1. Our two roles
For a therapist’s own account information, Well-Being is the data fiduciary. For a therapist’s clients’ information (including clinical notes), the therapist is the data fiduciary and Well-Being is a data processor acting only on the therapist’s instructions. Clients should also read their therapist’s own privacy notice.
2. Information we handle
Provided by therapists
- Account and profile details: name, email, credentials, bio, photo, services, availability.
- Payment details you choose to display (for example a UPI ID) and your connected Google account, if you link one.
About clients
- Identity and contact details, booking history, and consent records.
- Sensitive clinical information — session notes, assessments (such as PHQ-9 / GAD-7) and mood logs. This content is encrypted at rest (AES-256-GCM) and is not readable by Well-Being outside the therapist’s authenticated session.
Collected automatically
- Sign-in and session data, and audit logs recording access to records (for security).
- Basic technical logs needed to run and protect the service. [VERIFY: no analytics/tracking SDK is currently used — update this before adding one.]
3. Why we use it and our lawful basis
We use this information only to provide and secure the service: to run your bookable page and scheduling, store notes for you, generate payment links and receipts, create video-call links, and keep the service safe. We rely on your consent and on the necessity of providing the service you asked for. We do not sell personal data or use clinical content for advertising.
4. Who we share it with
We share data only with service providers that help us run Well-Being, under contract:
- Google — when a therapist connects their Google account, to verify identity and create Google Meet links (via the Meet API). [VERIFY: scope.]
- Hosting and database providers that store the service’s data. [VERIFY: names and locations.]
- Email provider for transactional messages such as receipts. [VERIFY: name.]
- Payments: UPI payments are made directly between client and therapist; a payment gateway (for example Razorpay) may be added later. [VERIFY.]
5. Storage, security and retention
Clinical content is encrypted at rest, access is audit-logged, and access follows deny-by-default rules. We keep information for as long as the account is active or as needed to provide the service and meet legal obligations, then delete or anonymise it. [CHECK: retention periods per data type.] [VERIFY: whether any provider stores data outside India and the safeguards for that transfer.]
6. Your rights
Subject to law, you can ask to:
- access the personal data we hold about you and get a copy (export);
- correct or update inaccurate data;
- delete your data / close your account;
- withdraw consent, and know who your data has been shared with.
Clients: many of these requests are handled through your therapist, who controls your clinical records. To make a request to Well-Being, contact us at [CHECK: contact email].
7. Grievances and breaches
Our grievance contact is [CHECK: grievance officer name / email]. If a personal-data breach occurs, we will act on it and notify the relevant people and authorities as required by law (aiming to notify within about 72 hours of becoming aware). [VERIFY: process and timelines with counsel.]
8. Children
Well-Being is not directed at children. [CHECK: state the minimum age and how the therapist handles consent for any client who is a minor.]
9. Changes and contact
We will post updates to this policy here and update the effective date. Questions or requests: [CHECK: contact email].