Privacy Policy

Your privacy is very important to us. Company and its related companies has created this Privacy Policy to demonstrate our firm commitment to privacy and security (“Privacy Policy”). Capitalized terms and other terms used but not defined in this Privacy Policy are defined in the Terms, which are incorporated herein by reference. This Privacy Policy describes how Company collects information from EMDR Clinicians and Visitors who either visit our Site and/or use our Services, what we do with the information we collect, and the choices you have concerning the collection and use of such information. We request that you read this Privacy Policy carefully.

You also agree that your electronic consent will have the same legal effect as a physical signature. You acknowledge that by accepting this Privacy Policy, you have read, understood and agree to be bound by Company’s Privacy Policy.

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) and other information gathered when you are using or accessing the Site and the Services. While Company may collect Personal Information from EMDR Clinicians for payment for the Software or other purposes (as set forth below), Company does not collect Personal Information from EMDR Clinician’s Patients or Visitors to the Site, unless such Patients or Visitors contact the Company by email or consent to receiving emails from Company. This Privacy Policy also does not apply to the practices of third parties that we do not own or control, like third party websites, services, applications and payment processors (if any) (“Third Party Services”). While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services, and any links from our Site to third parties do not imply that we endorse or have reviewed the Third Party Services. We encourage you to review the privacy policies of any Third Party Services you access.

1.         Introduction

Company collects information in different ways from you depending upon whether you are a Visitor or an EMDR Clinician that access the various parts of our Site and/or the Services. We use this information primarily to provide a customized experience as you use our Site and/or the Services, and also to collect, transfer, manipulate, store, and disclose for purposes of measuring and improving our Site and the Services and to send you information about our Site and/or Services or to advertise additional services to you.

In order to offer an enjoyable and premium experience on our Site and Services, we collect information which may personally identify EMDR Clinicians only (e.g., name, address and email); and we collect information from you that visit our Site that does not identify you individually (e.g., aggregate information on the number and frequency of visits to various pages of the Site).

We receive information from various sources, including: (i) information that EMDR Clinicians provide to us when they purchase the Software and/or use the Services generally; (ii) how Visitors use the Site; and (iii) from third party websites and services (if applicable).

From time to time, Company may notify you of new products, announcements, upgrades and updates if you provide us with your email address. You may also opt-out of these promotional mailings by sending your name to innovativebilateraldesigns@proton.me. Similarly, if we have collected and processed EMDR Clinicians’ Personal Information with their consent, then they can withdraw their consent at any time.

You can also always unsubscribe from receiving messages by e-mailing us at innovativebilateraldesigns@proton.me.. We use EMDR Clinician’s Personal Information for the purpose of providing them with the Site and/or the Services, verifying their authority to enter our Site and/or use the Services, improving the content, customer management, general administration of the Site and/or the Services, providing EMDR Clinicians with notices regarding the Site and/or the Services that they have purchased or for Visitors who may wish to purchase our Services in the future, and for targeted marketing purposes (if applicable).

2.         Information Collected

We collect information to operate, maintain, and provide you with the features and functionality of the Site, the Services, and to communicate directly with you. We may also send EMDR Clinicians service-related emails or messages (e.g., verification, change or updates to features of the Site or the Services, technical, and security notices). We may use your data to inform you about additional products and services and, if applicable, to ask you about our products and services. Of course, participation in such activities is voluntary. If you do not wish to take part, you can notify us at any time so that we can exclude your data accordingly.

When you interact with us through the Site and/or the Services, we may collect information from you as follows:

We may periodically conduct both business and individual surveys. We encourage EMDR Clinicians to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to our EMDR Clinicians. EMDR Clinicians’ Personal Information and responses will remain strictly confidential, even if the survey is conducted by a third party. Participation in our surveys is entirely voluntary.

We may take the information we receive from EMDR Clinicians who respond to our surveys and combine (or aggregate) them with other EMDR Clinicians’ responses to create broader, generic responses to the survey questions (such as gender, age, education, employment, or other demographic information). We then use the aggregated information to improve the quality of the Services and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties.

3. Personal Information Automatically Collected

We and our third party partners (if any), may automatically collect certain types of usage information when you visit our Site or use our Services, read our emails (if you agreed to receive our emails), or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technologies. For example, we automatically collect Personal Information as follows:

General Usage Data: Generally, the Site automatically collects usage information, such as the pages that you visit on our website, the date of your visit, server type, the operating system, browser number and frequency of Visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often individuals use parts of the Site so that we can analyze and improve them.

