Terms of Use

This privacy policy (this “Policy”) was last updated on September 12, 2023.

Sawa Health (“we”, “our”, “us”, “Sawa Health”) takes your privacy seriously, and we want you to know how we collect, use, share and protect your information.

Introduction

At Sawa Health, we provide mental health professionals with insights and capabilities to drive improved and measurable clinical outcomes for patients receiving virtual therapeutic services on our platform. You can access our platform via the website or through our mobile application available in the app stores.

When you enroll, or inquire about enrolling for or use of Sawa Health Services (as defined below), we keep a record of the medical information that you provide to us or your therapist as well as any medical information that Sawa Health employees or independently contracted therapists provide to you via our platform (such as information on and related to your diagnosis). Medical information means any information that:

identifies you; and relates to your past, present, or future physical or mental health, treatment, the provision of health care services or payment for treatment. This includes medical history, diagnoses, treatments, current medical condition, and use of prescription medications. If you are a US subscriber to Sawa Health services, your personal information in our possession is protected health information (“PHI”) protected by the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”), and the applicable provisions of the Health Information Technology for Economic and Clinical Health (“HITECH”) Act. In addition to this Privacy Policy, the HIPAA Notices of Privacy Practices of Sawa Health or your Sawa Health Provider apply to your PHI.

This Policy explains Sawa Health’s practices where we process “personal data”, which is information that relates to an identified or identifiable individual. To “process” or “processing” means the use of personal data including, collecting, recording, storing, using, analyzing, combining, transferring, disclosing, or deleting.

We reserve the right to change the terms of this Privacy Policy at any time by posting those changes in revisions to this Privacy Policy, so that you are always aware of our processes related to collection, use and disclosure of information. We urge you to check here for any updates to this Privacy Policy from time to time. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Website or the App.

What is included in this Policy? 

Personal Data We Process & How We Use It Using the Sawa Health App Advanced Data Processing Research What choices do you have about how we collect or use your information? How can I access, delete, or modify my personal data? California Privacy Rights EU/EEA/UK Privacy Rights Retention Sawa Health and Minors Other Mobile Applications and Services Applying for a Job at Sawa Health Security How to Contact Us Additional Information for EU, EEA and UK users What is included in this Policy? The information on this page applies to the personal data we collect about your interactions, use, and experience with our website at https://sawa.health/  (our “Website”), our app on iOS or Android (our “App”), and in connection with the online therapy services we provide (the Website, App and our online therapy services are together, the “Services”). As noted below, our data practices depend on how you interact with our Services, and how you receive and pay for Services, for example whether purchasing Services as a consumer or receiving them through an employment-related benefit.

This Policy does not apply to any other websites that you visit before our Website or any third-party sites that may be accessible through the Sawa Health Services. Please read this Policy carefully so that you understand your rights in relation to personal data, and how we will process that personal data. This Policy supplements our Notice of Privacy Practices (for US patients) any other privacy related disclosures we may provide from time to time (including during your enrollment or management of your account with Sawa Health) and is not intended to override them.

If you do not want us to share personal data or feel uncomfortable with the ways we use information in order to deliver our Services, please do not use the Services.

Personal Data We Process & How We Use It 

This table presents the types of information (whether legally classified as personal data or PHI under HIPAA), the sources, and the uses.

