TALKSPACE

Privacy Policy

Personal Data

The Personal Data and Browser Data (hereinafter collectively referred to as "Data"), automatically collected from this website (hereinafter the "Site"), by means of automated systems or freely entered by the User of this Site.

Your privacy is very important to us. We designed our Privacy Policy to make important disclosures about how you can use Talkspace.com and how we collect and use your content and information. We encourage you to read the Talkspace Terms of Use and this Privacy Policy in its entirety.

We receive a number of different types of information about you, including:

The information that's required when you sign up for the site, as well as the information you choose to share.

Required information such as your name, email address, birthday, and gender. We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties.

Usernames and User IDs, which are a way to identify you on Talkspace. A User ID is a string of numbers and a username generally is some variation of your name.

"Public Information" which means the information you choose to make public, as well as information that is always publicly available.

Information posted to a group chat or moderated session and information kept within a one on one session.

“Contact Information” is personal information and or family/friend/relation that Talkspace stores confidentially for your Provider to access in case of an emergency or mental health crisis.

If you are coming to the site through an employer or insurer payor such as and Employee Assistance Program (EAP) then there is additional information collected by these Parties. This information is typically collected to confirm your eligibility with the EAP or network benefit administrator and is not shared with your Provider (who will collect your contact information separately). Further, your Employer or the Employer of the subscriber of your benefits will not be provided this information (you likely already gave them similar information in your employee file unless you are a family member of an eligible employee).


This information may include:


First Name
Last Name
Email
Date of Birth
Phone number
Who you are (employee or the spouse, domestic partner, or dependent of an employee in certain programs)
Employer’s name

Parties processing the data

Talkspace is a "DBA" used by Groop Internet Platform Inc. who runs the site and keeps the Data. Talkspace Network LLC is a wholly owned subsidiary of Groop Internet Platform Inc. This entity partners with Businesses and Insurance Networks and contracts with our Providers for Psychology and Psychiatry., We will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies or during an emergency circumstance as judged by your Provider working with local authorities). Generally, we will only use your information within our company. However, sometimes we use third parties to process your information (for example as credit card payment providers). We will require these third parties to comply strictly with its instructions and we will require that they not use your personal information for their own business purposes.

The Uses of the collected Data by Talkspace

Talkspace uses non-identifying and aggregate information to better design our Web site and to use in research and trend analysis. For example, we may tell an advertiser that X number of individuals visited a certain area on our Website, or that Y number of men and Z number of women filled out a site survey or form, but we would not disclose anything that could be used to identify those individuals. We only provide data to our partners, if any, after we have removed your name and any other personally identifying information from it, or have combined it with other people's data in a way that it no longer personally identifies you.

Talkspace uses non-identifying (De-Identified or “Safe Harbor” form) and aggregate information about responses to the clinical outcome assessments (personal assessments), and the frequency of the utilization of the Talkspace service. These efforts enhance program evaluation.

The anonymous and aggregated data also may be published through various media platforms/academic journals. No personal identifying information will be tied to the results, and Talkspace will not share anything that could be used to identify your account or your private information.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will contact you before we use your data for these new purposes to notify you of the policy change and to provide you with the ability to opt out of these new uses.

Talkspace stores data only for as long as it is necessary to provide products and services to you and others, including those described above and for legal protections or as required by applicable laws and regulations.

Talkspace may enable access to public information that has been shared through our services.

Talkspace may allow service providers to access information so they can help us provide services.

IP addresses are used to identify the location of users, the number of visits from different countries and also to block disruptive use; and to analyze and improve the services offered on our website, e.g. to provide you with the most user-friendly navigation experience.

Certain information is needed to provide you with services, so we only delete this information after you delete your account.

Some forms of processing (sending promotional information, commercial profiling, behavioral advertising, geo-location, etc.) may require the express consent of the User. Specific information may be shown on the pages of the Site in connection with particular services or processing of Data provided by the Site User.

Upon request we provide site visitors with access to a description of information that we maintain about them. Talkspace.com uses industry-standard encryption technologies when transferring and receiving consumer data exchanged with our site. If you feel that this site is not following its stated information policy, you may contact us at addresses or phone number below.

