HAKINI, INC. a corporation organized and existing under the laws of Delaware with commercial registration number 6224500 and having its registered address at 651 N Broad St, Suite 206,Middle Town, 19709 ("HAKINI, INC." or the "Company") provides an online platform at www.hakini.net (the "Platform") allowing natural persons (the "Users") to set up anonymous accounts in order to receive talk therapy services (the "Services") from licensed therapists (the "Counselors").
As such, it is HAKINI, INC.’s policy to respect the privacy of its Users and Counselors. In accordance with our general Terms of Use, the Company collects information about Users and Counselors when Users or Counselors (collectively "Persons") use or access the Services. This privacy policy (the "Policy") sets forth the ways by which any information, including any personal data the Company collects from Persons, or which Persons provide to the Company, will be processed by the Company.
Before a Person will be able to access the Services, each Person will be required to actively consent to the provisions of this Policy by affixing his or her signature to this Policy. Thereafter, each time a Person accesses or uses the Services or provides the Company with information, such Persons shall be deemed to consent to the provisions described herein.
This Policy applies to Users and Counselors anywhere in the world who access or use the Services.
2.1 Information the User or Counselor Provides to the Company.
2.1.1 This is information each Person provides to the Company about the Person by providing information: (1) during required registration processes; or (2) through correspondences with the Company (for example, by telephone, e-mail or any other digital or electronic form).
2.1.2 The personal information Persons provide to the Company may include a Person’s name, address, e-mail address and phone number, certain device information, username, password, address, and other registration information Persons may provide ("Personal Information" or "Personal Data").
2.1.3 The Company collects and processes Personal Data for specific, lawful purposes only.
2.1.4 The Services are not intended or expected to be used by minors, and minors may not use the Platform or access the Services.
2.2 Information the Company Collects about Persons. Each time a Person uses the Platform or accesses the Services, the Company may automatically collect the following information.
2.2.1 Technical Information. Technical information includes, but is not limited to, the type of mobile device a Person uses, a unique device identifier (for example, mobile network information, a Person's mobile operating system, the type of mobile browser a Person uses, device token, device type, time zone setting.
2.2.2 Log Information. Log information includes, but is not limited to, details of a Person’s use of our Website Services or App including, but not limited to traffic data, weblogs and other communication data, and the resources that a Person accesses.
2.2.3 Location Information. Location information includes, but is not limited to, information provided by GPS technology.
2.3 Other Information the Company May Collect. When Persons use the Platform, the Company may collect Personal Information as well as demographic information, for example information that a Person submits, or that the Company collects, which may include, but is not limited to, post code, age/birth date, current residence, mobile network information, a Person’s mobile operating system, the type of mobile browser a Person uses, time zone setting, device location, IP address, SMS data, transaction information, business activities, and browsing history information ("Demographic Information").
The Company may use Personal Data which Persons provide or which the Company collects to:
(1) Provide, maintain, and improve the Platform and the Services, including, for example, to facilitate payments, send receipts, provide products and services Persons may request (and send related information about them), develop new features, provide customer support to Persons, authenticate Persons, and send administrative messages, whether information or required by applicable law;
(2) Perform internal administration and operations, including, for example, to prevent fraud or abuse of our Website Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends
(3) Send communications to Persons that the Company thinks will be of interest to such Persons, including information about products, services, and promotions, where permissible under applicable laws;
(4) Notify Persons about changes to the Company’s Platform and Services;
(5) Allow Persons to participate in any interactive features of the Company’s Platform or Services;
(6) Keep the Company’s Platform and Services safe and secure;
(7) Personalize and improve the Platform and Services, including providing or recommending features, content, social connections, referrals, and advertisements, in accordance with each Person’s individual preferences.
4.1 The Company will take all steps reasonably necessary to ensure that each Person’s data is processed fairly and lawfully, in accordance with the applicable laws, and with the provisions of this Policy.
4.2 By submitting his or her Personal Data, each Person agrees to such transfer, storing, or processing in order for HAKINI,INC. to perform its general administrative and regulatory functions. Unless otherwise notified, the Company will not ordinarily engage in automated decision making when processing Personal Data.
4.3 Each Person agrees that the Company shall have the right to transfer the Personal Data described in this Policy to and from, and process and store it in, the state of Delaware and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where each Person resides. Where this is the case, the Company will take appropriate security measures to protect each Person’s Personal Data in accordance with this Policy.
4.4 To preserve the integrity of the Company’s databases, to carry out on-going Services, or to maintain the Platform, the Company retains Personal Data submitted by Users for a reasonable length of time unless otherwise prescribed by applicable law.
4.5 HAKINI, INC. is not responsible for the accuracy of the information Persons provide, and the Company will modify or update a Person’s Personal Data in its databases upon a Person’s request, as further outlined below.
4.6 The Company will erase or archive from active use each Person’s Personal Data upon request, unless the Company is required to retain it in accordance with the r applicable law. By accessing or using the Platform or Services, each Person hereby represents that he or she understands that all information such Person submits through on the Platform or through other communications to the Company may be used by the Company in accordance with applicable laws.
The Company may share Personal Data which it collects about Persons as described in this Policy or as described at the time of collection or sharing, including as follows:
5.1 Through Our Website Services or the App. The Company may share a Person’s Personal Data with third parties with whom such Person chooses to let the Company share his or her Personal Data.
