Privacy Policy for StrongMinds’ Amani WhatsApp Service

This Privacy Policy (the “policy”) is for StrongMinds’ official “Amani” WhatsApp service (“the WhatsApp Service”). In processing your personal information, we will comply with the EU’s General Data Protection Regulation and this policy. For the purpose of this policy, “processing” includes collecting, using, storing, retrieving, disseminating, and destroying, and your “personal information” (PI) is information about a data subject, who is an identifiable living natural person (i.e., you). Nothing contained in this policy shall be a waiver of StrongMinds’ privileges and immunities under law or as submitting StrongMinds to any national court jurisdiction.

CONSENT: You consent to us processing your PI in accordance with the provisions of this policy. You consent to your PI being processed outside of your country where necessary and to us sharing your PI for the purpose of this policy. You understand that WhatsApp and other third parties may have additional terms and conditions applicable to the use of the WhatsApp Service, which may include privacy and personal data terms (including WhatsApp’s privacy policy, mentioned below); you understand that these terms are not from StrongMinds and you agree to be responsible for any such third-party terms.

WE COLLECT:

  • Your phone number and WhatsApp username directly from you through the WhatsApp Service,
  • If you send messages to the WhatsApp Service, we will receive the information that you include,
  • Location (Town/City/ Country or a Location Pin), age, and gender.
  • the name of your network operator and the country in which your network operator is located,
  • details of the menu items you select.

Communications using WhatsApp are secured with end-to-end encryption (WhatsApp’s privacy policy at https:// www.whatsapp.com/legal/#privacy-policy.)

WE PROCESS YOUR PERSONAL INFORMATION:

  • to provide you with further mental health screening and opportunities for enrollment in our programs,
  • to allow you to meaningfully participate in the WhatsApp Service,
  • to contact you to ask you for further information and to prompt you to carry out follow up,
  • to help us understand how chatbot users experience and understand depression symptoms,
  • to aggregated and anonymized information on mental health in Africa,
  • to conduct research and statistical analysis,
  • to administer this WhatsApp Service,
  • to improve this WhatsApp Service and other communications channels that StrongMinds might use in its public education and outreach,
  • to keep this WhatsApp Service safe and secure and for any other purpose authorized by you (requests for a consultation with a StrongMinds counselor).

DISCLOSING YOUR PERSONAL INFORMATION:

We will not publish or sell any personally identifiable information. Your PI may be shared with persons who provide services to us to the extent necessary for those persons to provide those services to us. We may disclose your PI:

  • when we believe that disclosure is reasonably necessary to comply with any law, regulation, legal process, or government request,
  • to enforce our contracts and policies,
  • to protect the security and integrity of the WhatsApp Service and to protect ourselves and the
  • public from illegal activities; or
  • to respond to an emergency which we believe in good faith requires us to disclose information.

PROTECTING YOUR PERSONAL INFORMATION

We will take reasonable steps to keep your PI safe from loss, unauthorized activity, or other misuses. We are legally obliged to provide adequate protection for the PI we hold and to stop unauthorized access and use of personal information. The transmission of information via the internet is not completely secure. We will do our best to protect your PI but we cannot guarantee the security of your information transmitted through this WhatsApp Service; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. The WhatsApp Service may, from time to time, provide links to external sites which have their own privacy policy relating to your PI. Review that site’s privacy policy before you provide PI. We are not responsible for the privacy policies or the content of such sites. Users will be notified if there is a data breach with undue delay if there is a high risk of harm to the data subject.

ACCESSING, CORRECTING, AND ERASING YOUR PERSONAL INFORMATION

If you have any questions or requests relating to this policy, email us at [email protected] Your email should provide evidence of who you are and set out the details of your request (e.g., the PI, or the correction, that you are requesting).