Privacy

Table of Contents

    Preamble

    Dear website visitors and users of the WeMingo self-help program,

    We know about the special sensitivity of the topic Paruresis. Therefore, we would like to inform you here transparently and professionally about which data is collected and processed when using the self-help program and browsing the sites on wemingo.com.

    We treat your personal data confidentially and in accordance with the statutory data protection regulations and this data protection declaration. We want you to be able to use the self-help program without worrying that someone might find out about your Paruresis or read your entries. To ensure this, we set high standards for data security and allow you to use the programy pseudonymously. In addition, we promise you that the WeMingo team will not read your free text entries in the context of expressive writing and situation logs. We only reserve the right to check your free text entries automatically for keywords and text length in order to adjust the course contents accordingly.

    None of your personal data from the program is passed on to third parties.

    The use of "we" and "WeMingo" in this privacy declaration always refers to Johannes Schirrmeister, Goslarer Platz 2, 10589 Berlin, Germany.

    Which data is collected for what purpose?

    Pseudonymous usage

    We recommend to use the self-help program pseudonymously. When registering, you should choose a fictitious user name and an e-mail address that is not related to your real name or your real e-mail address.

    Ideally, you set up a new e-mail address specifically for the use of the self-help program.

    Collected data Purpose

    Sign-up

    “Your symptoms” (Paruresis Checklist): in case of a subsequent registration, the entries are saved and linked to the user profile.

    “Further symptoms” (PHQ9 questionnaire): The information in this questionnaire will be evaluated once and a score will be saved without any link to the user profile.

    With the help of these two scientifically tested questionnaires we check whether the self-help program seems suitable for the applicant.

    The evaluation from the Paruresis Checklist may be used for individualizing the program content.

    The calculated score from the PHQ9 questionnaire is saved for statistical purposes only. Again, they are not linked to user accounts.

    Payment

    Your payment details are not stored by WeMingo, but transmitted directly to our payment provider Braintree. The payment details are used by Braintree solely for the purpose of processing the payment.

    WeMingo merely stores a transaction number which links the corresponding payment through the payment provider.

    Saving the transaction number enables us to link a payment to a user, which allows us, for example, to refund the program fee.

    User account

    The following data is required when signing up for WeMingo:

    • First name
    • User name
    • Email
    • Gender

    Additionally, we store date and time of the registration as well as the time of the last successful login attempt.

    First name for addressing the user in a more personal manner

    User name for a unique identification of the user within the system

    Email address for notifications as part of the self-help program (unlock notifications, reminder)

    Gender for gender-specific customization of the program contents

    Data submission during the course of the program

    In the course of the program, the following data is collected:

    • Self-evaluation scores as part of “Progress Tracking”
    • Multiple choice answers as a way to reflect on one's safety/avoidance behavior and individual triggering events
    • Free text as part of the expressive writing exercises, goal setting and in situation record exercises
    • Completion of modules

    All data collected during the program serves therapeutic purposes.

    The entries are saved because they are used several times during the program. We also intend to use them as a personal reference beyond the end of the program itself.

    We reserve the right to automatically check your free text entries for keywords and text length in the future in order to adjust the course content accordingly and thus offer a better user experience.

    Duration of Storage

    We also store your data after the end of the actual self-help program, so that you can access your content and repeat modules if you wish. If you do not register again for a period of 2 years, we will delete your data after prior notification.

    Newsletter

    We offer you the opportunity to register for our free newsletter via our website.

    We use MailChimp, a service of The Rocket Science Group, LLC, 512 Means Street, Suite 404, Atlanta, GA 30318, USA, hereinafter referred to as "The Rocket Science Group".

    Through certification according to the EU-US Privacy Shield

    https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active

    the Rocket Science Group guarantees that it will follow the EU's data protection regulations when processing data in the United States. In addition, the Rocket Science Group offers further information about its data protection practices at

    http://mailchimp.com/legal/privacy/

    If you register for our free newsletter, the data requested from you for this purpose, i.e. your email address and, optionally, your name and address, will be processed by The Rocket Science Group. In addition, your IP address and the date and time of your registration will be saved. During the registration process, your consent to receive this newsletter will be obtained together with a concrete description of the type of content it will offer and reference made to this privacy policy.

    The newsletter then sent out by The Rocket Science Group will also contain a tracking pixel called a web beacon. This pixel helps us evaluate whether and when you have read our newsletter and whether you have clicked any links contained therein. In addition to further technical data, such as data about your computer hardware and your IP address, the data processed will be stored so that we can optimize our newsletter and respond to the wishes of our readers. The data will therefore increase the quality and attractiveness of our newsletter.

    The legal basis for sending the newsletter and the analysis is Art. 6 Para. 1 lit. a) GDPR.

    You may revoke your prior consent to receive this newsletter under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent or click on the unsubscribe link contained in each newsletter.

    Web Analytics

    We use Google Analytics on our website. This is a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).

    Through certification according to the EU-US Privacy Shield

    https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

    Google guarantees that it will follow the EU's data protection regulations when processing data in the United States.

    The Google Analytics service is used to analyze how our website is used. The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.

    Usage and user-related information, such as IP address, place, time, or frequency of your visits to our website will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymization function, whereby Google truncates the IP address within the EU or the EEA before it is transmitted to the US.

    The data collected in this way is in turn used by Google to provide us with an evaluation of visits to our website and what visitors do once there. This data can also be used to provide other services related to the use of our website and of the internet in general.

