We at RELai deem privacy as a fundamental human right. This means people need to know what they are
signing up for in plain language.
Declaration of the RELai’s Services
RELai is not a suicide intervention solution and does not claim to save individuals with suicidal
tendencies. RELai will not accept any responsibility in case of any individual's death.
Overview of Privacy Policy
Our full Privacy Policy is outlined below, and it includes contact details as well as information about
how we process data, your rights, our beliefs, and legal requirements. We understand that it can be quite
lengthy for you, so we have outlined the three things we definitely want you to know:
- We’re intentional about the data we collect, and it’s always with the goal to improve and
deliver an experience that helps our users. We collect data: directly from you, like your
email address to get in touch or your age for content recommendations; passively, such as your general
app usage to improve RELai; from program partners like payors, and providers, to verify eligibility. Our
systems are designed such that the data we collect and hold internally is only available to the RELai
privacy team when it’s absolutely necessary for their job.
- What you write to RELai, and the transcripts of your conversations with RELai, are never
shared with any third party (except to ensure your safety and those of your loved ones). We never,
ever sell or share your data with advertisers. We do use your data for development and
deployment, for example, to train the AI model to serve you with better responses, but we do not share
or sell your data to do so.
- Your data is yours. Anyone who uses RELai, regardless of where you live or are
physically located, can access, correct, delete or restrict their own data. You can share as much or as
little as you like, and you can opt-out of emails, texts or push notifications.
Privacy is complex, and the types of data available online continue to evolve but know this: while we may
evolve our policies, the commitments we’ve outlined above will never change.
Please reach out anytime with questions, comments, concerns or ideas at signal@RELai.one,
Now, here are the full, all-inclusive details.
Introduction
RELai (“RELai”, “us”, “we” or “our”)
is committed to protecting and respecting your privacy. This Privacy Policy describes how we collect,
store, use and distribute personal data through our
software, website, mobile application (“App”), documentation, and related services
(together, the “Services”).
In this Privacy Policy, references to “you” means the person whose personal data we collect, use and
process. Please read this Privacy Policy carefully to understand our services and use of personal data.
We will use your personal data only for the purposes and in the manner outlined below, and in compliance
with applicable laws.
Please note that by using the Services, you acknowledge that you have read and understood this Privacy
Policy.
Purpose of RELai
RELai is a trained AI therapist aimed at improving individuals’ mental health and it serves the following purposes:
Access to suitable and suitable (non-critical/safe) therapy as well as support in the selection and
implementation.
Facilitating well-being through mindfulness practices such as the ‘Gratitude Wall’ helps users to
express gratitude to each other.
All RELai Platforms
When you create a user account, you will be asked to provide an email address and password so that we can
identify you across devices or comply with any potential request to delete or access your data. We may
also ask for a referral or access code, which we may use to track your participation in specific programs,
described in more detail below. On certain versions of the Services, you may be able to skip account
creation and create an account locally on your device: note that without an account, you will not be able
to recover your data or log in on a different device.
Registration or creation of your personal user account
You can register or create a user account on our website or in the mobile app. For registration you need
the following data:
Your email address
Your freely chosen password
A statement that within the last two weeks there was no concrete plan to end your own life
After successful registration and confirmation of your e-mail address, you can log into your user account
using your e-mail address and your password. We process the aforementioned data so that you can manage
your profile
iOS and Android apps
We use your email to create a user account. We use your time zone to personalize the experience.
Identity of the Controller of Personal Information
The data controller for the Services is RELai.
Contact Details of the Data Protection Officer / Representative
RELai’s Data Protection Officer can be contacted at:
Email Address: signal@RELai.one, Address: Dr Gessler Str 16,
Regensburg, 93051.
Processing your Data
How and why do we process your personal data?
When you use the Services, we may collect and process different personal data about you. The personal
data we process, the basis of processing and the purposes of processing are detailed below. Sometimes,
these activities are carried out by third parties (see “Sharing of Personal Data with Third Parties”
section below).
We encourage you to supply only the information you are comfortable with.
