Infinit Care Privacy Policy

Last updated: August 1, 2024

This privacy policy sets out how Infinit Care uses and protects any information that you give Infinit Care when you use our website, applications or services (hereafter "services").

Infinit Care is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using Infinit Care's services, then you can be assured that it will only be used in accordance with this privacy statement. Infinit Care is committed to comply with the Philippine Data Privacy Act of 2012 (DPA) in order to protect your right to data privacy.

Infinit Care may change this policy from time to time by updating this page. If we make any changes to the policy, we will notify you by email in advance.

This policy explains in general terms:

• The purpose/s and legal bases for the processing of your personal data that Infinit Care collects from you when coaching/counseling sessions and other related activities are conducted and documented using Zoom and other video conferencing applications;
• The measures in place to protect your data privacy; and
• The rights that you may exercise in relation to such information.

The term Infinit Care/us/we refers to the company "Infinit Care" and the company's authorized personnel.

The term you/your refers to all clients of Infinit Care whose information are processed using Zoom and other video conferencing applications.

PERSONAL DATA COLLECTED FROM CLIENTS, THE PURPOSE/S AND LEGAL BASES FOR PROCESSING SUCH INFORMATION

Collection of information

When you register and when you use Infinit Care's services, you provide information such as your name, email address, mobile number and other relevant personal data. Infinit Care needs to process your personal information to identify you and to provide you with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations.

Attendance may be checked for generating meeting reports. These reports may contain your name, email address, and attendance status (ex: late, no show, present). Personal data are collected to verify your identity and prevent fraud.

During coaching/counseling sessions and other related activities using video conference applications the following pieces of information may be collected and processed: your name, image, personal views, anecdotes, including details that you share during the session.

Your life coach/counselor may, with your consent, record sessions. Such recordings may be made for the following purposes: quality control, training, view or review sessions to further support you, conduct research and assessment, and build predictive models to improve the Vendor’s services.

Authorized personnel may process user information and related information and statistics about sessions such as audio, video, network quality information, and others to provide technical support and advisories for users.

Infinit Care may also process your personal data for purposes allowed by the DPA and other applicable laws, including the following:

• To compile statistics and conduct research, subject to applicable guidelines;
• To comply with other applicable statutory and regulatory requirements, including directives, issuances, memoranda, or by obligations of Infinit Care to any competent authority, law enforcement agencies, and others;
• To establish, exercise, and defend legal claims; and
• To fulfill other purposes directly related to the above-stated purposes.

How Infinit Care Obtains Your Consent

By registering and using Infinit Care's services through video conferencing apps used by your life coach/counselor to offer coaching/counseling sessions, you certify that you:

• Have read this Privacy Policy which was sent to your registered email address and other invitations containing the link to your session/s;
• Understand that Infinit Care must process your personal data in order to carry out its registered services; and
• Grant your consent to and recognize Infinit Care's authority to process your personal data pursuant to this Privacy Policy.

What personal information do we collect?

A. Personal data information by users

Currently, we collect the following personal information provided directly by users:

• User profile information
• Required: Email, First name, Last name, Phone number
• Employee information (if applicable): Company name, company site, work level, gender, age group, department, account
• Dependent information (if applicable): Full name, relationship
• Emergency contact information (if applicable): Full name, relationship
• Mood tracking data (daily mood logs)
• User-generated content (journaling notes)
• Assessment responses (wellbeing assessment)
• Preferences (counseling and mental health topics)
• Recording of counseling or coaching session

As with many online services, Infinit Care requires that you provide us with some personal information in order to set up your account and use our service (for example, your name and an email address). However, most of the personal information listed above is not required. Users can choose to provide this information if they wish to share it with other users or to help Infinit Care improve its services. If you do not provide us with the required personal information, we will not be able to set up an account for you and you will not be able to use Infinit Care’s services.

Rights of the Subject Data

In compliance with Republic Act 10173 ‐ Data Privacy Act of 2012 (DPA) and other applicable laws and regulations, Infinit Care recognizes the Rights of the Subject Data.

Rights of the Data Subject. ‐ The data subject is entitled to:

• Be informed whether personal information pertaining to him or her shall be, are being or have been processed;

• Be furnished the information indicated hereunder before the entry of his or her personal information into the processing system of the personal information controller, or at the next practical opportunity:

  1. Description of the personal information to be entered into the system;
  2. Purposes for which they are being or are to be processed;
  3. Scope and method of the personal information processing;
  4. The recipients or classes of recipients to whom they are or may be disclosed;
  5. Methods utilized for automated access, if the same is allowed by the data subject, and the extent to which such access is authorized;
  6. The identity and contact details of the personal information controller or its representative;
  7. The period for which the information will be stored; and

  8. The existence of their rights, i.e., to access, correct, as well as the right to lodge a complaint before the Commission.

     Any information supplied or declaration made to the data subject on these matters shall not be amended without prior notification of data subject: Provided, That the notification under subsection (b) shall not apply should the personal information be needed pursuant to a subpoena or when the collection and processing are for obvious purposes, including when it is necessary for the performance of or in relation to a contract or service or when necessary or desirable in the context of an employer-employee relationship, between the collector and the data subject, or when the information is being collected and processed as a result of legal obligation;

• Reasonable access to, upon demand, the following:

  1. Contents of his or her personal information that were processed;
  2. Sources from which personal information were obtained;
  3. Names and addresses of recipients of the personal information;
  4. Manner by which such data were processed;
  5. Reasons for the disclosure of the personal information to recipients;
  6. Information on automated processes where the data will or likely to be made as the sole basis for any decision significantly affecting or will affect the data subject;
  7. Date when his or her personal information concerning the data subject were last accessed and modified; and
  8. The designation, or name or identity and address of the personal information controller;

• Dispute the inaccuracy or error in the personal information and have the personal information controller correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. If the personal information have been corrected, the personal information controller shall ensure the accessibility of both the new and the retracted information and the simultaneous receipt of the new and the retracted information by recipients thereof: Provided, That the third parties who have previously received such processed personal information shall he informed of its inaccuracy and its rectification upon reasonable request of the data subject;

• Suspend, withdraw or order the blocking, removal or destruction of his or her personal information from the personal information controller’s filing system upon discovery and substantial proof that the personal information are incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or are no longer necessary for the purposes for which they were collected. In this case, the personal information controller may notify third parties who have previously received such processed personal information; and

• Be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal information.

