Oasis Education Application Privacy Policy

Last Revised: October 24, 2022

1.  General

We know that your privacy is important to you, and we work hard to earn and keep your trust.  Oasis Mental Health Applications, Corp. (collectively with its subsidiaries, “Company,” “we,” “us,” and “our,”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).

This Policy describes:

• The types of information we collect from you or that you may provide when you visit or use the Oasis Higher Ed Application (the “App”); and 
  
  
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this App or in emails and other electronic messages between you and this App, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy. This Policy applies to your use as a user of the App, including as a student, faculty member or staff member of a School (defined below).

This Policy does not apply to information collected by us offline or through any other means, including on any other website or application operated by the Company or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the App (for further information, see below, “Third-party Websites and Applications”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, then please do not use our App.  By using our App, you agree to the terms of this Policy.  This Policy may change from time to time (see below, “Changes to this Policy”).  Your continued use of our App after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2.  App Terms of Use; Other Agreements and Policies

App Terms of Use.  This Policy should be read in conjunction with any applicable App Terms of Use, into which this Policy is incorporated by reference.

School Agreements and Policies.  Use of the App and any user information associated with the App may also be subject to the terms of separate written agreements (the “School Agreements”) between the Company and schools, universities, or other educational institutions (“School”), that are contracted with the Company for Company’s services.  When applicable, this Policy may be superseded by specific terms in the School Agreements.  If you use or submit any materials on the App, you agree to be bound by any applicable School Agreements, as well as any posted School guidelines and policies related to the materials you wish to use or submit, as applicable.  When applicable, if you do not agree to the terms of the School Agreements, you will not be able to use the App.

Chat With Licensed Providers.  The App may provide services in which you can chat, message or otherwise communicate with a licensed provider or counselor.  If you use such services, the information that you provide and the use of those service will be subject to a separate Licensed Provider Support Chat Privacy Policy and Terms of Use.

3.  What We Collect and How We Collect It

We obtain the categories of Personal Information (defined below) listed below from the following categories of sources:

• Directly from you. For example, when you:
  • register yourself with the App;
  • subscribe to one of our e-newsletters;
  • apply and/or use third-party applications within the App;
  • provide a journal entry or mood log;
  • provide your story about your lived experience or mental health struggles and progresses;
  • participate in trivia, polls, quizzes and mindfulness techniques;
  • chat or otherwise communicate with a Chat Specialist;
  • make an appointment with a School counselor or other faculty member; and
  • communicate with us, such as request information.
• Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
• Directly and indirectly from activity on our App. For example, from App usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.

To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy.  Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, the App has collected the following categories of Personal Information from users of the App within the last twelve (12) months:

The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information.  When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services. 

Additionally, we may ask you to create a username and password that should only be known to you.  When you provide this information to us, you are no longer anonymous.  Moreover, we may receive information about you from other sources and add it to the information you have provided to us.

Important Information Relating to Health Information: While some of the information you provide or access through the App may be health-related, the App and any information you provide directly to it (except for communications with licensed providers via a separate chat room) is not subject to the Health Insurance Portability and Accountability Act (“HIPAA”) nor is any information “protected health information” as defined under HIPAA. If you ever have an emergency, you should contact your local authorities for assistance.  

Student Information/FERPA.  The Company is not an educational institution as defined under the Family Educational Rights and Privacy Act (“FERPA”).  However, the Company engages Schools to provide services to students of the School.  While the Company does not seek to collect student Personal Information (“Student Information”), if Company processes any Student Information, the Company protects the Student Information with reasonable administrative, technical and physical safeguards, including, where appropriate, in accordance with any School Agreements.

Information of Other Individuals.  You may have the opportunity to provide information of other individuals. When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and the Company shall not be responsible or held liable for your failure to obtain the necessary consents.

4.  Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our App.  We collect this information using automated technology.  This technology may collect information about your behavior and your device, such as your internet address (IP Address), the pages you have viewed, the actions you have taken while using the App, saved preferences, and log-in session ID.  This information is not personally identifiable or capable of being used to identify you in the scope of this Policy.

5.  How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• manage your account;
• providing the information, products and services you request;
• understand your personal situation, objectives, and circumstances, help and guide you to learn and implement ways for you to overcome your challenges and achieve your goals, evaluate the quality and progress of our support program;
• review, discuss, assess, and take actions on the incidents, situations, and problems relating to our services that you report to us;
• review, approve, edit, and share stories that you submit to share with the community;
• security, credit or fraud prevention purposes;
• providing you with effective customer service;
• providing you with a personalized experience when you use this App;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of this App;
• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• better understanding your needs and interests;
• improving the content, functionality and usability of this App;
• improving our products and services;
• improving our marketing and promotional efforts; and
• any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

6.  How We Share Your Information

We do not sell or lease your Personal Information to any third party.  We may share your Personal Information by disclosing it to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Schools.  We may share your information with your applicable School, such as, but not limited to, when you set up an appointment with a School counselor or respond yes to the “are you in crisis” prompt on the App.  In certain situations, it is necessary to disclose this information with your applicable School in the interest of continuity of care.  The Company is not responsible or liable for any uses of your information or your content by your applicable School. 
• Third-party Vendors.  Third-party vendors who provide services that enhance our App, products and services to you (such as vendors for credit card processing, advertising and customer support).
• Affiliates.  If our affiliates need the information to provide services and improve these services, we will provide access and information to the extent needed and only for the specific related purposes.

