Date of publication: 04.04.2025
Starting from the date of publication, the document applies to new and existing terappio.com Users

PRIVACY POLICY

By using the Site or filling out any forms on the Site, you accept the Privacy Policy, Terms of Use and Disclaimer and consent to the collection and use of any information you provide. If you do not agree to this Privacy Policy, Terms of Use and Disclaimer, please do not use our Site or services.

Terms and definitions not defined in this document are defined in the terappio.com Terms of Use.

"GDPR" means Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

Personal data, processor and controller have the meaning given to them in Article 4 of the GDPR.

1. Information about the Company

1.1. About us

The operator of terappio.com and the responsible person within the meaning of the GDPR is Terappio OÜ, a limited liability company incorporated under the laws of Estonia, with registration number: 16586404 and registered office: Terappio OÜ - Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 3 // 5 // 7, 10145, Estonia (hereinafter referred to as the "Company", as well as "we", "us", "our", etc.)

We are committed to ensuring the security of your data storage and processing. The protection and security of not only your personal data, but also your User Content transmitted through our Site is important to us. As part of this principle, we process personal data in accordance with the GDPR and in accordance with the data protection regulations applicable to us and our Site.

BY ACCESSING OR USING OUR WEBSITE, YOU CONFIRM THAT YOU HAVE READ THIS PRIVACY POLICY AND TERMS OF USE, AND THAT YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY AND OUR TERMS OF USE.

Please read this Privacy Policy carefully, as your access to and use of the Site means that you have read and understood all the terms of this Privacy Policy, the Terms of Use and the Disclaimer.

If you do not want to send us your personal data, you can use all areas of our Site that do not require filling out forms/authorization without having to disclose your personal data.

1.2. Additional information

Our Site may contain links to other sites or services for which the Company is not responsible for the content and functions. Please read the data protection policies of the respective websites or services of the respective operators. If you use the Site to transfer your User Content from one service or system to another, you are solely responsible for the compliance of such data transfer with the protection rules of such services or systems from and to which you transfer your User Content.

We take appropriate technical and organizational measures to protect against unauthorized access and/or unlawful processing of your personal data or your User Content, as well as against accidental or unlawful destruction, loss, alteration or unauthorized disclosure of such data. However, please note that we cannot completely eliminate the security risks associated with the storage and transmission of such data.

Since our Site is not specifically designed for underage children and adolescents, no one should send us their personal data without the consent of their parents or legal guardians. If we become aware that a minor has sent us his or her personal data through the Site without the consent of a parent or guardian, we will immediately delete this information. We encourage parents to instruct their children about the safe use of personal information on the Internet.

2. Information we collect

2.1. Information processed by default

In order to ensure the technical functionality of our Site, to investigate security incidents and monitor technical malfunctions or attacks, to recover your User Content or personal data in the event of technical problems with the Site, we collect the standard data necessary for this purpose.

When you visit our Site, we automatically record information from your browser to help us improve the usefulness of our Site, manage the provision of services through the Site, and resolve technical issues. Such log files may include:

As a rule, this is not personal data, and this information is not combined with other data that we process.

We may create anonymized or de-identified data from Users' personal data, except for data components (such as your name, email address or phone number) that make the data identifiable to you personally, through anonymization or other means. Our use of anonymized and de-identified data is not governed by this Privacy Policy.

Providing some data is necessary and mandatory. Without the transmission of technically necessary information, the functionality and access to our Site cannot be guaranteed.

2.2. Information you provide to us directly

We also collect, store, and process the following information that you provide to us directly and for which we are the controller:

By filling out the Psychologist's profile and sending his/her data to us for verification, the User agrees that his/her profile data (name, qualifications, contact information, description of services, his/her photo, photos of educational documents, etc.) after successful verification will be available for viewing by other Users of the Site. The User agrees to receive, collect, process, register, accumulate, store, modify, update, use and transmit information, including, but not limited to, verification of profile data, its publication on the Website and other actions necessary to ensure the functioning of the Website. The Website Administrator reserves the right not to publish a Psychologist's profile on the Website without giving any reason.

The User has the right to withdraw his/her consent to the processing of personal data by contacting the Website Administrator. The request to terminate the processing of personal data must include the surname, name, patronymic (if any), contact information (phone number, e-mail address or postal address) of the User (personal data subject), as well as a list of personal data to be terminated. In this case, the profile will be deleted or hidden in accordance with the Website's Privacy Policy.

