Last Updated: 24 January 2025
1. Introduction
Welcome to EvaTherapy (hereafter “the Website”), owned and operated by EvaTherapy (“we”, “us”, “our”). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our services, which include:
- Interacting with our AI therapy assistant (“Eva”) for one-to-one therapy chats;
- Accessing and participating in our online forums; and
- Enrolling in and viewing our courses and guides.
We are committed to protecting the privacy of our users (“you” or “your”). By accessing or using our Website and services, you confirm that you have read, understood, and agree to the practices described in this Privacy Policy.
2. Data Controller and Contact Information
For the purposes of the Swiss Federal Act on Data Protection (FADP), EvaTherapy is the Data Controller of your personal data processed through the Website.
- Data Controller: EvaTherapy
- Email: support@evatherapy.io
If you have any questions regarding this Privacy Policy or wish to exercise any of your legal rights, please contact us using the details provided above.
3. Types of Personal Data Collected
We may collect and process the following categories of personal data:
- Identity Data: e.g. your name, chosen username, or pseudonym.
- Contact Data: e.g. your email address, phone number, or other contact details you may provide.
- Account Data: Information you provide during account creation and use, including forum posts, messages, or other user-generated content.
- Therapy Interaction Data: The content of your chats with Eva, including any data relating to your mental or emotional health. As such, this may constitute sensitive personal data under the FADP and will be processed only with your explicit consent or another applicable legal basis.
- Usage Data: Information about your interactions with our Website, including IP address, browser type, device information, and browsing activity.
- Cookies and Tracking Technologies: We use cookies and similar technologies to collect usage data and enhance user experience. For further details, see Section 9.
Please note: While we respect the confidentiality of the information you share via our services, you are responsible for the information you post in public areas (e.g. forums) that may be visible to other users.
4. Legal Basis for Processing
We process your personal data only if we have a lawful basis under Swiss law. The legal bases include, as applicable:
- Consent: When you have provided explicit consent, in particular for the processing of sensitive personal data (e.g. data relating to mental or emotional health).
- Performance of a Contract: Where processing is necessary for the performance of our services, such as providing therapy sessions, forum access, or courses.
- Compliance with a Legal Obligation: When processing is required by law.
- Legitimate Interests: Where processing is necessary for our legitimate interests (for example, to improve our services, ensure security, or defend our legal rights), provided that such interests are not overridden by your fundamental rights and freedoms.
For the processing of sensitive personal data, explicit consent is required unless another legal basis applies.
5. Purposes for Collecting and Using Your Data
We use your personal data for the following purposes:
- Service Provision: To facilitate therapy chats with Eva, manage your forum membership, and provide access to courses and guides.
- Customisation: To tailor AI therapy sessions, forum content, or learning materials to your preferences and needs.
- Communication: To send you updates, respond to your queries, and provide technical or administrative support.
- Analytics and Improvement: To analyse and enhance the functionality, user experience, and security of our Website.
- Legal and Compliance: To comply with legal obligations, enforce our policies, or protect our rights and those of our users.
6. Data Retention
We will retain your personal data only as long as necessary for the purposes outlined in this Privacy Policy and in compliance with applicable legal or regulatory requirements. Once your data is no longer required, we will securely delete or anonymise it. Where possible, specific retention periods will be communicated or are detailed in our internal policies.
7. Data Sharing and Disclosure
We may share your personal data in the following circumstances:
- Service Providers: We engage trusted third-party processors (e.g. for data hosting, analytics, or customer support) who act solely on our instructions and in compliance with this Privacy Policy and applicable data protection laws.
- Legal Obligations: We may disclose your personal data to law enforcement agencies, courts, or regulatory bodies if required by law or to protect our rights, property, or users.
- Business Transfers: In the event of a merger, acquisition, or asset sale, your personal data may be transferred as part of the transaction.
We do not sell your personal data or share it for direct marketing purposes without your explicit consent.
8. International Data Transfers
Your personal data may be transferred to and processed in countries outside Switzerland. In such cases, we will ensure that appropriate safeguards are in place (such as Standard Contractual Clauses or other approved transfer mechanisms) to protect your data in accordance with the applicable data protection standards.
9. Cookies and Similar Technologies
We use cookies, web beacons, and other tracking technologies to collect information about your interactions with our Website. This information is used to:
- Analyse user behaviour;
- Remember your preferences; and
- Enhance the functionality and performance of our services.
You can manage or disable cookies through your browser settings. However, please note that disabling cookies may affect the functionality of our Website.
10. Security Measures
We employ industry-standard technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or disclosure. These measures include encryption, secure servers, regular security assessments, and internal access restrictions. However, no transmission or storage system is entirely infallible, and we cannot guarantee absolute security.
11. Your Rights Under Swiss Data Protection Law
Subject to certain conditions, you have the following rights regarding your personal data:
- Right of Access: You may request a copy of the personal data we hold about you.
- Right of Rectification: You may request the correction of any inaccurate or incomplete data.
- Right to Erasure: In certain circumstances, you may request the deletion of your personal data.
- Right to Restrict Processing: You may request that we limit the processing of your personal data under specific conditions.
- Right to Object: You may object to the processing of your personal data on grounds relating to your particular situation.
- Right to Withdraw Consent: If processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
To exercise any of these rights, please contact us using the details provided in Section 2. You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC).
12. Children’s Privacy
Our services are not intended for children under the age of 16. We do not knowingly collect or process personal data from children without verifiable parental consent. If you believe that we have inadvertently collected data from a child, please contact us immediately so that we can delete the information.
13. Third-Party Links
Our Website may include links to third-party websites, applications, or services. We do not control these external sites and are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.
14. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time. Should we make any material changes, we will notify you by updating the “Last Updated” date at the top of this document and by providing notice on our Website. Your continued use of our services after such changes constitutes your acceptance of the updated Privacy Policy.
15. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us at:
- Email: support@evatherapy.io