 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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If you opt in to "Advertising (previously "Targeting cookies")" information regarding your activity on our websites, excluding activity when you're logged in and have started therapy, may be shared for advertising purposes.
In order to reach people who may be looking for mental health support, we advertise on some Third Party2 web properties such as Third Party websites and apps.
Therefore, if you opt in to Advertising cookies and web beacons, some Visitor Data, excluding activity when you're logged in and have started therapy and PHI, may be shared for advertising purposes. As a result, you may see ads for our services on some Third Party websites.
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.
Qualifications & exceptions
The activity exclusion applies when logged in after therapy has started; PHI is excluded as stated.
No payment for data can still involve a California-law sale
BetterHelp says nobody pays it for data. It explains that California’s broad sale definition can include exchanges for things of value, so opted-in advertising cookies/web beacons may count as a sale under that law. The statement does not promise no legally defined sales.
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We aren't paid by anyone for any data. However, in California, the laws define "sale" broadly to include the sharing of personal information in exchange for anything of value. If you opt in to our use of Advertising cookies and web beacons, this use may be considered a "sale" of personal information under that specific California law.
Cross-references
contrast (model-proposed): Advertising opt-in still excludes retargeting and private therapist information — The policy says no one pays for data and no retargeting occurs, yet opted-in advertising disclosure can still count as a California-law sale. Sale terminology and retargeting describe different things; no legal finding is inferred.
App tracking permission enables a GA4 and Google Ads integration
With iOS tracking permission or Android advertising-cookie opt-in, mobile identifiers and app-use data collected by Google GA4 are used to improve Google advertising. Android users can opt out in app Sharing Settings; iOS users can Ask App Not to Track at download or change permission in device Settings > Privacy & Security > Tracking. The policy’s therapy-content and PHI advertising exclusions still apply. Even with opt-in, the policy says it does not engage in retargeting advertising.
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If you use the App and have "Allowed" app to track using IOS or have opted into Advertising Cookies on Android, some data such as your mobile device identifier (IDFA and IDFV for iOS, and Android Advertising ID for Android) and data about how you use the App which is collected by our Service Provider Google (specifically GA4) will be used to make our Google advertising more effective.
If you do not want to enable this, for Android users, you can navigate to "Sharing Settings" in the App and opt out of advertising.
For IOS users, you can "Ask App Not to Track" when you download the app or, at a later time, go to your device's privacy settings to see a list of apps that requested to track your activity (Go to Settings > Privacy & Security* > Tracking).
excluding activity when you're logged in and have started therapy and PHI
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.
Even if you do opt in, we still do not engage in "retargeting" advertising.
Qualifications & exceptions
The described integration depends on the relevant device/app permission.
Advertising opt-in still excludes retargeting and private therapist information
BetterHelp says it does not engage in retargeting, even with advertising opt-in. It also says third-party advertisers do not receive therapist-shared information or listed details such as member names/phones, diagnoses, questionnaire answers, sessions, journals, messages and worksheets. Marketing service providers are different recipients, limited to directed use and restricted onward disclosure. SMS-program personal data is not shared, sold or rented to affiliated or unaffiliated third parties for their own marketing.
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Even if you do opt in, we still do not engage in "retargeting" advertising.
To be clear, we don't share any data or information you share with your Therapist with any Third Party advertisers.
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.
Service Providers can only legally use data at our direction - no other person or company can authorize how they use it and they cannot disclose data that is individually identifiable to any other person or company, other than to us or the Service Providers' own subcontractors provided that they're bound to data Processing terms that are no less restrictive than the Service Provider's terms.
Personal data collected through the short code/SMS program won’t be shared, sold or rented to unaffiliated or affiliated third parties for their own marketing purposes.
Cross-references
narrows (model-proposed): Visits generate usage, device and identifier data — Advertising opt-in does not authorize advertiser access to the excluded member identifiers or private therapist information, and retargeting remains excluded.
contrast (model-proposed): No payment for data can still involve a California-law sale — The policy says no one pays for data and no retargeting occurs, yet opted-in advertising disclosure can still count as a California-law sale. Sale terminology and retargeting describe different things; no legal finding is inferred.
California’s past-year sharing list differs from its collection list
For the past twelve months, the notice refers to the general sharing section for recipients and says shared data may fall into identifiers, customer records, protected characteristics, commercial, network activity, geolocation, sensory, sensitive, professional/employment and non-public education categories. Biometric information appears in the collection list but is not listed in this sharing list; that local omission is not a broader promise about all processing.
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The information that we may have shared in the past 12 months falls into the following personal information categories under the CCPA and CPRA:
Identifiers;
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
Protected classification characteristics under California or federal law;
Commercial information;
Internet or other similar network activity;
Geolocation data;
Sensory data;
Sensitive Personal Information;
Professional or employment-related information; and
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Sharing & Disclosure · Context
California’s sale disclosure concerns targeted advertising categories
The notice describes legally defined sales as targeted-advertising disclosures, including information about consumers under sixteen, while saying no external or Third Party pays for the data. It lists identifiers, commercial information and internet/network activity as categories that may have been sold in the past twelve months. This remains subject to advertising opt-in and exclusions for post-therapy logged-in activity and PHI; it does not establish an age-specific consent process or resolve legal compliance. 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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our "sale" of information (including sale of information about consumers under the age of 16) consists of the disclosure of your information for targeted advertising purposes, and we aren't paid by any external or Third Party2 for any data.
Identifiers;
Commercial information; and
Internet or other similar network activity;
If you opt in to our use of Advertising cookies and web beacons, this use may be considered a "sale" of personal information under that specific California law.
excluding activity when you're logged in and have started therapy and PHI
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.
Qualifications & exceptions
The disclosure uses a California-law definition and remains subject to advertising consent and exclusions.
Not stated here
The quoted under-sixteen statement does not specify an age-specific sale-consent procedure.
Lawful public-authority requests can require disclosure
Under certain circumstances BetterHelp may have to disclose personal data in response to lawful public-authority requests, including national security or law-enforcement requirements. The passage does not make every governmental request sufficient.
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Please note that under certain circumstances, we may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.