Last Updated March, 2023

This Privacy Policy (“Privacy Policy”) sets out how we use, share and protect Personal Information (as hereinafter defined) and other information that we collect when you:

• access or use the Site;

• register to become a User; and/or

Capitalized terms not defined herein shall have the meaning set forth in the INVI Mindhealth™ Terms and Conditions (“Terms and Conditions”).

Except where noted, statements in this Privacy Policy with respect to the Site and INVI Mindhealth™ mobile device applications ("Apps") for iPhone, iPad and Android devices.

You must affirmatively consent to use our offerings, and by doing so, you consent to this Privacy Policy and the use of your personal information as stated herein. If you do not agree to the terms of this Privacy Policy and the use of your personal data as stated herein in their entirety, you may not access or otherwise use the site and/or INVI Mindhealth™ applications.

1. Information We Collect

We collect three basic types of information and data: Personal Information, non-Personal Information, and aggregate data.

2. Personal Information Collected

For the purposes of this Privacy Policy, Personal Information shall mean individually identifiable information from or about an individual. We collect Personal Information from you primarily in three (3) ways:

1. when you register to become a User on the Site;
2. when you register to become a User, or otherwise utilize certain aspects of the INVI Mindhealth™ Applications, through and/or in connection with an account that you already have with certain third-party social media websites (“Social Media Websites”), such as Facebook®.

In addition, when you access and/or use the Site and/or INVI Mindhealth™ Services, and based on our legitimate interest to improve the quality of the INVI Mindhealth™ Services, we may collect certain usage data, such as:

1. the number of times that you visit the Site;
2. the specific INVI Mindhealth™ Services accessed, as well as the frequency and duration of use associated with them; and
3. other analyses and data associated with your access to, and use of, the Site and/or INVI Mindhealth™ Services (collectively, “Usage Data”).

We also may collect information and responses you provide when participating in activities on the Site, which may include activity postings, survey responses, assessment responses and any other data you generate in using the Site and/or INVI Mindhealth™ Services (“User Responses”).

3. Site Registration

The Personal Information that you must supply on the Site in order to obtain access to the INVI Mindhealth™ Services may include, without limitation:

• your full name;
• your email address;
• your telephone number;
• your date of birth;
• your home address;
• your user name and password;
• any and all other information requested on the applicable registration form (collectively, “Site Registration Data”).

4. Use of Personal Information

Providing The Services:

1. To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with customer service;​

2. To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request other information about our Services;

3. To verify your information and provide related customer service;

4. To send you administrative information, such as changes to our terms, conditions and policies; and

5. To allow you to send messages to another person through the Services.

Providing You with Information About Our New Services and/or Marketing Materials And Facilitate Social Sharing:

1. To send you marketing related emails with information about our services, new products and other company news; and

2. To give you the ability and option for social sharing on your preferred platform.

Improving Our Services: We may use your personal information in order to improve our services.

Providing Personalized Services: To better understand your interests and preferences so we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

Aggregating And/Or Anonymizing Personal Information: We may aggregate and/or anonymize personal information so that it will no longer be considered personal information.

Accomplishing Our Business Purposes:

1. For data analysis to, for example, improve our efficiency;

2. For audits to verify that our internal processes function as intended and to address legal, regulatory or contractual requirements;

3. For fraud prevention and security monitoring to, for example, detect and prevent cyberattacks and identity theft;

4. For developing new products and services;

5. For enhancing, improving, repairing, maintaining or modifying our current products and services, as well as undertaking quality and safety assurance measures;

6. For identifying usage trends;

7. For determining the effectiveness of our promotional campaigns;

Other Uses and Disclosures Of Personal Information

Applicable Law: We may share personal information to comply with applicable law and regulations, which may include laws outside your country of residence.

Transaction, Liquidation: We may share personal information with third parties in connection with a transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, or in the event of a bankruptcy or related or similar proceedings.

Public And Government Authorities, Law Enforcement: Where permitted or required by applicable data protection laws, we may disclose your personal information pursuant to a legal request or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.