Types of Personal DataHow We Get ItWhat we do with it
RegistrationInformation 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)AddressCountryDate of birthPhone numberGender and the preferred gender of therapistEmailRelationship statusOrganization/Employer (if applicable)Payment information and transaction historyInformation on the type of subscription you chooseInsurance information (including an image of that information)Referral sourceInformation on why you are accessing our Services including what you are hoping to get from therapyNotification preferencesYou provide this when you go through the registration processProvide you with the Services (including resubscription) To match you to a therapistProvide you with treatment informationEnroll you in services and administer your accountProvide you with supportProcess insurance claims, billing, and payment informationMaintaining the safety and security of our users, our Services, and our businessProvide announcements and communicate with you, including for marketing purposesProvide 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 informationProvide you with and to evaluate, improve and develop the ServicesConduct therapist oversightControl the quality of the ServicesPermissive reporting of abuse; expressed threats of violence towards an ascertainable victim
Use of the ServicesData 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 functionalityInformation collected via our symptom tracker and information on your clinical progressInformation collected via chat, telephone, or email support channelsInformation on friends you referInformation you provide as part of treatment intake including emergency contact details, information on your health and mental health and medical history, images (optional)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 ServicesTo provide you with the ServicesTo 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 To address patient concerns or complaintsTo carry out quality assurance and compliance activitiesremoved, or pursuant to explicit patient authorization). For more information see “Research” below. See Notice of Privacy Practices.To provide you with assistance in the event of an emergency
When Website visitors contact usWe 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 directlyTo respond and address your communicationTo provide you with the ServicesTo improve the ServicesProvide support to users (therapists and patients)
Technical Data 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 Sawa Health environment Metrics on system or App feature useInformation on system events and statusAutomatically through use of the ServicesCreate anonymized and/or aggregated data to improve and deliver our Services Comply with legal obligationsMaintain the security of our infrastructureFacilitate the delivery and optimization of ServicesMonitor performance of our data centers and networks, systems and applicationsProvide support to users (therapists and patients)Administer our business continuity and disaster recovery plans and policiesDetect, 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 ServicesTo develop new products
Persistent Identifiers Data collected via cookies, pixels and other tracking technologies (such as Google Analytics and Google Ads), such as:Internet protocol (IP) addressesDevice IDBrowser typeInternet service provider (ISP)Referrer URLGeolocation information (derived from IP Address,Exit pages, the pages and files viewed on our Website (e.g., HTML pages, graphics, etc.) Operating systemDate/time stampNOTE: Once you become a patient the use of cookies, web beacons, pixels, and other processes are limited to ensure that we do not monitor or use patient information for other purposes without your consent.Collected automatically when you use the ServicesTo provide you with and to evaluate, improve and develop the ServicesTo develop new productsAnalyze how our Services are used so we can improve your experienceEvaluate the success of our marketing campaignsMarketing, including tailoring advertising

Using Sawa Health App

The Sawa Health 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 Sawa Health only, pursuant to written agreements. Sawa Health does not sell client information to third parties.

Advanced Data Processing

The Sawa Health 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 precision therapy 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 Sawa Health counsoler) to match you to a provider. 

Optimizing Diagnosis and Treatment. Throughout your experience, your provider uses the Sawa Health 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 into patient needs and behaviors and offer techniques and suggestions that we believe are likely to maximize clinical outcomes.

What choices do you have about how we collect or use your information?

When you create a Sawa Health account or otherwise use the Sawa Health 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 by emailing us to support@sawa.health.

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 Sawa Health.
  • Limit the use of cookies, pixels, or web beacons. 
  • 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 support@sawa.health

How can I access, delete, or modify my personal data?

You may request access to or deletion of your Personal Information. We will honor your request regardless of where you live or are physically located unless a legal requirement prevents us from doing so or a legal exception applies. Please complete the appropriate request form below and email the completed form with a copy of your photo identification to support@sawa.health.

Your California Privacy Rights

If you are a resident of the State of California, this privacy policy is supplemented by our California Privacy Rights Statement that explains certain California privacy rights and how affected parties can exercise these 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).

Retention

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. 

Sawa Health and Minors

In the United States, Sawa Health may collect information and may provide Services to minors ages 13 – 17 with the written authorization of a parent or guardian..  

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 Sawa Health Website or App. 

Security

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 Sawa Health user may choose to share information. As such, you should be cautious about the access you provide to others when using Sawa Health, and the information you choose to share when using the Sawa Health 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 support@sawa.health