5.2 Other Types of Data Sharing. HAKINI,INC. may share Personal Data: (1) With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract the Company enters into with such third parties; (2) In response to a request for information by a competent authority or government entities if the Company determines that such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process; (3) With law enforcement officials, government entities or authorities, or other third parties as required by applicable law; (4) With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; (5) If the Company otherwise notifies and receives consent from the Person or Persons whose Personal Data is being shared; or (6) With third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify the Person or Persons whose Personal Data is being shared.
6.1 Marketing and Opting Out. The Company supports each Person’s right to opt-out of receiving communications from the Company and its partners and affiliates. Each Person shall have the continuous option to ask the Company not to process his or her Personal Data for marketing purposes and to remove it from the Company’s database, to not receive future communications or to no longer be able to access the Company’s Platform or Services.
6.2 Preference Changes. Each Person acknowledges that the Company may continue to send Persons transactional or service-related communications despite a Person’s desire to not receive promotional or marketing e-mail messages. Additionally, please note that if a Person elects to opt-out of receiving promotional communications from the Company, such Person may continue to receive promotional emails from other, non-affiliated marketers whose services such Person may have accessed through hyperlinks to External Sites (defined herein) pursuant to Section 10 below.
6.3 Access to and Correction of Personal Information. Persons have the right to access information held about them. Each Person’s right of access can be exercised in accordance with applicable law. Any access request generally comes at no cost to Persons, but may, where permissible, be subject to a fee to meet any extraordinary administrative costs in providing a given Person with details of the information the Company may hold about such Person.
6.3.1 When a Person contacts the Company about a potential Personal Data error, the Company will endeavor to confirm or verify the information in question, and then the Company will correct verified inaccuracies and respond to the original inquiry. The Company will endeavor to send a correction notice to businesses or others whom the Company knows to have received the inaccurate data, where required and/or appropriate. Some third parties and third party sites may continue to process inaccurate data about Persons until their databases are refreshed in accordance with their update schedules, or until such Persons contact such third parties to ensure relevant corrections are made.
6.3.2 Persons may request that the Company restricts, erases, or otherwise processes Personal Data .
The Company may change this Policy from time to time without notice. If the Company makes significant changes to the Policy or to the way it treats Personal Data, the Company will provide all Persons with notice through email. Users will be asked to actively accept any amendments made to this Policy prior to such amendments taking effect.
8.1 The Company makes every effort to ensure that Personal Data is secure on its systems. The Company has staff dedicated to maintaining its data protection and security policies, periodically reviewing them and making sure that the Company’s employees are aware of the Company’s data protection and security practices.
8.2 HAKINI,INC. cannot guarantee that data transmission over the internet is or will be completely secure. As a result, the Company cannot warrant or guarantee the security of any Personal Data transmitted while using the Platform or accessing the Services.
8.3 The Company has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. HAKINI,INC. continually assesses its data privacy, information management, and security practices. The Company does this in the following ways:
8.3.1 Establishing policies and procedures for securely managing information;
8.3.2 Limiting employee access to viewing only necessary information in order to perform his or her duties;
8.3.3 Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required;
8.3.4 Requiring service providers with whom the Company does business to comply with relevant data privacy legal and regulatory requirements;
8.3.5 Monitoring the Company’s websites through recognized online privacy and security organizations;
8.3.6 Conducting background checks on employees and providing training to the Company’s employees.
8.3.7 If a Person has any further questions about our security and processing activities, please contact the Data Protection Commissioner’s team or refer to the Company’s Terms of Use. To the extent permitted by applicable law, HAKINI,INC. expressly disclaims any liability that may arise should any other third parties obtain Personal Data.
A cookie is a small text file that is unique to the web browser on a Person’s computer or mobile device, which is used to retain user preferences, and enhance browsing experience (a "Cookie" or "Cookies"). HAKINI,INC. uses Cookies to track overall site usage, which enables the Company to provide a better user experience. The Company does not use Cookies to access other data on a Person’s computer.
10.1 The Platform may contain hyperlinks to other websites on the Internet that are owned and operated by third parties ("External Sites"). These links are provided solely as a convenience to Persons and shall not be construed as the Company endorsing or otherwise providing an interpretation regarding the contents of External Sites.
10.2 Each Person acknowledges that the Company is not responsible for information or content provided on any External Site. Each Person should contact the site administrator or webmaster for those External Sites in the event that such Person has any concerns regarding such links or the content provided on such External Sites.
10.3 If a Person decides to access a linked third party website, such Person does so at his or her own risk. HAKINI, INC. does not accept liability, and shall not be held liable to such Person for any loss or damage arising from or as a result of such Person engaging with or acting upon the content of External Sites to which Persons may arrive at by using links appearing on the Platform.
If any User or Counselor has questions, comments, or requests related to this Policy, or if a Person has any complaints related to how the Company processes a Person’s personal information, please contact the Company at the following address.
651 N Broad Street
Suite 206
Middletown
19709
Legalinc Corporate Services, Inc
The undersigned Person hereby acknowledges and agrees to the provisions of this Policy, has full legal authority to agree to the provisions contained herein, and understands that this Policy shall govern the Company’s use of the undersigned’s Personal Information.
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