  Transmissibility of Rights of the Data Subject. ‐ The lawful heirs and assigns of the data subject may invoke the rights of the data subject for, which he or she is an heir or assignee at any time after the death of the data subject or when the data subject is incapacitated or incapable of exercising the rights as enumerated in the immediately preceding section.

  Right to Data Portability. ‐ The data subject shall have the right, where personal information is processed by electronic means and in a structured and commonly used format, to obtain from the personal information controller a copy of data undergoing processing in an electronic or structured format, which is commonly used and allows for further use by the data subject. The Commission may specify the electronic format referred to above, as well as the technical standards, modalities and procedures for their transfer.

  Non-Applicability. ‐ The immediately preceding sections are not applicable if the processed personal information are used only for the needs of scientific and statistical research and, on the basis of such, no activities are carried out and no decisions are taken regarding the data subject: Provided, That the personal information shall be held under strict confidentiality and shall be used only for the declared purpose. Likewise, the immediately preceding sections are not applicable to processing of personal information gathered for the purpose of investigations in relation to any criminal, administrative or tax liabilities of a data subject.

B. Data from the use of the Infinit Care website

Infinit Care collects anonymous data from the use of our website. This data includes, for example, the responses that users input in the counseling intake form, as well as user choices they make on our website (for example, which counselor they wish to work with).

C. Analytics Data

1. Data Collection

Infinit Care utilizes Mixpanel, a third-party analytics service, to gather information about user interactions with our website, mobile application and services. Mixpanel collects various types of data, including:

• Device Information: This includes details such as your device type, operating system, browser type, and screen resolution. This helps us optimize your experience across different devices.
• Usage Information: We collect information about how you navigate and interact with our web and mobile applications and services. This includes pages visited, actions taken and time spent on each page.
• Geographical Information: Mixpanel may capture your general geographic location, which helps us understand the distribution of our user base.
• Referral Sources: We may collect data about the sources that referred you to our website, such as search engines, social media platforms, or referral links.

2. Data Usage

The data collected through Mixpanel is used to improve our web and mobile applications and services. We analyze this information to gain insights into user behavior, preferences, and trends. This allows us to enhance user experience, tailor content, and make informed business decisions.

3. Data Retention

Mixpanel retains collected data for a limited period necessary for analysis purposes. Your personal data shall be securely kept for as long as the above purposes for processing such data exist, in order to establish or defend legal claims, or as otherwise allowed by the DPA and other applicable laws.

4. Data Security

We take data security seriously. We have implemented appropriate technical and organizational measures to safeguard the data collected through Mixpanel. Access to this data is restricted to authorized personnel only, and all reasonable efforts are made to prevent unauthorized access, use, or disclosure.

5. Opt-out

If you prefer to opt-out of data collection via Mixpanel, you can do so by adjusting your browser settings to disable cookies or by utilizing browser add-ons. However, please note that opting out may affect your experience on our website.

What do we do with the personal information we gather?

We collect and store your personal information for the following reasons:

• To run our service effectively
• To improve our products and services
• To understand your needs and provide you with a better service

We may use personal information

• To periodically send informational or promotional emails about mental health, Infinit Care products or other information that we think you may find interesting using the email address that you have provided. Infinit Care provides you with the option to unsubscribe from such emails.
• To contact you from time to time by email for market research purposes.
• As part of reports containing anonymized, aggregated employee data provided to the company or other organization that is paying for your use of Infinit Care’s services.

Service providers

We may employ third party companies and individuals to help us provide services (including web hosting and customer support). If these third parties have access to your personal information, it is only to perform tasks on our behalf and they are obligated not to disclose or use your personal information for any other purpose.

Controlling your personal information

You can contact Infinit Care at any time to

• Request access to information that Infinit Care has about you
• Correct any information that Infinit Care has about you
• Delete information that Infinit Care has about you

You may choose to restrict the collection or use of your personal information in the following ways:

• Whenever you are asked to fill in a form as part of our services, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by clicking the “Unsubscribe” link at the bottom of emails you receive from Infinit Care or by emailing us at [email protected].

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties that we think you may find interesting if you tell us that you wish this to happen. You have the option to opt out of this service by going to your account settings or by emailing us at [email protected]. Infinit Care will continue to hold your data for as long as we need it to serve you and to perform other Infinit Care purposes listed above. (Please see the description above of what we do with your personal information.) If you have deactivated your Infinit Care account or are no longer an active user, we may delete your personal information that we no longer require. We may also continue to hold your personal information for the period of time that we need to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Security

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. You have a right to file a complaint with a competent supervisory authority.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our services in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with better services, by enabling us to monitor which web pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our services.

Links to other websites

Our website and applications may contain links to other websites of interest. However, once you have used these links to leave our website or applications, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Business transaction

If Infinit Care is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

Children's privacy

Our Service does not address anyone under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

Contacting Infinit Care

You can contact Infinit Care at any time to request, correct or delete information that Infinit Care has about you. If you have any additional questions about Infinit Care’s storage of data, please contact us as soon as possible at [email protected]. You can also contact our Data Protection Officer (DPO) at [email protected]. We will promptly respond to your request.