Table of Contents

  1. Introduction
  2. Information Collected And How It Is Used
  3. Use of Cookies and Access Logs
  4. Information Update and Retention
  5. Security Considerations
  6. Disclosure to Third Parties
  7. External Links
  8. Acceptance

1. Introduction

This Privacy Policy ("Policy") pertains to all information collected or submitted to any tools or applications on this website. This website is operated by NetUnion Sārl, a company located in Lausanne, Switzerland.

Please read this Policy carefully. It describes the information that can be collected as you visit or use this site and how we intend to use this information. Unless specified in this Policy, we will not sell, share, licence, trade, or rent your personal information to others.

We may amend this Policy from time to time. We will post any changes to this Policy here so that you can be always aware of what information we gather, how we might use that information and whether we will disclose that information to anyone. A notice will be posted on your personal welcome page at your next login to the Site to inform you about such changes. Please refer back to this Policy on a regular basis. By using this website or any of our products, offerings, features, tools or resources that we provide on this website (collectively "Online Services"), you agree to the terms of this Policy.

The server that makes the website and Online Services available may be located outside the country from which you accessed this website. We will collect, process and use personal information only in accordance with this Policy.

Questions regarding this Policy should be directed to your Coach. Please remember that this Policy applies only to information collected by our website and Online Services. We are not responsible for the privacy of any information you reveal or post in any public forum, information submitted by e-mail, or for the privacy practices of websites that are operated or owned by third parties.

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2. Information Collected and How It Is Used

While you may access the public portion of this website without a personal account, access to our Online Services requires you to set up an account through an organisation or a therapist (Coach) who monitors your progress.

Personal Account Information is collected when you establish your account. The information required depends on the type of account.

If you are an End-User (someone using Online Services under the supervision of a Coach), only your pseudonym, your e-mail address, your gender and your age are stored on our servers during account registration. Our services do not intentionally collect or store any other Personal Account Information on our servers other than those that are required to provide the specific services you selected or to inform you of updates.

All other Personal Account Information is kept by your coach in a separate file in accordance to their Organisation's Institution's internal procedures.

Gender and age are used for statistical purposes only. No other personal information from the EndUser is stored in the System.

Information stored on Institution and Staff accounts could include contact information or any information submitted by a Staff or your organisation that is required for the administration and functioning of the Online Services. This information could include such information as your first and last name, pseudonym, contact address, telephone number, e-mail, institution name, age, gender, treatment approach, affiliation or other information.

Username and password are used for gaining access to your personal account and communicating with other authorised users through the messaging module. For Institutional users, such as Coaches, the username is composed of their first and last name. For End-Users, it is a pseudonym that should not in any case contain or refer to their real name.

Your e-mail address is solely used by the system for automatic notifications and password recovery. You can disable the automatic notifications in your profile. E-mail addresses are stored encrypted on our servers and cannot be viewed by unauthorised personnel.

Personally Identifiable Information is information that can be traced back to an individual (contrast with Non-Personal Information). Any information you submit can become Personally Identifiable Information if it is linked to other information that can help identify you, e.g. your pseudonym can become Personally Identifiable Information if you send a message containing your real name. So always use your pseudonym when you using any part of our service.

Submitted Information: After getting a personal account, you may use certain tools, exercises and questionnaires where you can submit information about your health and your lifestyle. This information is linked to your pseudonym and not to your real name. This information is used to personalise these tools and allows your Coach to monitor your progress. This information could also be used for statistical analysis and to improve the Online Services only when the information is not linked to your real name or to any other Personally Identifiable Information.

Messages exchanged through the messaging module can only be seen by their sender and recipient(s). They are stored encrypted on our servers and cannot be viewed by unauthorised personnel. We may gather anonymous data regarding messages for statistical analysis only (for example, the average number of messages exchanged between Coaches and End-Users during a certain period of time).

Non-Personal Information: Information collected by Web servers (standard access logs such as browser type, Internet Protocol (IP) address, page reference, etc.) and cookies (see section 3 - Use of Cookies and Access Logs for more information). Non-Personal Information is non-identifiable. This means that there is no reasonable way to identify the individual person this data was collected from.

Standard access logs are used for various purposes, including but not limited to, service evaluation and maintenance planning. Such data is aggregated and cannot be used to identify individual users. For example, aggregated data can be the percentage of persons accessing the website at a certain period of time.

