Information you provide when you create an account for yourself (or an authorized account for a minor), are matched to a therapist, or register yourself (or on behalf of a minor) as a patient:
- Name (e.g. your name or the name of your parent/guardian)
- Date of birth
- Phone number
- Gender and the preferred gender of therapist
- Relationship status
- Organization/Employer (if applicable)
- Payment information and transaction history
- Information on the type of subscription you choose
- Insurance information
- Referral source
- Information on why you are accessing our Services including what you are hoping to get from therapy
- Notification preferences
You provide this when you go through the intake process
- Provide you with the Services (including resubscription)
- TMatch you to a therapist
- Provide you with treatment information
- Enroll you in services and administer your account
- Provide you with support
- Process insurance claims, billing, and payment information
- Maintaining the safety and security of our users, our Services, and our business
- Provide announcements and communicate with you, including for marketing purposes
- Provide mandatory reporting to law enforcement or other governmental authorities, for example in instances of abuse, or ascertainable threats of violence to another person (See Notice of Privacy Practices for more information)
- Respond to a valid legal request.
- Process claims or insurance information
- Provide you with and to evaluate, improve and develop the Services
- Conduct therapist oversight
- Control the quality of the Services
- Permissive reporting of abuse; expressed threats of violence towards an ascertainable victim
Data you provide when you use our therapy service, including:
- Information you disclose in chat data and your chat sharing preferences (transcripts)
- Audio/Video communication
- Documents you share with your therapist via our chat functionality
- Information collected via our symptom tracker and information on your clinical progress
- Information collected via chat, telephone, or email support channels
- Messages that you “star”
- Information on friends you refer
- Information you provide as part of treatment intake including emergency contact details, information on your health and mental health and medical history
- If you use couples therapy, sharing of contact details and some communications will be conducted jointly.
- If you choose to admit another individual to a therapy “room” for a session, their contact information will be collected and used for that purpose.
Through your use of the Services
- To provide you with the Services
- To build, modify, and develop new products, features, and Services.
- To conduct clinical and other academic research, internally and with approved research partners and identify summary trends or insights for use in external communications (where direct identifiers such as name and contact details have been removed, or pursuant to explicit patient authorization). For more information see “Research” below. See Notice of Privacy Practices.
- To address patient concerns or complaints
- To carry out quality assurance and compliance activities
- To provide you with assistance in the event of an emergency
We collect information when you communicate with us via email. This includes information that you provide when you contact us as well as your email address.
You provide this information to us directly
- To respond and address your communication
- To provide you with the Services
- To improve the Services
- Provide support to users (therapists and patients)
Technical information from software or systems hosting the Services, and from the systems, applications and devices that are used to access the Services, such as:
- Information on the device operating system or Talkspace environment
- Metrics on system or App feature use
Information on system events and status
Automatically through use of the Services
- Create anonymized and/or aggregated data to improve and deliver our Services
- Comply with legal obligations
- Maintain the security of our infrastructure
- Facilitate the delivery and optimization of Services
- Monitor performance of our data centers and networks, systems and applications
- Provide support to users (therapists and patients)
- Administer our business continuity and disaster recovery plans and policies
- Detect, investigate, and remediate stop fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) through automated and manual means
- To provide you with and to evaluate, improve and develop the Services
- To develop new products
Using the Talkspace App
The Talkspace App includes third party software development kits (SDKs) from a number of other companies whom we engage as service providers, for identifying and logging code issues, errors and events; managing interactive communication within the App; compiling analytics on which features get used the most; facilitating customer service contacts regarding subscriptions and service; and processing device identifiers and event logs for ad attribution purposes (such as the initial login event, account creation, subscription events). These third parties process data as a service to Talkspace only, pursuant to written agreements
Advanced Data Processing
The Talkspace therapy experience is enhanced by advanced data processing activities, carried out in order to measure and improve clinical outcomes. Our proprietary matching algorithm and machine-learning tools provide real-time engagement insights, inform treatment, and track clinical progress, and are fundamental to our care delivery model.
Matching Algorithm. During onboarding we ask you to provide information so that we can assess your condition and incorporate your preferences. We then leverage a proprietary algorithm (and/or support from a Talkspace consultant) to match you to a provider.