Personal data |
Legal basis of processing |
Purpose of processing |
Account information: Personal datais (which may include your name and other similar
personal data you provide to us), password, referral or access code for participation in specific
programs, and email address. Some of this data may be considered “Protected Health Information”
under the Health Insurance Portability and Accountability Act. |
-Contractual necessity
-Consent |
This is required to provide the Services, to maintain our customer/visitor lists, to respond to
your inquiries or provide feedback, for identification and authentication purposes, for service
improvement, and to address issues like malicious use of the Services. |
Your communications with us: Your email address, full name, platform, operating system
version, communications with us, and any attachments you submit via our help portals, such as an
optional profile photo or phone number. |
-Contractual necessity
-Consent
-Legitimate interest |
We collect this information when you request information about our services, register for our
newsletter, request customer or technical support, or otherwise communicate with us. You can
unsubscribe from communications, including the newsletter at any time by clicking the unsubscribe
link in each email or by contacting us. |
CeParticipation and Assessment data: Participation data, responses to assessments, S.O.S.
triggers, measures and satisfaction surveys. Some of this data may be considered “Protected Health
Information” under the Health Insurance Portability and Accountability Act.ll |
-Contractual necessity
-Consent
-Legitimate interest |
We collect this information to enable us to administer and improve our Services to you. We may
also collect this information to fulfill participation in Specific Programs as described in
“Disclosures to Third Parties for Specific Programs ” below. |
Conversation data: Text, graphics, video, or messages you generate through your
interactions with RELai. |
-Contractual necessity
-Consent
-Legitimate interest |
We collect this information to enable us to administer and improve our Services to you. |
Hardware Diagnostic and login information: Crash reports, along with logging information from your
system documenting the error.Information regarding your operating system version, hardware, browser
version (and .NET version information in case of Windows systems), and your email address, if
provided. Additionally, certain login information may be maintained in a cookie stored locally on
your device in order to streamline the login process. |
-Contractual necessity
-Legitimate interest |
We collect this information to enable us to administer and improve our Services to you. |
Your use of our Services: Analytics information is collected through the use of cookies, log
files, pixel tags and web beacons (“Technologies”) or while using the Services. Such information may
include standard information regarding your mobile device, browser type, browser language, operating
system, Internet Protocol address, and the actions you take on our website, such as the web pages
viewed and the links clicked. |
-Contractual necessity
-Legitimate interest |
We collect this information to enable us to administer and improve our Services. We may also use
your Analytics Information in conjunction with an analytics service such as Google Analytics to
monitor and analyze use of the Services, for the Services’ technical administration, to increase the
Services’ functionality and user-friendliness, and to verify users have the authorization needed for
the Services to process their requests. |
Product surveys, promotional activities and social media content. |
-Contractual necessity -Consent -Legitimate interest |
Within or outside the App, we may offer the ability to participate in surveys or run sweepstakes
or contests to promote the Services. The Contact information you provide may be used to reach you
about the sweepstakes or contest and for other promotional, marketing and business purposes, as
permitted by law. In some jurisdictions, we are required to publicly share information about
winners. We may offer forums, blogs, or social media pages. Any content you provide on these
channels will be considered “public” and is not subject to the privacy protections referenced
herein. Please exercise caution before revealing any information that may identify you in the real
world to other users. |
Our uses of the aforementioned Technologies fall into the following general categories:
Operationally Necessary. This includes Technologies that allow you access to our Services,
applications, and tools that are required to identify irregular website behaviour, prevent fraudulent
activity and improve security or that allow you to make use of our functionality;
Performance-Related. We may use Technologies to assess the performance of our Services, including as
part of our analytic practices to help us understand how individuals use our Services;
Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when
accessing or using our Services. This may include identifying you when you sign into our Services or
keeping track of your specified preferences, interests, or past items viewed;
Advertising- or Targeting-Related. We may use first-party or third-party Technologies to deliver
RELai-relevant content, including ads relevant to your interests, on our Services or on third-party
websites. We do not sell or share data with advertisers.
See “Your Rights” below to understand your choices regarding these Technologies.