Our services do not intentionally collect or store any other information not specified above.

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3. Use of Cookies and Access Logs

Cookies are a technology that can be used to provide you with tailored information from a Web site. A cookie is an element of data that a Web site can send to your browser, which may then store it on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or not. It can also be set to reject all cookies (most browsers offer instructions on how to change the browser to reject cookies in the "Help" section of the toolbar).

We use cookies only for keeping track of user sessions and logging you out automatically after a certain period of inactivity. If your browser is set to reject cookies, we won't be able to keep track of your session and you will not be able to log in to the private portion of this website. We do not link the cookie information to any information you provide.

Access logs are stored on the server for recording non-personal information such as Internet domain and host names; Internet Protocol (IP) addresses; browser software and operating system types; and dates and times that our website or Online Services are accessed.

We use this information to improve the website and its Online Services and your Web experience.

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4. Information Update and Retention

Information collected through this website and Online Services is kept secure for as long as it is necessary taking into consideration the purpose for which it is collected before being destroyed.

Personal Account Information
All users can consult, revise and update their Personal Account Information directly or with the help of an authorised account administrator at any time, except for End-Users' pseudonym that can only be changed for a valid reason such as confidential breach of the pseudonym or illegal account access.

Personally Identifiable Information If you suspect a breach of the confidentially of any Personally Identifiable Information, you should immediately contact your authorised account administrator or your Coach to correct this.

Submitted Information You can consult, revise and update any Submitted Information submitted in accordance to the instructions for each interactive tool or exercise. Some tools such as diagnostic or evaluation questionnaires cannot be changed.

Our policy is not to keep permanent records of your Submitted Information and we recommend you maintain copies of your submitted information in accordance to the Conditions of Use of these Online Services for your personal record. Coaches should also maintain copies of their End-Users' Submitted Information when the End-Users' account is inactive or before it expires.

Messages Messages exchanged are stored as a record and cannot be changed or revised. A message log, containing both messages sent and received, is available to all authorised users. All users can download a copy of their message log for their own records. Our policy is not to keep permanent records of messages and we recommend you download a copy of your message log for permanent storage before deleting any message or before your account expires. Coaches should download a record of the message log with any particular End-User when the End-User account is inactive or before it expires.

Coaches have access to all information of End-Users they supervise. Information kept by your Coach and his/her Institution is subject to the Institution's own privacy policy.

We are regularly making backups of our systems to prevent inadvertent loss of data. Therefore, copies of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. However, upon valid request, we can delete all your information from our databases actively used.

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5. Security Considerations

We have put in place, and we regularly review and update, appropriate physical, electronic and managerial procedures to safeguard and help prevent unauthorised access, maintain data security and integrity, and correctly use the information we collect online.

Personnel from NetUnion are required to protect any information collected on the site in a manner that is consistent with this Policy, for example, by not using the information for any purpose other than to carry out the services provided. NetUnion personnel shall also abide by this Policy and those who violate them are subject to disciplinary action, up to and including termination.

All communications in the private portion of the website and the Online Services go through an encrypted channel (Secure Sockets Layer protocol (SSL) with High-grade Encryption, RC4 128 bit) as long as you are logged in. Passwords, e-mail addresses and messages exchanged using the messaging module are stored encrypted on our server.

Although we take appropriate measures to safeguard against unauthorised disclosures of information, we cannot guarantee that personal information will never be disclosed in a manner that is inconsistent with this Policy.

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6. Disclosure to Third Parties

Some of your information is accessible by users from the Institution as described in section 2 - Information Collected and How It Is Used.

Apart from cases described above, information collected is not shared with any third party. We may release personal information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as a physical threat to yourself or to others. In the event that we are legally compelled to disclose your personal information to a third-party, we will notify you by the appropriate means, unless doing so would violate the law or court order.

In case we provide data to research institutions, it is always aggregated and does not contain information that might identify individuals.

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7. External Links

Our website and Online Services may contain links to other third party websites which are outside our control and are not covered by this Policy. If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours. We are not responsible for the privacy of third party websites.

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8. Acceptance

By browsing this website and using our Online Services, you acknowledge and agree to our processing of personal data in this way and to the terms of this Policy.

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Last modification: 2009-06-15 14:38:49.822456