In case of creating a Personal Account, the Psychologist agrees to: (a) provide accurate, up-to-date and complete information about himself/herself as required in the registration form; and (b) update his/her data to keep the information accurate, true, up-to-date and complete. All Personal Accounts of Psychologists remain the property of terappio.com and may be terminated or suspended at any time without prior notice. The User is solely responsible for the confidentiality of the data of the Personal Accounts and the User's password. Similarly, all actions performed on the Site under your username and password are solely your responsibility.

2.3. Information we receive through your use of our Site

We also collect, store and process the following information that we receive as a result of your use of our Site:

2.4. Use of cookies.

We use cookies for your convenience. A cookie is a data file that we send to your device. We use several types of cookies: (1) wbsid cookies, which store your registration email address and password so that you do not have to enter it each time you access our Site, and to store your registration ID so that you can remain on our Site, (2) wbsid cookies, which allow us to track and remember which source you came to our Site from, including whether you came through a Partner's referral link, and (3) apix_rf cookies, which are used in advertising campaigns, etc.

When you start using our Site, we will additionally ask for your consent to the use of cookies. Please read the information in the pop-up window and in this document about which cookies we use and for what purpose, and provide us with your consent to the use of such cookies or your refusal to use such cookies.

Cookies are optional and you can choose to accept them or not. However, if you choose not to use them, we are not responsible for the results of such a refusal. If you have agreed to store a cookie, the cookie will be deleted from your device (1) after 30 days of inactivity, or (2) when you clear your browser cache.

If you do not agree to our use of cookies, please manage your cookie settings on the Site and in your browser to set your cookie preferences to a satisfactory level.

3. Legal grounds and purposes of information processing

3.1. Legal basis for data processing

The Company processes your data in accordance with the GDPR, namely:

We process only the personal data that you provide to us for use in connection with the use of our Site.

3.2. Purposes of data processing

The purposes of data processing specified in Section 2 of this document are:

4. Data processing and storage period

We store your personal data and your User content only as long as it is necessary for the purposes for which they are processed, including the provision of services to you, i.e. while the Psychologist keeps his/her profile on the Website; until the Client stops interacting with the Psychologist selected on the Website. We will also retain some of your personal and other data as necessary to comply with our legal obligations, resolve disputes, and ensure compliance with our legitimate interests.

We will delete your personal data and your User Content stored with us as soon as we no longer need to process it for the purposes set forth in this Privacy Policy. If applicable, we will also delete your personal data upon your written request to the Site's support service.

We keep your data safe:

5. Rights of data subjects

As a data subject under the GDPR, you have the following rights:

In addition to making a request to the Website support service, the Psychologist may partially exercise his/her rights as a data subject on the Website using the tools in the Personal Account. For example, you can ask the support service to delete your personal data or change the data in your Personal Account yourself. If we are obliged to keep records of some of the Psychologist's personal data, for example, for accounting purposes, this information is stored. We delete the rest of the information, including personal data, within 5 calendar days from the date of the User's request for this.

6. How we process and store your data

We process and store the information received on the terms and conditions described in this document.

For example, we store your User Content in an encrypted, raw format for no longer than the period specified in this document.

Please note that we store the User's content for a limited period of time, as specified in Section 2.3, and only during this period we can investigate the error that occurred in the operation of the connections, if any. If you contact us after the expiration of the storage period for such data, the support staff will not be able to help you, therefore, all claims regarding the incorrect operation of the Website and/or communications will be accepted by the support service only within 5 (five) business days from the date of such error in the communication.

Please take into account the working hours and days of the support service, we will not be able to provide you with assistance if you contact us on the sixth or seventh calendar day after the error just before a weekend or holiday.

We process all data that we process as a processor under the terms of this document and the GDPR.

Data security

Your data is safe with us. All of our partners are bound by non-disclosure obligations and must not use the data transmitted for any purpose other than that for which we have provided them with such data.

In particular, we ensure this level of security by pseudonymizing and encrypting personal data and your User content, regularly testing and evaluating the effectiveness of technical and organizational measures to ensure the security of processing. We implement and maintain various security measures designed to protect the Site and your data from unauthorized access, unauthorized processing or disclosure to unauthorized third parties.

We undertake to notify you of any breach of data processing and storage security and/or data leakage in the manner and within the timeframe provided for by applicable law.

Depending on which jurisdiction you are a User from, your personal data and User Content are stored in secure web hosting centers in the United States.

We do not sell your personal data.