Provision of the website
Every time you use our website, we collect the data that your browser automatically transmits to enable
you to visit the website. These are in particular:
IP address of the requesting end device
Date and time of the reques
Address of the accessed website and the requesting website
Information about the browser used and the operating system of the end device
Data processing is required to enable visits to the website and to ensure the long-term functionality and
security of our systems. The data mentioned are also temporarily stored in internal logs for the purposes
described above. This serves to evaluate statistical data about the use of our website and its further
development. The mutual, legitimate interest in the error-free provision and functionality of our website
serves as the legal basis.
Information from Other Sources
We may obtain information about you from other sources, including through third-party services and
organizations to supplement the information provided by you. For example, if you access our Services
through a third-party application, such as an app store, a third-party login service, or a social
networking site, we may collect information about you from that third-party application that you have made
available via your privacy settings. This supplemental information allows us to verify the information
that you have provided to us and to enhance our ability to provide you with the Services and information
about our business and products.
Analytics Vendors
We may also use Google Analytics, and other service providers to collect information regarding visitor
behaviour and visitor demographics on our Services.
For more information about Google
Analytics, please visit Google Privacy. You can opt out of Google’s collection and processing of
data generated by your use of our website by clicking this link: Opt-Out of Google Analytics.
Social Media Platforms
Our Services may contain social media buttons that might include widgets such as the “Share RELai”
button. These features may collect your IP address, and which page you are visiting on our Services, and
may set a cookie to enable the feature to function properly. Your interactions with these platforms are
governed by the privacy policy of the company providing it.
We use the offers of social networks such as Facebook, Twitter or Instagram to provide you with further
contact and information options. These offers are very popular with our users, which is why using them is
in our mutual interest. However, we will only transmit your data if you give your consent. You can find
more information on this in the data protection information:
Instagram & Facebook Inc., 1601 S California Ave, Palo Alto, California 94304,
USA, privacy policy and further information on data collection .
Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA,
privacy policy
Use of De-identified and Aggregated Information
We may use personal data and other data about you to create de-identified and aggregated information,
such as general location information, information about the computer or device from which you access our
Services or other analyses we create. We may share this information with the parties listed in “Sharing of
Personal Data with Third Parties” below or as required or permitted by applicable law.
Where does RELai Obtain my Personal Data From?
Most of the personal data we process is obtained from you when through the application you register for a
RELai account and exchange messages with RELai. Other types of personal data may be obtained from third
parties (such as Google Analytics) to enrich and continuously improve the user experience.
Sharing of Personal Data with Third Parties
We do not share your personal data with third parties, except as provided below.
1. Service Providers
We use third-party service providers who provide technical and support services to help us provide and
improve the product and Services. In providing the Services, these third-party service providers may have
limited and controlled access to databases of user information or registered member information solely for
the purpose of helping us to improve the product and they will be subject to contractual restrictions
prohibiting them from using the personal data of our members for any other purpose.
2. Disclosures to Third Parties for Specific Programs
We partner with Program Partners in Specific Programs to conduct studies or provide services with the
Program Partner’s offerings. Program Partners may include your employer, hospital, or care physician,
certification authorities, or other medical and academic partners. If you choose to participate in a
specific program, we will not share your Conversation Data as defined under Personal Data with
RELai to a program partner.
What we may share:
In an Employer setting, we may share with the program partner usage information about the Services,
such as statistical usage information and the outcome of participation in the program (as measured, for
example, by survey responses, engagement and satisfaction metrics) in a de-identified and aggregate
manner.
In a Clinical setting, we may share clinically relevant data with the program partner if required as
part of your care. This could include usage information about the Services, such as statistical usage
information, and the outcome of your participation in the program (as measured, for example, by your
survey responses, engagement and satisfaction metrics).
In a Research setting, what we may share is clearly identified during participant consent.
Note that your participation in specific programs may be governed by terms outside of this Privacy Policy.
Please contact the Program Partner for additional information on their Privacy Policy and Terms of
Service.