    Google states that it will not connect your IP address to other data. In addition, Google provides further information with regard to its data protection practices at

    https://www.google.com/intl/de/policies/privacy/partners,

    including options you can exercise to prevent such use of your data.

    In addition, Google offers an opt-out add-on at

    https://tools.google.com/dlpage/gaoptout?hl=en

    in addition with further information. This add-on can be installed on the most popular browsers and offers you further control over the data that Google collects when you visit our website. The add-on informs Google Analytics' JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analytics services we may use as detailed herein.

    Google AdWords with Conversion Tracking

    Our website uses Google AdWords and conversion tracking. This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).

    Through certification according to the EU-US Privacy Shield

    https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

    Google guarantees that it will follow the EU's data protection regulations when processing data in the United States.

    We use conversion tracking to provide targeted promotion of our site. The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.

    If you click on an ad placed by Google, the conversion tracking we use stores a cookie on your device. These so-called conversion cookies expire after 30 days and do not otherwise identify you personally.

    If the cookie is still valid and you visit a specific page of our website, both we and Google can evaluate that you clicked on one of our ads placed on Google and that you were then forwarded to our website.

    The data collected in this way is in turn used by Google to provide us with an evaluation of visits to our website and what visitors do once there. In addition, we receive information about the number of users who clicked on our advertisement(s) as well as about the pages on our site that are subsequently visited. Neither we nor third parties who also use Google AdWords will be able to identify you from this conversion tracking.

    You can also prevent or restrict the installation of cookies by making the appropriate settings in your browser. Likewise, you can use the browser to delete cookies that have already been stored. However, the steps and measures required vary, depending on the browser you use. If you have any questions, please use the help function or consult the documentation for your browser or contact its maker for support.

    In addition, Google provides further information with regard to its data protection practices at

    https://services.google.com/sitestats/de.html

    http://www.google.com/policies/technologies/ads/ 

    http://www.google.de/policies/privacy/

    in particular information on how you can prevent the use of your data.

    Google Remarketing

    We use the remarketing function on our website. This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).

    Through certification according to the EU-US Privacy Shield

    https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

    Google guarantees that it will follow the EU's data protection regulations when processing data in the United States.

    We use this feature to deliver interest-based, personalized advertising on third-party websites that also participate in Google's advertising network.

    The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.

    To allow this advertising service to function, Google stores a cookie with a sequence of numbers on your device via your browser when you visit our website. This cookie records both your visit and the use of our website in anonymous form. However, personal data will not be passed on. If you subsequently visit a third-party website that also uses the Google advertising network, advertising may appear that refers to our website or our offers there.

    To permanently disable this feature, Google provides a browser plugin for most common browsers at

    https://www.google.com/settings/ads/plugin?hl=de

    Likewise, the use of cookies from certain providers, e.g. via

    http://www.youronlinechoices.com/uk/your-ad-choices/

    or

    http://www.networkadvertising.org/choices/

    can be deactivated by opt-out.

    Cross-device marketing allows Google to track your usage patterns across multiple devices, so you may see interest-based, personalized advertising even when you switch devices. However, this requires that you have agreed to link your browsing history to your existing Google account.

    Google offers more information about Google Remarketing at

    http://www.google.com/privacy/ads/

    Server Logs

    Every time you use the Internet, your Internet browser automatically transmits certain data, which we store in so-called server logs. The server logs are used for detection of faults and for security reasons (e.g. attack detection) for a time between seven and ten days and then deleted unless a security incident occurs and the server logs are required as evidence. Server logs included typically the following information:

    • the IP address of the device from which the online service was accessed,
    • the Internet address of the site, which referred to WeMingo (the so-called referrer URL),
    • the name of the Internet Service Provider, which was used to access WeMingo,
    • the name of the requested resources,
    • date and time as well as the duration of access,
    • the size of transmitted documents,
    • the operating system and information regarding the web browser that was used,
    • the HTTP status code (e.g. "page requested successfully").

    Cookies

    Some of our pages use so-called cookies. Cookies do not damage your computer and do not contain viruses. Cookies serve to make our website more user-friendly, effective and secure. Cookies are small text files which are saved on your computer and by your web browser.

    Most of the cookies we use are so-called "session cookies". They are automatically deleted at the end of your visit. Other cookies are stored on your device until you delete them, which enables us to recognize your browser the next time you visit.

    You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

    Data Security

    Your data is stored on servers in the Microsoft Cloud Germany. The data in the Microsoft Cloud Germany is managed in trust by Deutsche Telekom AG - and thus in accordance with the strict German data protection regulations.

    WeMingo's self-help program is based on a modern web framework and follows best practices to prevent common web application security risks. All data traffic between your browser and WeMingo servers is encrypted using HTTPS. After server-side processing, the data is stored encrypted on the hard disks.

    What rights do you have with regards to your personal data?

    You have the right to free information about your stored personal data and the purpose of data processing as well as the right to correct, block or delete this data at any time. To do so, please contact the e-mail address provided below.

    Contact

    When writing this document, we have tried to be complete and simple in language. If you still have any further questions while reading this statement, please write to us at johannes@wemingo.com.

    Complaint

    You can file a complaint with the data protection authority of your federal state or another German data protection authority.

    Changes in Regulations

    These provisions are reviewed regularly to reflect new laws and technologies, changes in our operations and procedures, and the changing business environment.

    Last updated: May 24, 2018