For content that is covered by intellectual property rights, like photos and videos you specifically grant Talkspace.com a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use any IP content that you post on or in connection with Talkspace.com (IP License). This IP License ends when you delete your IP content or your account unless your content has been shared with others, and they have not deleted it. This Paragraph does NOT apply to photos, images or other videos shared ONLY with your Provider in your private “Room” on the Platform.

When you delete IP content, it is deleted in a manner similar to emptying the recycle bin on a computer. However, you understand that removed content may persist in backup copies for a reasonable period of time (but will not be available to others).

Protecting the Privacy of your fellow Talkspace Users

During your use of Talkspace.com services, you will not send or otherwise post unauthorized commercial communications (such as spam) on Talkspace.com.

You will not collect users' content or information, or otherwise access Talkspace.com, using automated means (such as harvesting bots, robots, spiders, or scrapers) without our permission:

You will not upload viruses or other malicious code.

You will not solicit login information or access an account belonging to someone else.

You will not bully, intimidate, or harass any other User.

You will not post content that: is hateful, threatening, or pornographic; incites violence; or contains nudity or graphic or gratuitous violence.

You will not provide any false personal information on Talkspace.com, or create an account for anyone other than yourself without permission. You will not create more than one personal profile.

Copyrights: Talkspace and Protecting Other People's Intellectual Property Rights

We respect other people's rights, and expect you to do the same. You will not post content or take any action on Talkspace.com that infringes or violates someone else's rights or otherwise violates the law. We can remove any content or information you post on Talkspace.com if we believe that it violates this Privacy Policy or the Terms of Use on this Site. You will not use our copyrights or any confusingly similar marks, without our written permission. If you collect information from Talkspace Users, you will: obtain their consent, make it clear you (and not Talkspace.com) are the one collecting their information, and post a privacy policy explaining what information you collect and how you will use it. You will not post anyone's identification documents or sensitive financial information on Talkspace.com. You will not tag Talkspace fellow Users or send email invitations to non-users without their consent.

Portable Electronic Devices

The Talkspace Platform is available on a multitude of portable electronic devices. We provide our connection to mobile services for free, but please be aware that your carrier's normal rates and fees, such as text messaging fees, may still apply. You provide all rights necessary to enable Talkspace Users to sync (including through an application) their contact lists with any basic information and contact information that is visible to them on Talkspace.com, as well as your name and profile picture.

Your Use of Your Personal Data

If a Talkspace.com User utilizes the Platform to publish or otherwise share their own Personal Data or Contact Information with third parties, he or she assumes full responsibility for any further use of that Data or information.

International Use and The GDPR

The Talkspace Platform advises both its Client/Users and practicing Platform Providers to be aware of and respect and comply with the local laws of any international based Client. Talkspace is cognizant and respects the formal promulgation of the existing European Union (EU) data privacy regulations. The General Data Protection Regulation 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It also addresses the export of personal data outside the EU and EEA and is commonly referred to as “GDPR.” Talkspace has always respected our Client’s Privacy (see our Privacy Policy) and we were already a HIPAA certified platform following stringent data privacy rules.

The basic tenants of the promulgated GDPR regulations include, but are not limited to the following:

Disclosure when you sell, transfer or third party marketing of User’s data: As outlined in this Terms of Use, Talkspace does not sell or transfer Client data and any marketing efforts are focused solely on internal information updates to our registered Clients.
Access to collected data: At Talkspace, you already have the ability to access your shared data (Your personal information, your emergency contact information and all your interactions with your Providers) and use it as you wish.
Clear Consent: At Talkspace our Terms of Use are clear on what consent we seek with regards to your data and prior to your engagement with your Provider, you review and agree to a further “informed consent” process.
Security: At Talkspace we have encrypted our data from day one and has always been stored all Private Health Information with full HIPAA compliance and in an anonymized form as required by the GDPR.
Notice/Audit: At Talkspace, we will provide our Clients notice of any data breach and we employ a full time security Officer, as well as engaging a third party security firm to periodically audit both or code and technology security as well as our HIPAA policies and procedures around data security.

Finally, dependent of your EU country or origin, the GDPR takes into account what was previously termed the right “to forget” or request deletion of your data once you cease using a particular application or site. This particular tenant of the GDPR may conflict with applicable medical records retention laws. In the United States, this requires at least seven years of retention, which is common around the world and is sometime up to ten years or more in certain countries. So, unlike some data platforms, Talkspace cannot erase private health data directly upon a Client’s request, as it may be considered essential for other medical file retention purposes. Applicable individual country medical retention laws are generally considered an acceptable exception to the GDPR regulations regarding the right to deletion of certain data.

