Privacy Declaration

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?

Data collection with regards to using the self-help program (everything under www.wemingo.com/en/course/)

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.

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 six weeks after the two-year period has passed after prior notification.

Data collection when using the publicly accessible sites

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 the web analytics service "Plausible Analytics" to understand which content is accessed and how often. Plausible is a trademark of Plausible Insights OÜ, Västriku tn 2, 50403, Tartu, Estonia, Registration number 14709274, hereinafter only referred to as "Plausible". Plausible Insights OÜ is fully compliant with the GDPR.

Plausible takes a particularly privacy-friendly approach to analyzing your visit. Plausible collects the following information, among others, for this purpose: Date and time of your visit, title and URL of the pages visited, incoming links, the country you are in and the user agent of your browser software. Plausible does not use or store "cookies" on your terminal device. All personal data (e.g. your IP address) is stored completely anonymously in the form of a so-called hash. A hash is an encryption of data that is not reversible, i.e. cannot be "decrypted". In this way, we can analyze your visit without storing personal data in a form that would be readable by us, plausible or third parties.

Further information on the technical implementation can be found here: https://plausible.io/privacy-focused-web-analytics.

Further information on data protection at Plausible can be found at https://plausible.io/data-policy.

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").

The collection of this data is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website - for this purpose, the server log files must be collected.

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.

Our page is only setting so-called "session cookies". They are automatically deleted at the end of your visit. These cookies issued by us cannot be used for tracking your online activity.

Data Security

Your data is stored on a server hosted by Netcup GmbH 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.

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: November 11, 2022