Domain and IP Address Information and Other Browser Information: We automatically receive and record information from your web browser when you interact with the Site, including, but not limited to, your IP address and cookie information, browser type, operating system, web pages viewed while visiting our Site, links clicked (if applicable), length of time spent on our Site, etc.. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Site (for example, what links you have clicked on) and to provide custom, personalized content and information. These cookies do not contain or track sensitive information such as payment information.

Email Communications: We may receive a confirmation when you open an email from us. In addition, when you send email inquiries to the Company, the return email address is used to answer the email inquiry we receive. The Company does not use the return email address for any other purpose and does not share the return email address with any third party.

By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Information through the Site or the Services, you acknowledge and agree that such Personal Information may be transferred to us and the authorized third parties referred to herein.

Non-Identifiable Information: When you interact with the Site, we receive and store certain personal, non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store this information and we may use it and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of your Internet service providers. It is important to note that no Personal Information is available or used in this process.

Aggregated Personal Information: In an ongoing effort to better understand and serve you, we may collect statistical information about how EMDR Clinicians use the Services (“Aggregate Information”). Some of this information may be derived from Personal Information. The Aggregate Information may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with affiliates, agents, business partners and potential investors. This Aggregate Information is not Personal Information and does not identify you or your web browser personally.

4.         Our Use of Your Personal Information and Other Information

We utilize information that is collected in various ways. For example, information collected helps our efforts to advance your online experience when visiting the Site and/or using our Services, including accessibility, improving content, customer service, and overall service satisfaction. In addition, we use information that we collect to assist with product development efforts, response to mandated legal notices, to provide you with products or services you request from us, to improve your overall experience with the Site and/or the Services, for internal analytics purposes, to troubleshoot technical difficulties and errors, to notify you about changes to the Site and/or the Services, and in any other way we may describe to you at the time you provide the information. Company and Company Representatives. We may also use your Personal Information and other personally non-identifiable information collected through the Site and the Services to help us improve the content and functionality of the Site and/or the Services and to better understand you.

In instances where Company and a partner jointly promote the Site and/or the Services, we may provide the partner certain Personal Information of our EMDR Clinicians that use our Services, such as the name, e-mail address, and age or if you consent to providing us with such information if you are not an EMDR Clinician as a result of the joint promotion for the sole purpose of allowing us and the partner to assess the results of the promotion. However, in this instance, Personal Information may not be used by the partner for any other purpose. We may also generate non-identifying and aggregate profiles from Personal Information EMDR Clinicians provided to us when they purchased the Software or if the EMDR Clinician consents to providing such information (such as the total number, but not the names, of the EMDR Clinicians or those who consent to us using their Personal Information that are not EMDR Clinicians. As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Site and/or Services.

5.         Our Disclosure of EMDR Clinician’s Personal Information

We do not store Patient Personal Information. We do, however, store EMDR Clinician Personal Information when they purchase the Software. Thus, it is Company’s policy not to use or share the Personal Information about EMDR Clinicians in ways unrelated to the ones described above without also providing EMDR Clinicians an opportunity to opt out or otherwise prohibit such unrelated uses. There are, however, circumstances in which we may share EMDR Clinicians’ Personal Information with certain third parties without further notice, including:

Information Shared with our Agents: We may sometimes hire other parties or vendors to perform certain tasks on our behalf ( “Agents”) which may include, but is not limited to, providing financial services, web hosting, or providing analytic services. For example, we may provide EMDR Clinician Personal Information to our credit card processing company to process EMDR Clinicians’ payment. This sharing is only done when those Agents are performing functions solely on our behalf and they are not permitted to store such information except as needed to perform our work or as required by law.

Information Disclosed Pursuant to Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, EMDR Clinician Personal Information may be part of the transferred assets.

Information Disclosed to Company’s Representatives: We may also share EMDR Clinician Personal Information with Company’s Representatives for purposes consistent with this Privacy Policy.

Information Disclosed Due to Legal Requirements or For Our Protection or the Protection of Others: THE SITE AND THE SERVICES PROVIDED BY US MAY BE HIGHLY REGULATED BY VARIOUS GOVERNING AGENCIES. IT MAY BECOME NECESSARY TO SHARE THE INFORMATION THAT WE COLLECT WITH SUCH AGENCIES TO COMPLY WITH LAWS, A JUDICIAL PROCEEDING, COURT ORDER, OR OTHER LEGAL REQUESTS. We may also disclose EMDR Clinician Personal Information if we believe it is necessary to (i) satisfy any legal obligation or governmental request, (ii) enforce the Terms, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our EMDR Clinicians who paid for the Software and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Aggregate Information: We may share Aggregate Information with our partners, service providers and other persons with whom we conduct business. This Aggregate Information does not identify EMDR Clinicians or those that consent to submitting their Personal Information to Company personally.