Disputes

You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Statement or Talkspace.com exclusively in a state or federal court located New York. The laws of the State of Delaware will govern this Statement, as well as any claim that might arise between you and us, without regard to conflict of law provisions.

If anyone brings a claim against us related to your actions, content or information on Talkspace.com, you will indemnify and hold us harmless from and against all damages, losses, and expenses of any kind (including reasonable legal fees and costs) related to such claim.

Social Networks and Talkspace

These services allow the web site to access the data on your profile in the social networks, and to interact through your post. These services are not activated automatically, but require express authorization by the User.

Talkspace Users can share information and Data supplied to this Site with the social networks with which the User is registered, accepting their privacy policy. Facebook social buttons/widgets (Facebook) Facebook Social button is a service run by Facebook Inc., a company that complies with the “Safe Harbor” Privacy Policy Framework initiative, guaranteeing the handling of Personal Data.

Twitter is managed by Twitter, a company that complies with the “Safe Harbor” Privacy Policy Framework initiative, guaranteeing the handling of Personal Information.

Cookies on Talkspace.com

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet, phablet, cell phone or other electronic devise (referred to here as a "device") browser from a website's computer and is stored on your device's hard drive. Each website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track traffic flows.

Cookies record information about your preferences and allow us to tailor Talkspace to your interests. During the course or any visit to the Site, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things such as finding out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking for the cookie left there on the previous visit.

Information supplied by cookies can help us to analyze the profile of our visitors so we can provide you with a better user experience.

Definitions

Clinical Assessments: Questions from clinical scales that measure mental health and well-being. Clinical assessments vary by condition.

Data/results: The quantitative scores that are based on responses to questions in the assessments.

Personal identifying information: Name, address, credit card number

Final Words from Talkspace

We try to keep Talkspace.com safe, but you use it at your own risk. We are providing Talkspace.com “As Is” without any express or implied warranties. We do not guarantee that Talkspace.com will be safe or secure. Talkspace.com is not responsible for the actions, content, information, or data of third parties, and you release us, our directors, officers, employees, and agents from any claims and damages, known and unknown, arising out of or in any way connected with any claim you have against any such third parties.

We strive to create a global community with consistent standards for everyone, but we also strive to respect local laws. You consent to having your personal data transferred to and processed in the United States. If you are located in a country embargoed by the United States, or are on the U.S. Treasury Department's list of Specially Designated Nationals you will not engage in commercial activities on Talkspace.com (such as advertising or payments) By content we mean anything you post on Talkspace.com that would not be included in the definition of information. By data we mean content and information that third parties can retrieve from Talkspace.com or provide to Talkspace.com through Platform. By post we mean post on Talkspace.com or otherwise make available to us (such as by using an application). By use we mean use, copy, publicly perform or display, distribute, modify, translate, and/or create derivative works.

Talkspace.com openly volunteers its practices of collecting information, its targeting capabilities, and its use of cookies. If you have any questions pertaining to this privacy policy and its contents, please direct your correspondence to Talkspace.com at the "contact us" link on the website.

Understand, that we treat your use of our platform with the utmost respect to your privacy. We keep all information not disclosed above private between the Provider and the User, keeping only non-decimated "file" copies for reference in case of legal dispute of by court order as we are required to under Federal Laws for period up to seven years or by the applicable State Regulation. File retention protects both the User and the Providers safety. Talkspace is not responsible for data lost/exposed/used due to the nature of the Internet and digital environments, including illegal actions of hackers and criminals, technical malfunctions of servers and database etc. These are the accepted risks of our Users and users of the Internet in general. You are agreeing to this standard in using our site.

Talkspace reserves the right to amend this Privacy Statement at any time without notice, and only the current Privacy Statement may be deemed effective. Regardless of later updates or changes to our privacy notice, we will never use the information you submit under our current privacy notice in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.

This Privacy Policy was  last updated on December 1, 2018  and is deemed effective as of this date.

Terms of Use

These are the rules that govern your access and use of the Talkspace platform (do's and don'ts).

User Agreement

Read these details to understand your use of Talkspace as a casual visitor or a registered member.