Optimizing Diagnosis and Treatment. Throughout your experience, your provider uses the Talkspace Services to manage your diagnosis and treatment plan. The advanced machine learning features of our proprietary Services include natural language processing of communications with therapists. A core focus of our machine learning strategy is to provide the therapist with insights on patient needs and behaviours and offer techniques and suggestions that we believe are likely to maximize clinical outcomes.
Separate and apart from internal healthcare operations and quality assurance activities undertaken for the purpose of delivering and optimizing patient care on the platform, from time to time, Talkspace conducts or participates in research studies with select universities. You may be offered the opportunity to participate in these studies. If your protected health information will be disclosed as part of these studies, your information will only be included with your written authorization. You will be asked to review and accept terms and enrollment separately from the information included in this Policy. Information from these studies may be published by third parties including through various media platforms/academic journals. See our Notice of Privacy Practices.
What choices do you have about how we collect or use your information?
When you create a Talkspace account or otherwise use the Talkspace Services, we collect (or you may provide us with) your email address, and you have the choice to receive newsletters or promotional material about our services at this address. These messages may be tailored to your responses to onboarding surveys so that you receive information relevant to you. You can further manage your email preferences by unsubscribing from emails (via the link in the message), emailing [email protected] or by visiting our online preference center within the App or the Website.
In addition to your rights as a patient as set out in the Notice of Privacy Practices, you can ask us to:
- Stop sending marketing or promotional emails and mobile marketing communications from Talkspace.
- If you are a EU, EEA or UK user, you can also exercise the rights set out below.
- Certain California residents may have additional rights set out below.
To ask us about these choices, contact [email protected].
Your California Privacy Rights
EU/EEA/UK Privacy Rights
If you are located in the European Union, the European Economic Area, or the United Kingdom, this Policy is supplemented by our Additional Privacy Statement for EU, EEA and UK Users which explains your privacy rights and how you can exercise these rights (among other matters).
We will retain your information in accordance with the appropriate statutory limitation periods as required by local law, in line with our legitimate business purposes for as long as your account is active or for as long as needed to provide you with the Services, as required in order to comply with our legal obligations, a court order or to defend or pursue legal claims, in line with industry codes of practice, to resolve disputes and enforce our agreements.
Talkspace and Minors
In the United States, Talkspace may collect information and may provide Services to minors ages 13 – 17 with the written authorization of a parent or guardian. Talkspace does not provide therapeutic services to minors outside of the US.
Other Mobile Applications and Services
This Policy does not apply to any third-party applications or software that you download, or any other third-party websites, mobile applications, or online products, services, or businesses you may access from the Talkspace Website or App.
Applying for a Job at Talkspace
Please see our statement on Candidate Privacy for more information on the personal data we process in connection with recruiting.
We take commercially reasonable steps to protect the integrity and confidentiality of personally identifiable and health information that you may share with us. We have complied with the HIPAA security rule for administrative, technical, and physical security safeguards and have third party assessments of our controls performed annually. However, please be aware that no security measures are perfect or impenetrable and we cannot guarantee the absolute security of your information.
We will do our part to protect your information, but it is important for you to protect your information as well. In addition, we do not control the actions of anyone with whom you or any other Talkspace user may choose to share information. As such, you should be cautious about the access you provide to others when using Talkspace, and the information you choose to share when using the Talkspace website or App.
How to Contact Us
If you have any privacy-related questions or comments related to this Policy, please send an email to [email protected].
Additional Information for EU, EEA and UK Users
Please see our Additional Privacy Statement for EU, EEA and UK Users for further details on your privacy rights, how we share your personal data, international transfers of personal data and retention of personal data.
We process the personal data described above in accordance with the following legal basis:
- With your consent;
- As necessary to perform our agreement with you, including when you agree to our Terms of Service;
- As necessary for our legitimate interests, such as to provide you with the Services;
- As necessary to comply with our legal obligations;
- As necessary for the establishment, exercise or defence of legal claims; and
- As necessary to protect the vital interests of an individual.
We are a limited liability company established in New York, USA, with a registered office at 157 Columbus Avenue, New York, NY 12567, United States, and, if you are based in the EU, EEA, or UK for the purpose of the EU and UK General Data Protection Regulation, we are the data controller.