6.         Opt Out

If EMDR Clinicians or those that consent to submitting their Personal Information to Company wish to access and correct or remove any Personal Information that we hold about them, please contact us at innovativebilateraldesigns@proton.me and we will respond to requests in writing or other means necessary as soon as possible and in accordance with applicable law whether and what Personal Information relating to them has been stored by us. In addition, EMDR Clinicians and those that consent to submitting their Personal Information to us can object to processing of their Personal Information, ask us to restrict processing of their Personal Information or request portability of their Personal Information.

Be aware, however, that in the event an EMDR Clinician who purchased our Software modifies their Personal Information that we hold about them, we may need to run another pre-verification check on them. Please note that it is not always possible to completely remove or delete all Personal Information from our databases and that residual data may remain on backup media or for other reasons. If an EMDR Clinician who purchased our Software or those that consent to us having their Personal Information edits their Personal Information or changes their preferences on the Site or the Services, Personal Information and/or preferences on the Site or the Service that they remove may persist internally for our own administrative purposes.

You may cancel or modify marketing communications you receive from us by following the instructions contained on our Site or within our promotional e-mails. If your opt-out preferences are limited to certain types of e-mails, then the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your use of our Services, such as administrative and service announcements, and these transactional messages may be unaffected even if you choose to opt out from receiving our marketing communications.

7.         Security

Some of your user information and data you upload to the Site and/or the Services are password-protected for your privacy and security. We take other reasonable steps to secure your Personal Information, and to protect it from misuse, loss, unauthorized access or modification. Our security measures are continually improved in line with technological developments. Although Company uses commercially reasonable safeguards to protect your Personal Information, the Internet is inherently nonsecure and we cannot guarantee that the Site and/or the Services or your information is secure (“hacker-proof”). When your Personal Information is no longer required by Company, we destroy or permanently de-identify the information within one (1) year of the date that the EMDR Clinician purchased the Software or if others provide their Personal Information to us. In the event of a breach, we will promptly notify you.

8. “Cookies” and How Our Company Uses Them

We use cookies and similar technologies, such as HTML5 web storage and local shared objects (all referred to as “cookies” below), to record your preferences and optimize the design of the Site. They make navigation easier and increase the user-friendliness of the Site.

A “cookie” is a small data file that can be placed on your hard drive when you visit certain websites. Company may use cookies to collect, store, and sometimes track information for statistical purposes to improve the products and services we provide and to manage our telecommunications networks. This may include your server address, domain name, date and time you visited the site, pages viewed and the information downloaded and other aggregate data through our use of cookies. If you prefer not to receive cookies, you can disable your cookies by adjusting your browser, but you will not be able to participate in some of the services offered by Company.

By using our website, you consent to the use and storage of cookies on your end device. However, you can also view our Site without cookies. Most browsers accept cookies automatically. You can prevent cookies from being saved on your end device by setting your browser to not accept cookies. You can delete cookies stored on your end device at any time. The exact instructions for how to do this can be found in the manual for your browser or end device. If you choose not to accept cookies, it may result in a reduced availability of the services provided on our Site. By using our Site without deleting or rejecting some or all cookies, you agree that we can place those cookies that you have not deleted or rejected on your device.

We categorize cookies as follows:

Essential cookies (type 1): These cookies are essential for websites and their features to work properly. Without these cookies, services such as the vehicle configurator may be disabled.

Functional cookies (type 2): These cookies enable us to improve the usability and performance of websites and to provide various features. Functional cookies can store language settings, for example.

Performance cookies (type 3): These cookies collect information about how you use websites. Performance cookies help us, for example, to identify especially popular areas of our Site. In this way, we can adapt the content of our Site more specifically to your needs and thereby improve what we offer you. These cookies do not collect personal data. Further details on how the information is collected and analyzed can be found in the section, “Analysis of usage data.”

9. Age Verification: Children

THE SITE AND THE SERVICES REQUIRE YOU TO BE EIGHTEEN (18) YEARS OR OLDER AND THE SERVICES ARE ONLY FOR EMDR CLINICIANS TO USE WITH THEIR PATIENTS.  PATIENTS UNDER THE AGE OF 18 YEARS OF AGE ARE NOT PERMITTED TO USE OUR SITE OR SERVICES WITHOUT THE WRITTEN CONSENT OF A PARENT OR GUARDIAN.