Protecting Rights and Safety: Where permitted or required by law, we may share your personal information with others if we believe in good faith that it will help protect the rights, property or personal safety of INVI Mindhealth, any of our users or any User of the general public, with or without notice to you.

​5. Other Information Collection and Use

We use the information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage, as well as to offer you products and services.

6. How we may use cookies and other tracking technologies

When providing our Services, we may use the following types of cookies and tracking technologies for the purposes set out below.

Cookies and local storage may be set and accessed on your computer. Upon your first visit to the Services, a cookie or local storage may be sent to your computer that uniquely identifies your browser. “Cookies” and local storage are small files containing a string of characters that is sent to your computer's browser and stored on your device when you visit a website. Many major Web services use cookies to provide useful features for their users. Each Web site can send its own cookie to your browser. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you will not be able to sign into the Services or take full advantage of our Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all cookies or indicate when a cookie is being sent, you will have to again reset your browser to refuse all cookies or indicate when a cookie is being sent.

To support our Services, we may use one or more of the following cookies for the purposes set forth below:

Type of Cookie

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages that they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services work. You can find out more information about Google Analytics cookies here: Find out more information about Google Analytics cookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: Google Analytics Opt-out Browser Add-on

Essential Cookies

These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, remembering which polls you have voted in and in some cases, to show you poll results, and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook® or Twitter®. The social network will record that you have done this.

You can find more information about cookies and how they work, what cookies have been set on your computer or mobile device and how to manage and delete them at http://www.allaboutcookies.org/

We may also use “pixel tags,” which are small graphic files that allow us and third parties to monitor the use of the Services and collect Usage Data. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your computer.

We may use pixel tags, either provided by us or by our third party advertisers, service providers and ad networks, to collect information about your visit, including the pages you view, the links you click and other actions taken in connection with our sites and Services and use them in combination with our cookies to provide offers and information of interest to you. Pixel tags may also enable ad networks to serve targeted advertisements to you when you visit the Services or other websites.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

7. Location Information

When you use the Site, INVI Mindhealth™ Services, or Promotions, and based on our legitimate interest to improve them, we may collect location information either provided by a mobile device interacting with our Site or one of our applications, or associated with your IP address, where we are permitted by law to process this information.

8. Aggregate Data

INVI Mindhealth™ reserves the right to transfer and/or sell aggregate or group data about INVI Mindhealth™ users (including Usage Data not linked to Personal Information) for lawful purposes. Aggregate or group data is data that describes the demographics, usage or other characteristics of INVI Mindhealth™ users as a group, without disclosing personally identifiable information.

9. Mobile Devices

One or more of our Apps may require that you be registered and signed in in order to use them. The information that we collect through your use of our Apps and tools will be treated as Personal Information under this Privacy Policy. When you download and install one of our mobile Apps onto your mobile device, we assign a random number to your App installation. This number cannot be used to identify you personally, and we cannot identify you personally unless you choose to become a registered user of the App. We use this random number in a manner similar to our use of Cookies as described in this Privacy Policy. Unlike Cookies, the random number is assigned to your installation of the App itself and not a browser, because the App does not work through your browser. Therefore, the random number cannot be removed through settings. If you do not want us to use the random number for the purposes for which we use Cookies, please do not use our mobile device Apps. Because some of the content on our mobile device Apps directs your mobile device to our website you will be exposed to the Cookies that we use and to third party Cookies that may be contained in advertisements that we do not control and will be unable to delete any of these Cookies with your mobile device. Therefore, if you do not want to be exposed to Cookies when you use your mobile device you should not use our mobile device Apps and you should set your mobile device to reject Cookies when you use our mobile optimized sites. Our use of Cookies and Web Beacons on our mobile optimized sites are similar to our use on our desktop sites. Your choices to reject Cookies are available on our mobile optimized site. If you have questions about how to reject Cookies on your specific device please check with the device manufacturer.

10. Third-Party Websites

This Site may contain links to third-party owned and/or operated websites. INVI Mindhealth™ is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and INVI Mindhealth™ has no responsibility or liability relating to them.

