Last Updated: January 2024

EMDRly ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our application and website (collectively, the "Service").

Please read this Privacy Policy carefully. By using EMDRly, you consent to the practices described in this policy.

1. Our Privacy Commitment

EMDRly handles sensitive personal information related to mental health and therapy. We take this responsibility seriously and have designed our Service with privacy as a foundational principle:

2. Information We Collect

2.1 Information Stored on Your Device (Not Sent to Us)

The following information is stored locally on your device and is NOT transmitted to EMDRly servers unless you explicitly choose to share it with your healthcare provider:

2.2 Information We Collect

We collect limited information necessary to provide and improve the Service:

Account Information:

Usage Information:

Communication Data:

2.3 Information Shared with Healthcare Providers

If you choose to connect with a healthcare provider through EMDRly, you control what is shared:

Important: When information is shared with providers, it is transmitted using anonymized client codes—not your name or other identifying information—to protect your privacy.

3. How We Use Your Information

We use the information we collect to:

4. AI Features and Anonymization

EMDRly uses artificial intelligence to provide supportive responses and insights. Here's how we protect your privacy when using AI features:

4.1 Anonymization Process

Before any text is sent to AI providers for processing:

4.2 Pre-Built Responses

Many supportive responses in EMDRly are pre-built and stored locally, requiring no external AI processing at all. This minimizes data transmission while still providing helpful support.

4.3 AI Provider Data Handling

When AI processing is required, we use providers that:

5. Data Storage and Security

5.1 Local Storage

Personal content (journals, memories, dreams) is stored on your device using industry-standard encryption. This means:

5.2 Server Storage

For data that is stored on our servers (account information, subscription data, aggregated metrics), we employ:

5.3 Data Backup

Locally stored data is not automatically backed up to our servers. If you want to preserve your data:

6. HIPAA Compliance

For healthcare provider features, EMDRly is designed to comply with the Health Insurance Portability and Accountability Act (HIPAA):

7. Information Sharing

We do not sell, rent, or trade your personal information. We may share information only in these limited circumstances:

7.1 With Your Consent

We share information when you explicitly direct us to, such as sharing data with your healthcare provider.

7.2 Service Providers

We use trusted third-party service providers for:

These providers are bound by contracts requiring them to protect your information.

7.3 Legal Requirements

We may disclose information if required by law, court order, or government request, or if we believe disclosure is necessary to protect rights, safety, or prevent illegal activity.

7.4 Business Transfers

If EMDRly is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you of any such change.

8. Your Rights and Choices

8.1 Access and Export

You can access and export your data at any time through the app settings. Local data can be exported in common formats (JSON, PDF).

8.2 Deletion

You can delete your account and all associated data by contacting us or using the in-app deletion feature. Note that:

8.3 Communication Preferences

You can opt out of non-essential communications at any time. Essential service communications (security alerts, billing) cannot be opted out of while maintaining an active account.

8.4 California Residents

Under the California Consumer Privacy Act (CCPA), California residents have additional rights including the right to know what information is collected, the right to delete, and the right to opt out of sales (though we do not sell personal information).

8.5 EU/EEA Residents

Under GDPR, you have rights including access, rectification, erasure, data portability, and the right to lodge a complaint with a supervisory authority.

9. Children's Privacy

EMDRly is not intended for children under 13. We do not knowingly collect information from children under 13. If we become aware that we have collected information from a child under 13, we will delete it promptly.

Users between 13 and 18 may use EMDRly with parental/guardian consent and supervision.

10. Cookies and Tracking

Our website uses limited cookies for:

You can control cookies through your browser settings.

11. Third-Party Links

EMDRly may contain links to third-party websites or services (such as crisis resources). We are not responsible for the privacy practices of these third parties. Please review their privacy policies separately.

12. Data Retention

13. International Data Transfers

EMDRly is based in the United States. If you access the Service from outside the US, your information may be transferred to and processed in the US. We use appropriate safeguards for international transfers, including Standard Contractual Clauses where required.

14. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

Your continued use of the Service after changes constitutes acceptance of the updated policy.

15. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

EMDRly Privacy Team
Email: privacy@emdrly.com

For data protection inquiries in the EU/EEA, you may contact our Data Protection Officer at dpo@emdrly.com.

By using EMDRly, you acknowledge that you have read and understood this Privacy Policy.