Furthermore, Patients under 18 years old may not download the Software or participate in an EMDR session with an EMDR Clinician absent the parent or guardian execute all required written consents required by the EMDR Clinician, including guardian or parental consent for their child to engage in EMDR therapy and agrees to be available to join the session if needed or requested by EMDR Clinician.

DUE TO THE AGE RESTRICTIONS FOR USE OF THIS SITE AND THE SERVICES, NO INFORMATION OBTAINED BY THE SITE AND/OR THE SERVICES, FALL WITHIN THE CHILD ONLINE PRIVACY ACT (COPA) AND IS NOT MONITORED AS DOING SO.

10. California Do Not Track Policy

We do not track you over time and/or across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, you can modify the preferences on your browser to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. Please consult your browser for instructions on how to change the preferences to “Do Not Track.”

11. Your California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or affiliates for those third parties or affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. We do not store any non-EMDR Clinician Personal Information, unless you send us an email or agree to receive emails from us. If you are a California resident and would like a copy of this notice, please submit an email request by emailing us at innovativebilateraldesigns@proton.me. In your request, please specify in the subject line that you want a “Your California Privacy Rights Notice.” Please allow at least thirty (30) days for a response.

12.       Colorado, Connecticut, Utah, and Virginia Residents Privacy Rights

The Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act each provide certain rights to residents of Colorado, Connecticut, Utah and Virginia, respectively. This section applies to you if (a) you are an EMDR Clinician or a non-EMDR Clinician who sends emails to us or agrees to receive emails from us, (b) a natural person who is a resident of the States of Colorado, Connecticut, Utah or the Commonwealth of Virginia and (c) use our Services (each and all of whom shall be referred to collectively, as the “Consumer”). This section supplements the information in the Privacy Policy. Certain terms used below have the meanings given to them in the respective laws.

13. EU and EEA Personal Information Data

Types of information we collect from EU and EEA citizens.

If you are an EMDR Clinician or a non-EMDR Clinician who sends us emails or agrees to receive emails from us and an EU or EEA citizen, the types of information we collect are cited above. In addition, this section supplements the information in the Privacy Policy. The kind of information we collect include:

(1)       EMDR Clinicians’ first and last name, email address, company name, address (city, state/province, ZIP/postal code, country), secondary emails, phone number or non-EMDR Clinician emails send to us or when a non-EMDR Clinician agrees to receive emails from us.

(2)       Payment information includes bank information (applies to EMDR Clinicians only).

(3)       Usage data includes internet protocol (IP) address, browser user agent, activity (web pages visited), and/or cookies for auth/sessions.

(4)       Communication data includes name, email address, message/subject, user activity.

(5)       Visitor data includes internet protocol (IP) address, browser user agent, browser request headers/metadata, referring URL/site, user activity on the landing page (which ad clicked, what sort of ad/category the visitor has shown interest in), session cookies.

The purposes for which we use Personal Information data.

Company, as a data controller, may only use your Personal Information data if there is a lawful basis for such use. The most common lawful bases used by Company are:

(1) Consent: in some cases, we may process your Personal Information data only if we obtain your prior consent;

(2) Performance of a contract: we will require EMDR Clinician Personal Information data to be able to offer EMDR Clinicians the Services in accordance with the contract terms between you and us;

• Compliance with a legal obligation: due to the nature of the Services we provide, the laws applicable to our activities require us to collect and store certain data about you; and

(4) Legitimate interests: sometimes we rely on our legitimate interests to process your data (e.g., to improve our Services) and we will do so except where such interests are overridden by your interests or fundamental rights and freedoms.

How we use your Personal Information data.

Below you will find a table describing how we may use your Personal Information data and which of the legal bases are used by the Company to ensure lawful data processing.

If you fail or refuse to provide your Personal Information data we need to provide the Services to you or if the processing of Personal Information data is necessary for compliance with our legal obligations, you will not be able to access the Services.

Sources of Personal Information data.

Most of the Personal Information data we process about you is received directly from you. For example, when you register to use the Services or communicate with us, we may receive your Personal Information data from you. In other cases, we may receive Personal Information data about you from various third parties and publicly accessible sources, including but not limited to banks, payment service providers, advertising networks, analytics providers, etc. When you use the Services, we may also automatically collect Usage data through the use of cookies and similar technologies.