3. Disclosure to Other Third Parties
In certain circumstances, we share and/or are obliged to share your personal data with third parties in
accordance with applicable law, including if we, in good faith, believe doing so is required or
appropriate to comply with law enforcement or national security requests and legal processes, such as a
court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or
contracts; collect amounts owed to us; assist with an investigation or prosecution of suspected or actual
illegal activity or as otherwise allowed under applicable law.
These third parties include:
administrative authorities (tax or social security authorities)
financial institutions
insurance companies in the event we need to collect payment
police, public prosecutors, regulators
external advisors (such as external counsel)
We may also disclose your personal data in connection with a corporate reorganization, a merger or
amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including
any due diligence exercise carried out in relation to the same, provided that the information disclosed
continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the
information.
Transfer Outside the European Economic Area, Switzerland, or the UK
Your personal data may be transferred, stored and processed in one or more countries outside of the
country you reside or are currently located. In the European Economic Area (“EEA”), Switzerland, or the
UK, for example, when one of our service providers uses employees or equipment based outside the EEA or
UK. For transfers of your personal data to third parties outside of the country you reside in or are
currently located in, we take additional steps consistent with applicable law. We endeavour to put in
place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms,
and the exercise of your rights, e.g. we will endeavour to establish an adequate level of data protection
through EU Standard Contractual Clauses based on the EU Commission’s model clauses.
How is My Personal Data Secured?
RELai operates and uses appropriate technical and physical security measures to protect your personal
data.
We have, in particular, taken appropriate security measures to protect your personal data from an
accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Some examples of
our security standards include:
We adhere to hospital-level security policies and procedures to protect sensitive user data. That
means we treat all user data as Protected Health Information and adhere to all HIPAA and GDPR
requirements, even when the data is not legally classified as such.
We build security into the architectural design of the product by reducing the public and digital
footprint, using the benefits of cloud-enabled infrastructure and security by design, such as serverless
computing and automatic scaling. All data is encrypted at rest and in-transit.
We secure sensitive data in the product, such as protected health information (PHI) and personal
identifying information (PII), in a dedicated environment to ensure segregation and clear access
control.
We endeavour to maintain controlled access into our critical infrastructure through technical network
controls, multi-factor authentication and by applying deny-all/allow-by-exception concept whenever
possible.
We test the security of our design by performing and remediating findings of penetration tests,
vulnerability assessments, internal compliance reviews and more.
We support business resiliency by proactively planning for issues and regularly testing our Business
Continuity, Disaster Recovery and Incident Response Plans.
Access is only granted on a need-to-know basis to those people whose roles require them to process
your personal data.
You are also responsible for helping to protect the security of your personal data. For instance, safeguard
your email, password and personal credentials when you are using the Services so that other people will not
have access to your personal data.
Furthermore, you are responsible for maintaining the security of any device on which you utilize the
Services. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any
personal data you provide to us. To the fullest extent permitted by applicable law, we do not accept
liability for unintentional disclosure.
Data security at RELai
We are aware that you entrust us with sensitive health data in the form of a conversation with AI. This
data is therefore processed exclusively on particularly secure Digital Ocean servers. Digital Ocean’s data
centres are subject to particularly high-security standards. This makes access to your data by
unauthorized third parties almost impossible. We also use internal technical and organizational measures
to protect your data. These are adapted in accordance with the current state of the art. To secure the
personal data you provide on our website, we use, for example, Transport Layer Security (TLS), which
encrypts the information you enter.
There is also no data transfer abroad or sale to third parties. We regularly check compliance with data
protection together with our data protection officer regarding the high level of data confidentiality.
For more information, please review digital ocean’s privacy policy.
Storage of Personal Data
We will keep your personal data for as long as it is necessary to fulfil the purposes for which it was
collected as described above and in accordance with our legal and regulatory obligations.
If you would like further information about our data retention practices, you can ask for this at any time
(see “Contact Us” section).
Your Rights
Anyone who uses RELai, regardless of where they live or are physically located, can access, correct,
delete or restrict their own data. You may also have various rights under data protection legislation in
your country (where applicable). That means if your country gives you even more rights, we will also
uphold those rights, too.
