One More Light AI Pvt Ltd (“One More Light,” “we,” “us” and “our”) provides a virtual emotional support platform intended to increase access to peer care and support and promote early detection of mental health symptoms that predict the onset of mental illness. Privacy is extremely important to us, so we have taken several steps to protect your information and put you in control.

This privacy policy (“Privacy Policy”) describes how we collect, use, disclose and store Personal Information you provide to us through the website and mobile application tools that provide the services described above (collectively, the “Services”). Please review this Privacy Policy carefully and in its entirety. If you have questions about this Privacy Policy, you can contact us at the One More Light Help Center.

This Privacy Policy describes:

• The Personal Information we collect when you interact with the Services;
• How we use and process the Personal Information that we collect;
• How we may share Personal Information with third parties; and
• The security of your Personal Information.

The following parties will comply with this Privacy Policy:

• All One More Light employees, contractors and volunteers.
• All affiliated entities and applications.

1. User Consent and Incorporation
   PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you submit your Personal Information to or through the Services, you consent to the collection and processing of your Personal Information as described in this Privacy Policy. By using the Services, you accept the terms of this Privacy Policy, our Terms of Use and consent to our collection, use, disclosure and retention of your Personal Information as described in this Privacy Policy. You also consent to One More Light sending marketing communications to the email address you provide. You may opt-out (unsubscribe) to these emails at any time.

2. Effective Date and Changes to Privacy Policy
   The Effective Date of this Privacy Policy is set forth at the top of this Privacy Policy. We may change this Privacy Policy from time to time at our discretion. Changes will be posted to this page. We encourage you to return to this page frequently so that you are aware of our current privacy practices. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

3. Personal Information We Collect
   You may or may not share certain Personal Information to avail our Services. “Personal Information” may include contact information such as your first name, last name, email and phone number. One More Light does not consider Personal Information to include information that has been anonymized so that it does not allow a third party to identify a specific individual.

• Log Data. When you use our Services, we store, process and transmit your information about how you use our services, which we use to engage, educate and suggest behavioral activation strategies to you. When you contact us, we keep a record of email and chat communications to address and resolve any issues you are facing.
• Surveys. From time to time we may collect Personal Information from customers via surveys. This information is used solely to improve the content of our web pages and the quality of our service and is not shared with any third parties.
• Technical Support Requests. If you need technical support related to One More Light’s Site or Listening Platform, you will need to complete a form for the purposes of defining and clarifying your technical support request. When submitting a technical support request, you will be asked to provide Personal Information, including an email address and a description of the issue. We maintain copies of all technical support requests and other information submitted with or related to such requests.
• Browser Information and Cookies. We use browser information (e.g., IP addresses and browser types), cookies and pixel tags to determine what data or information should be shown on your browser when you are visiting One More Light’s Site. We may also use browser information, cookies and pixel tags: to determine how you arrived at One More Light’s Site, to determine whether you are a return visitor, to help us improve our platform, for quality assurance and training purposes.

4. How We Use Your Personal Information
   We may use Personal Information that we collect about you for various purposes, including:

• To operate, provide and improve our platform;
• To communicate with you regarding our platform, and promotions;
• To ensure network and information security; and
• To share with third parties to provide our Services to you, as described in the next section.

5. How We Share Your Personal Information
   We may share and disclose Personal Information as follows:

• Third Party Service Providers Performing Services on Our Behalf. We share Personal Information, with certain third-party service providers that assist us in providing the Services and which are bound by duties of confidentiality. For example, we may use third parties to host the Services, to send out email updates about the Services or remove repetitive information from our user lists.
• For Legal Purposes. We will disclose your Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share your Personal Information as required to pursue available remedies or limit damages we may sustain.

  We may de-identify your Personal Information, in compliance with applicable law and aggregate such de-identified data with the de-identified data of other users. We may then share such aggregate, de-identified data with the sponsors of programs that facilitate your access to the Services, such as County government health agencies.

6. Security of Your Personal Information

    

   We employ reasonable security measures designed to protect the security of information submitted through the platform. However, the security of information transmitted through the Internet can never be guaranteed. To protect you and your Personal Information we may suspend your use of the platform, without notice, pending an investigation, if any breach of security is suspected.

• Unauthorized Access. Access to and use of password protected and/or secure areas of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited.
• Encryption and Firewalls. Chat transcripts are anonymized and encrypted before stored on our servers. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All Transcripts are maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls, and passwords.

7. Links to Other Sites
   The Services may contain links and widgets related to third-party websites and services (“Third Party Services”) with which we have no affiliation. A link to any Third Party Services does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit any Third Party Services, you are subject to its privacy policy and practices and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

8. Non-discrimination
   One More Light does not and shall not discriminate on the basis of race, color, religion (creed), gender, gender expression, age, national origin (ancestry), disability, marital status, sexual orientation, or military status, in any of its activities or operations.

9. Child Protection
   One More Light complies with the Children’s Online Privacy Protection Act and clearly specifies that users must be at least 18 years old. If One More Light learns of a user who is younger than 18, or 13-18 years old without parental consent, then One More Light, at their sole discretion, can terminate that account.

10. Notice to Individuals in the European Economic Area and Switzerland
    This section only applies to individual using our Service that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection. We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individuals that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries.

    Our Relationship to You. One More Light is a data controller with regard to any Personal Information collected from Users of its Service. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that handle your Personal Information in accordance with our instructions are our service providers and are “data processors.”

    Legal Bases for Processing Personal Information. Article 6(1) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) describes when processing can be done lawfully.  Whenever we require your consent for the processing of your Personal Information such processing will be based on GDPR, Article 6(1)(a). If the processing of your Personal Information is necessary for the performance of a contract between you and One More Light or for taking any pre-contractual steps upon your request, such processing will be based on GDPR, Article 6(1)(b). Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR, Article 6(1)(c).  Also, in many cases, we handle your Personal Information on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals.

    Marketing. We will only contact individuals located in the Designated Countries by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. You can object to direct marketing at any time and free of charge.

    Individual Rights. We take reasonable steps to ensure that your Personal Information is accurate, complete, and up to date. You have the right to access, correct, or delete the Personal Information that we collect. You are also entitled to restrict or object, at any time, to the further processing of your Personal Information. You have the right to receive your Personal Information in a structured and standard format and, where technically and legally feasible, the right to have your Personal Information transmitted directly to a third party. You may lodge a complaint with the competent data protection authority regarding the processing of your Personal Information.

    If you would like to exercise your rights under applicable law, please contact us at the One More Light Help Center. We may seek to verify your identity when we receive an individual rights request from you to ensure the security of your personal information.  We may limit your individual rights requests (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; or (4) where the request is frivolous or burdensome.

11. Notices
    Please send all questions, comments and notices regarding this Privacy Policy to the One More Light Help Center.