How we protect your Personal Information data.

We take all reasonable and appropriate technical and organisational measures to protect all Personal Information data collected by us from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

How long we keep your Personal Information data.

Generally, we will retain your Personal Information data for as long as necessary to fulfill the specific purpose we collected it for, including the purpose of satisfying any legal, accounting, reporting requirements and our legitimate interests if you are an EMDR Clinician. For example, most of your Personal Information data will be retained up to 3 years after the end of the business relationship with us. However, we may need to keep certain information (e.g. Payment and Tax information) for longer in order to comply with our legal obligations. In certain cases, the authorities may require us to store the Personal Information data longer if they deem necessary (e.g., in case of an ongoing investigation).

Your rights.

With regards to our collection and processing of your Personal Information data, you have the right to (subject to applicable exceptions):

(1)       Obtain confirmation from us as to whether we process your Personal Information data.

(2)       Access your Personal Information data processed by Company.

(3)       Correct your Personal Information data.

(4)       Withdraw consent and remove your Personal Information data we collected on the basis of your consent (e.g. to opt out from marketing communications from us).

(5)       Obtain restriction of processing, for instance, where you contest the accuracy of your Personal Information data for a period enabling us to verify the accuracy of the Personal Information data.

(6)       Have your Personal Information data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

(7)       Erasure of your Personal Information data under certain circumstances. See more information about our data retention obligations in section “How long do we keep your Personal Information data” above.

(8)       Object to our processing of your Personal Information data when the processing is related to the performance of our task carried in the public interest or the exercise of official authority vested in us.

If you wish to make use of any of the above rights, please contact us stating your name and question related to any of the above rights at innovativebilateraldesigns@proton.me. 

Company will endeavour to provide you with information on the actions it has taken on your request related to your rights, specified above, within 1 (one) month of receipt of the request. That period may be extended by 2 (two) further months if the request is complex, or if Company is in the process of resolving a large number of requests. We will inform you if any such extension is required within 1 (one) month of receipt of the request, together with the reasons for the delay.

14.       Other Privacy Rights

In addition to your rights of access, correction, deletion and data portability, as described in the Privacy Policy, you may have certain additional rights in connection with the Personal Information data we collect about you, many of which are subject to exceptions under applicable law:

•           The right to non-discrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your rights.

•           The right to opt out of the sale and/or processing of your Personal Information data. You have the right to opt out of the sale of your Personal Information data to a third party and/or the processing of your Personal Information data for the following purposes: (i) targeted advertising; and (ii) profiling. We do not sell your Personal Information data as defined under applicable law. If you are a Colorado, Connecticut, Utah, or Virginia resident, you may nevertheless email us using the information below to exercise your right to opt out of sale under applicable law.

To submit a request under this section, contact us at innovativebilateraldesigns@proton.me. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your Personal Information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

How we share your Personal Information data,

We do not share your Personal Information with third parties, except as described in this Privacy Policy.

Company may engage service providers and partners to assist with delivery of the Services:

In case your Personal Information data is provided to service providers outside the EEA and where applicable, we will implement appropriate safeguards to protect your Personal Information data, including Standard Contractual Clauses as adopted by the European Commission. Please contact us at innovativebilateraldesigns@proton.me if you want further information on the specific mechanism used by us when transferring your Personal Information data out of the EEA. Moreover, Company requires its service providers to implement appropriate security measures to ensure the protection of your Personal Information data in accordance with applicable data protection legislation.

In other cases, we may disclose your Personal Information data:

•           to the relevant government agencies and regulatory authorities when required by the applicable laws;

•           with affiliates and subsidiaries within the Company, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future after they are made part of the Company;

•           in the event of any merger, acquisition, sale or change of control or a similar transaction or proceeding;

•           with professional advisors, such as lawyers, accountants, and auditors;

•           if you have consented to the disclosure;

•           to establish, exercise or defend legal claims.

15. Where to Direct Questions About Company’s Privacy Policy

If you have questions about this Privacy Policy or our privacy practices, or if you are seeking to exercise any of your rights, you may contact us at innovativebilateraldesigns@proton.me.

If you are a resident of the EU or the EEA, you have the right to lodge a complaint with the data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

16. Revisions to This Policy

Company reserves the right to revise, amend, or modify this Privacy Policy and our other policies and agreements at any time and in any manner, by updating this posting. Continued use of the Site and/or the Services after any changes to the Privacy Policy indicates your agreement with the revised Privacy Policy.

Last updated July 30, 2024