According to the law, you have the following data protection rights under data protection legislation in
Germany:
Right to information (Article 15 GDPR, Section 34 BDSG)
Right to erasure (Article 17 GDPR, Section 35 BDSG)
Right to rectification (Article 16 GDPR, Section 34 BDSG)
Right to restriction of processing (Article 18 GDPR)
Right to data portability (Article 20 GDPR)
Right to revoke consent (Article 7 Paragraph 3 GDPR)
Right to object (Article 21 GDPR)
Your rights may include (as relevant):
- The right of access enables you to check what type of personal data we hold about
you and what we do with that personal data and to receive a copy of this personal data.
- The right to rectification enables you to correct any inaccurate or incomplete
personal data that we hold about you.
- The right to erasure enables you to request that we erase personal data held
about you in certain circumstances.
- The right to restrict or object to processing of your personal data by us in
certain cases, including if you believe that the personal data held about you is inaccurate or our use
of the personal data is unlawful; and
- The right to data portability enables you to receive your personal data in a
structured, commonly used and machine-readable format and to have that personal data transmitted to
another data controller.
- The right to receive confidential communications containing your Protected Health
Information by alternative means, such as requesting that we contact you at a different email address
or phone number.
- The right to receive an accounting of disclosures we have made of your Protected
Health Information for a specified time period.
- The right to name a personal representative.
- The right to withdraw your consent; and
- The right to receive a paper copy of this Privacy Policy.
Any user can request the above, regardless of their jurisdiction. We will also process your request in
accordance with any other applicable laws. Note that we will require you to take steps to verify your
identity in accordance with applicable law.
If you wish to exercise any of the above rights, please contact us (see “Contact Us”).
Deletion of data (deletion concept)
Your personal and health data will only be processed on the basis of your consent when registering for
service. You can revoke your consent at any time, for example in your profile or by contacting us at
signal@RELai.one , If you revoke your consent, you can only use the
service to a limited extent. The consent then remains lawful until revoked.
Furthermore, within the framework of the right to erasure and the right to be forgotten, you have the option
of requesting the erasure of your data. In addition to the Federal Data Protection Act and the General Data
Protection Regulation as well as other laws (in particular the Fiscal Code (AO), the Commercial Code (HGB)
and the Social Code (SGB)), RELai has storage obligations for various types of data and documents.
In principle, we only store all data for as long as necessary to fulfil legal and contractual obligations.
We then delete the data immediately. Specific deletion periods can be found in the following sections.
Deletion of user data
RELai collects and processes certain user data. On the one hand, this concerns personal data ( e.g. e-mail
address, first/last name and IP address ) and on the other hand special categories of personal data, in
accordance with Art. 9 Para. 1 GDPR, in particular health data ( e.g. information on symptoms). To exercise
your right to erasure and right to be forgotten, simply log into RELai. You can then request the deletion of
your account and the data in your profile.
Deletion of billing data
For accounting reasons, billing-relevant data must be kept for up to ten years even after your deletion
request. We are legally obliged to do this, for example from the German Commercial Code, the Tax Code, the
Money Laundering Act and the Medical Devices Act. If you have registered for our services, we are obliged to
keep your billing data for a further year.
In order to fully comply with your deletion request, we will also use technical precautions to restrict and
pseudonymise such data that is subject to legal storage obligations immediately after your request, so that
it is then no longer possible to assign the data to your user profile. In this way, your pseudonymised data
will only be stored securely for legal storage purposes, but will no longer be processed. This is a security
measure to better protect your data.
Delete the app
Uninstalling our mobile application on your cell phone only deletes the application itself, but not the data
stored up to this point. To delete your data, please proceed as described above.
Deletion of applications
If there is no explicit consent from the applicant, application documents (e.g. cover letter, curriculum
vitae, etc.) must be deleted after six months, with the deadline starting as soon as the documents have been
received. This is based on applicant claims within the framework of the General Equal Treatment Act (AGG),
which can be asserted, for example, after an unsuccessful application.
For Android and iOS Apps
To request your data, you can contact support in the Settings section of the app or by emailing
signal@RELai.one from the email address you used to register with the
app. After verifying the legitimacy of the request, you will be sent an email that contains a .zip file
containing your personal data files.