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances: 

• Legal Reasons.

• We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
  • To respond to duly authorized information requests from law enforcement or other governmental authorities;
  • To enforce our agreements, policies, or the App Terms of Use;
  • To investigate and prevent security threats, fraud, or other malicious activity; or
  • To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.

• Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries.  Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.

Data Aggregation.  We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of the Company.  Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.

7.  Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information. 

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information.  After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

8.  Text Messaging

You may have the opportunity to receive SMS or “text” messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties.  Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested.  In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s App Terms of Use.  In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us.  You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy. 

9.  Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it. 

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage or within the App, or contact us directly for assistance.

10.  Information of Minors

Minor Users. As a user of the App who is considered a minor, such as being under the age of 18, you agree that you have obtained consent from a parent/guardian for your use of the App. By using the App, you, as a minor, represent that you have obtained consent from your parent/guardian who has read and agrees to this Agreement on your behalf. If you do not obtain such consent, then you are not authorized to use the App.

Parents and Guardians. As a parent or guardian, you represent and warrant that you are over the age of majority; that you are agreeing to the terms of this Policy on your behalf and on the behalf of a minor for whom you are legally responsible (“Your Minor”); and that you have authority to bind you and Your Minor to the terms herein. You acknowledge and agree that Your Minor cannot use the App without you first accepting this Policy on behalf of Your Minor. To the extent Your Minor needs to set up an account, you, as the parent or guardian, are responsible for doing so, and are responsible for both all information provided in setting up that account and all actions taken by Your Minor using that account.

Collection of Minor Information. Company will collect only the personal information from minors that is needed for the operation and management of the App and its related services, and only where the School has contracted with the Company to do so. The Company first requires the consent of parents/guardians prior to collecting such information, either obtained directly from the parents/guardians or indirectly via an institution, organization, or group working with minors. If you are a minor, do not send any Personal Information about yourself other than what is requested upon signing up for the App..

11.  Submissions

We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through this App are available to others who visit this App. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through this App. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Submissions comply with our App Terms of Use or other applicable agreements. All terms and conditions of our App Terms of Use apply to Submissions on or through this App. In particular, your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.

Your Stories. You may submit a story about your personal life experience and mental health struggles and progresses.  When you submit a story, we may review, approve, edit and share such stories with the community.  We will only share your story with your consent and approval of any edits.

Chat Rooms and User Contributions. The App may contain message boards, chat rooms, personal web pages or profiles, forums, bulletin boards, and other interactive features (collectively, “Interactive Services”) that allow you to post, submit, publish, display or transmit to other users or other persons text, materials, or other content (collectively, “User Contributions”) on or through the App.  When submitting User Contributions, please do not provide sensitive information, such as Social Security numbers or credit cards, unless required by our services.  We are unable to pre-screen or monitor all User Contributions and we will not do so.  Your use of the App is at your own risk.

12.  Social Features

Some features on third party websites and apps permit you to initiate interactions between the websites, platforms, and services, such as social networks (“Social Features”). Social features include allowing you to click and access the Company’s pages on certain third-party platforms, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may not be publicly displayed by the third-party service you are using. The Company and the third party may have access to information about you and your use of both the websites and third-party services.

13. Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates.  Our App may link to third-party websites and services. For example, if you click on an advertisement on this App, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them.  Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information. 

14.  Your California Rights

Shine the Light law.  Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

Do Not Track Signals.  Other than as disclosed in this Policy, the App does not track users over time and across third-party websites to provide targeted advertising.  Therefore, the App does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

WE DO NOT SELL YOUR PERSONAL INFORMATION. If we ever decide to sell Personal Information, we will update you via this Policy and include a link entitled “Do Not Sell My Personal Information,” to provide you with an opportunity to opt out of sales of your Personal Information.

California Consumer Rights.  If you are a California consumer, as defined by the California Consumer Privacy Act of 2018 (“Act”), please be advised that Oasis Mental Health Applications, Corp., does not currently meet the regulatory thresholds of a “business” as that term is defined under the Act and therefore is not required to comply with the Act.  Regardless, all Personal Information will be processed in accordance with this Policy.

15.  For App Users or Visitors Outside of the United States

Our App is designed for use by individuals in the United States only.  We do not warrant or represent this Policy or the App’s use of your Personal Information complies with the laws of any other jurisdiction.  Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy. 

16.  Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise 100% security.  As a User or Consumer, you have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password.  If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.     

17.  Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this App. We are continually improving and adding to the features and functionality of this App along with the products and services we offer through this App. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

18.  How to Contact Us

We value your opinions and welcome your feedback.  To contact us about this Policy or your Personal Information, please contact us by email at: privacy@oasisapp.com.