11. Security

We endeavor to safeguard and protect our Users’ Personal Information. When Users make Personal Information available to us, their Personal Information is protected both online and offline (to the extent that we maintain any Personal Information offline). The privacy of your Personal Information is very important to us. When our registration process asks users to submit Personal Information (if any), and when we transmit such Personal Information, that information is encrypted and is protected with the appropriate current industry standard software that employs state-of-the-art, best-practice encryption methods and algorithms.

Access to your Personal Information is strictly limited, and we take reasonable measures to ensure that your Personal Information is not accessible to the public. The servers that we store Personal Information in are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of Personal Information under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your Personal Information, and technological bugs, errors and glitches may cause inadvertent disclosures of your Personal Information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software constitutes a crime punishable by law. For the reasons mentioned above, we cannot warrant that your Personal Information will be absolutely secure. Any transmission of data at or through the Site is at your own risk.

All of our Users’ Personal Information, not just the sensitive information mentioned above, is restricted in our offices. Only employees or third-party agents who need the Personal Information to perform a specific job are granted access to Personal Information. Our employees are dedicated to ensuring the security and privacy of all user Personal Information. Employees not adhering to our firm policies are subject to disciplinary action. In compliance with applicable federal and state laws or other laws applicable to persons using our Services in foreign countries, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personal Information. You will be notified via email in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

12. Exercising your right to Opt-Out of Receiving Communications

Even after consenting to the Privacy Policy and Terms and Conditions, you may opt out of receiving email advertising from us by following the instructions at the end of the applicable email message or by sending us an email at support@INVImh.com and asking us not to send you email advertising.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for INVI Mindhealth™ Services, as well as to respond to any inquiry or request made by you. To opt-out of receiving INVI Mindhealth™ Services-related and inquiry response-related messages from INVI Mindhealth™, you must cease requesting and/or utilizing the INVI Mindhealth™ Services and cease submitting inquiries to INVI Mindhealth™, as applicable.

13. Identifying, Deleting and Updating Your Information

At your request, we will inform you of what Personal Information we have on file for you. In addition, at your request, we will update, correct, modify or delete Personal Information that you have provided to us, or that we have collected. You may do so by contacting us via email at support@INVImh.com; provided, however, that we ask individual Users to identify themselves and the information requested to be accessed or updated before processing such requests. We will comply with your request as soon as reasonably practicable. However, we may maintain Personal Information whenever we are required to do so by law or regulations or as we believe is reasonably necessary to comply with applicable law or regulations, government requests, to detect or prevent fraud, to resolve disputes, to address problems with the Services, to assist with investigations, or to enforce our terms and conditions or other applicable agreements or policies. We may also need to retain certain information for recordkeeping purposes. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

14. Data Retention

User information provided to INVI Mindhealth™ will be retained in accordance with the strictest application of the laws of the governing authorities for the user’s primary place of residence. In the absence of applicable laws governing data retention, INVI Mindhealth™ will not retain data for more than 7 years beyond the date the user last logs in to INVI Mindhealth™.

15. Children

INVI Mindhealth™ is committed to children's privacy. INVI Mindhealth™ does not knowingly permit any person less than 18 years of age to register directly for the INVI Mindhealth™ Services.

If INVI Mindhealth™ learns that Personal Information of persons under 18 years of age has been collected on the Site or through the Services then INVI Mindhealth™ will take appropriate steps to remove the information. If you are a parent or guardian and discover that your child under the age of 18 has a registered account with the Site, please alert INVI Mindhealth™ at support@INVImh.com to request that INVI Mindhealth™ remove the child’s Personal Information. Please provide the child’s name, address, and email address.

16. Changes to this Privacy Policy

INVI Mindhealth™ reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use Personal Information changes, INVI Mindhealth™ will notify Users by:

sending the modified policy to our Users via email; and/or

by any other reasonable means acceptable under applicable state and federal law.

You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

17. Contact Us

If you have any questions or comments about this Privacy Policy, please email support@INVImh.com