You have the right to know if your personal data is being sold.

Personal data is "sold" when it is provided to third parties in exchange for monetary or other valuable consideration for a purpose other than "business purposes".

Please note that "sale" does not include disclosures of your personal data at your direction or when permitted by law.

7. To whom we transfer data

WE DO NOT SELL ANY PERSONAL OR OTHER USER DATA.

To ensure the operation of our Site, we cooperate with various service providers and services (e.g., hosting provider). In addition, your data will be transferred to parties that are unavoidable for the performance of contractual obligations or where there is a legal obligation to transfer it. All such third parties must agree to respect the confidentiality of Users and protect the privacy of your personal data.

Your data may be transferred to providers and contractors in countries outside the European Economic Area (EEA). We transfer personal data to third countries only in those countries where the EU Commission has confirmed an adequate level of protection or where we and our contractors can ensure that personal data is treated with care.

When processing data, we work with the following service providers who have access to your data:

Name: Microsoft Azure Cloud (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA)
Address: https://azure.microsoft.com
Provides us with services: Cloud storage and data processing.
Purpose of data transfer: Placement, processing and storage of user data in cloud services to ensure the operation of the website.
Link to the privacy policy: https://privacy.microsoft.com/en-us/privacystatement

Name: Google Analytics 4 (GA4) (Google LLC, 1600 Amphitheatre Parkway, Mountain View, California, 94043, USA)
Address: https://analytics.google.com
Provides services to us: Analytics of user behavior on the website.
Purpose of data transfer: Analysis of user behavior to improve usability and effectiveness of marketing campaigns.
Link to the privacy policy: https://policies.google.com/privacy

Name: Kommo CRM (Kommo, 2048 Alameda Padre Serra, Suite 224, Santa Barbara, CA 93103, USA)
Address: https://www.kommo.com
Services provided: CRM systems for processing user requests.
Purpose of data transfer: Contact management, customer interaction, communication history.
Link to the privacy policy: https://www.kommo.com/privacy-policy/

Name: Facebook Pixel (Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA)
Address: https://www.facebook.com
Provides us with services: Facebook Ads targeted advertising and analytics.
Purpose of data transfer: Tracking of users' actions on the site to display relevant ads on Facebook (remarketing).
Link to the privacy policy: https://www.facebook.com/about/privacy/previous

Name: Google ADS (Google LLC, 1600 Amphitheatre Parkway Mountain View, California, 94043, USA)
Address: https://ads.google.com
Provides services to us: Google ADS contextual advertising.
Purpose of data transfer: Display of contextual advertising for users who have already been on the site (remarketing)
Link to the privacy policy: https://policies.google.com/privacy

Name: Stripe (Stripe, Inc., 354 Oyster Point Boulevard, South San Francisco, California, 94080)
Address: https://stripe.com
Provides services to us: Accepting payments.
Purpose of data transfer: Acceptance of payment from users, the payment provider receives the data to make the payment from the user's card
Link to the privacy policy: https://stripe.com/privacy

Name: Microsoft Clarity (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA)
Address: https://clarity.microsoft.com
Provides services to us: Analytics of user behavior on the website.
Purpose of data transfer: Tracking user interaction with the site to improve the interface and usability.
Link to the privacy policy: https://privacy.microsoft.com/en-us/privacystatement

Name: Gmail (Google LLC, 1600 Amphitheatre Parkway Mountain View, California, 94043, USA)
Address: https://gmail.com
Provides services to us: Sending emails.
Purpose of data transfer: Sending out notifications about the need for payment and receiving support requests via email
Link to the privacy policy: https://policies.google.com/privacy

Name: WhatsApp (Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA)
Address: https://www.whatsapp.com
Services provided to us: Messenger for communication with users.
Purpose of data transfer: Organization of communication between the Client and the Psychologist, informing Users about services, consultations, session schedule.
Link to the privacy policy: https://www.whatsapp.com/legal/privacy-policy

Name: Telegram (Telegram FZ-LLC, Dubai, UAE)
Address: https://telegram.org
Provides services to us: Messenger for communication with users.
Purpose of data transfer: Communication with Users, organization of consultations between the Psychologist and the Client.
Link to the privacy policy: https://telegram.org/privacy

Name: Facebook Messenger (Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA)
Address: https://www.messenger.com
Services provided to us: Instant messaging platform.
Purpose of data transfer: Organization of communication between Clients and Psychologists, provision of consulting services.
Link to the privacy policy: https://www.facebook.com/privacy/policy