Email Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email
to opt-out of receiving future emails. Note that you will continue to receive transaction-related emails
regarding products or Services you have requested. We may also send you certain non-promotional
communications regarding us and our Services, and you will not be able to opt-out of those communications
(e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by
applicable law.
Text Messages
You may opt-out of receiving text messages from us by following the instructions in the text message you
have received from us or by otherwise contacting us.
Mobile Devices
We may send you push notifications through our mobile application. You may opt-out of receiving these push
notifications by changing the settings on your mobile device.
“Do not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we
do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising
Some of our services require us to use so-called cookies. A cookie is a small text file that is stored on
your device by the browser. Cookies are not used to run programs or load viruses onto your computer. The
main purpose of our own cookies is rather to provide you with an offer specially tailored to you and to make
the use of our services as time-saving as possible. Most browsers are set by default to accept cookies.
However, you can adjust your browser settings so that cookies are rejected by default or only saved with
prior consent. If you refuse cookies, not all of our offers can function properly for you.
We use our own cookies in particular to note that information placed on our website has been displayed to
you. This ensures that the information is not displayed again the next time you visit the website. We want
to enable you to use our website comfortably and individually.
You may stop or restrict the placement of some of the technologies we use (e.g., cookies) on your device or
remove them by adjusting your preferences as your browser or device permits. However, if you adjust your
preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on
mobile applications.
However, you may opt out of personalized advertisements on some mobile applications by following the
instructions for
Android,
iOS and
others.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads
from data partners and other advertising partners that participate in self-regulatory programs. You can
access these and learn more about targeted advertising and consumer choice and privacy by visiting the
Network Advertising Initiative,
the Digital Advertising Alliance ,
the European Digital Advertising Alliance , and
the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Children’s Information
The Services are not directed to children under 13 and we do not knowingly collect personal data from
children. If you learn that your child has provided us with personal data without your consent, you may
contact us as set forth in “Contact Us” below. If we learn that we have collected any personal data in
violation of applicable law, we will promptly take steps to delete such personal data, unless we have a
legal obligation to keep it, and terminate the child’s account.
Third-Party Websites/Applications
The Services may contain links to other websites/applications and other websites/applications may reference
or link to our Services. These third-party services are not controlled by us. We encourage our users to read
the privacy policies of each website and application with which they interact. We do not endorse, screen or
approve, and are not responsible for, the privacy practices or content of such other websites or
applications. Providing personal data to third-party websites or applications is at your own risk.
Your Right to Lodge a Complaint with a Supervisory Authority
If you are unhappy about any aspect of the way we collect, share or use your personal data, please let us
know using the contact details below. If you are located in the European Economic Area, Switzerland, or the
United Kingdom, you also have a right to complain to your local Data Protection Authority if you prefer.
Contact details for Data Protection Authorities in the EU are available at
Data Protection.
Payment Details
If you choose to activate your subscription and pay for service, we offer you the payment methods credit
card, Paypal, Sepa direct debit or bank transfer on account. We process your payment data in order to
process the payments. Depending on the payment method selected, we will pass on your payment data to the
bank commissioned with the payment and, if necessary, to the payment service provider commissioned by us,
namely Stripe (Stripe Payments Europe Ltd, Block 4 Harcourt Centre, Harcourt Road, Dublin 2). All data
required for payment processing is used exclusively for making payments and is transmitted via the "SSL"
method. Stripe is PCI DSS certified. For more information, see Stripe's privacy policy.
Changes to This Policy
We may need to make changes to this Privacy Policy at any time. If we make any material changes to how we
collect your personal data, or how we use or share it, we will post or provide appropriate notice in
accordance with applicable law. You understand and agree that you will be deemed to have accepted the
updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
In order to ensure fairness of the processing, we encourage you to review the content of this Privacy Policy
regularly.
Contact Us
For further information, to exercise your rights, or if you have any questions or queries about this Privacy
Policy, please contact RELai’s
Data Protection Officer :
Email:
signal@RELai.one.