Name: Apple Pay (Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA)
Address: https://www.apple.com/apple-pay/
Services provided to us: Payment system for contactless payments.
Purpose of data transfer: Processing user payments, providing convenient and secure payment for services on the site.
Link to the privacy policy: https://www.apple.com/legal/privacy/en-ww/

Name: Google Pay (Google LLC, 1600 Amphitheatre Parkway, Mountain View, California, 94043, USA)
Address: https://pay.google.com
Services provided to us: Payment system for online payments.
Purpose of data transfer: Processing of user payments, secure financial transactions on the site.
Link to the privacy policy: https://policies.google.com/privacy

Name: MonoPay (JSC Monobank, Ukraine)
Address: https://monobank.ua
Services provided: Payment system for quick payments through Monobank.
Purpose of data transfer: Processing and confirmation of user payments through the MonoPay system.
Link to the privacy policy: https://www.monobank.ua/privacy

Processing of data by individual entrepreneurs: some of the personal data of Users may be transferred for processing to individual entrepreneurs registered in accordance with the laws of Ukraine. Such individual entrepreneurs provide services to the Company in accordance with the agreements between the Company and such individual entrepreneurs and process such data in favor of and on behalf of the Company. Such individual entrepreneurs process Users' personal data in accordance with this Privacy Policy and the legislation applicable to the Company regarding the processing of personal data. If you have any questions regarding the processing of your personal data by individual entrepreneurs or wish to refuse such processing, please contact the Support Service.

We do our best to ensure the protection of Users, but we cannot provide guarantees regarding the continuous technical serviceability of the third-party services we use.

Information about Google services

We use various services of Google LLC ("Google"), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

By integrating Google services, Google may collect and process information (including personal data) about you. It cannot be ruled out that Google may also transfer the information to a server in a third country.

As set forth in Google's Privacy Shield certification (available at https://www.privacyshield.gov/list under the search term "Google"), Google has committed to comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework when collecting, using, and maintaining personal data from EU member states or Switzerland. Google, including Google LLC and its wholly-owned subsidiaries in the United States, has certified that it adheres to the Privacy Shield principles. For more information, please visit https://policies.google.com/privacy/frameworks?gl=en.

Payments

The company is not a financial organization. We use services: Stripe, Monobank as credit card processors. We do not have access to your credit card number or any other payment information. Credit card numbers are never stored on our servers.

The site does not have access to the payment information of Psychologists, and therefore is not able to transfer any payment data to third parties.

Advertising

Our Site may contain third-party advertisements and links to third-party sites. We do not make any representations about the accuracy or suitability of any information contained in these advertisements or sites, and we assume no responsibility or liability for the conduct or content of these advertisements and sites, or for offers made by third parties.

We work hard to ensure that our advertising is safe, unobtrusive, and as relevant as possible.

Third-party advertisements and links to other sites that advertise products or services do not constitute a recommendation of the third-party sites, products or services. We are not responsible for the content of any advertisement, the promises made, or the quality/reliability of the products or services offered in any advertisement.

8. Contacts for data protection issues

If you have any questions about our data protection measures, the processing of your personal data or the protection of your rights, please contact us as follows:

e-mail address: office@terappio.com.

9. Our social networks

You can also follow the Company's news by subscribing to our social media pages, but you cannot use a subscription to our social media as a substitute for reading the newsletter sent to you in your Personal Account or to your email address.

Facebook - https://m.facebook.com/terappio.com/?locale

LinkedIn - https://ua.linkedin.com/company/qui-help

Instagram - https://www.instagram.com/terappio.com/

Telegram - https://t.me/terappio

10. Changes to the Privacy Policy

This Privacy Policy contains information about data protection in our Company. If our processes change, we will adjust the information in this document accordingly.

The new version of the Privacy Policy comes into force from the moment it is posted on the Internet on our Website.

The current version of the Privacy Policy is always available on the page at: https://www.terappio.com/notice-of-privacy.

In the event that we change any provisions with which the User does not agree, he/she is obliged to stop using the Website. The fact of continuing to use the Site is a confirmation of consent and acceptance of the relevant version of the Privacy Policy.

11. Support service

If you have any questions regarding the Website, organizational or administrative issues, you can contact the Website support service for advice or assistance using the e-mail address or writing to the online chat support service on the Website.

The support team will make every effort to respond to the issue as quickly as possible, usually within one to three business days.

The e-mail address of the Website support service is office@terappio.com.