Version from 21.02.2024

Aepsy AG, based in Zurich, is a public limited company pursuant to Art. 620 ff. OR. In this privacy policy, we, Aepsy AG (hereinafter Aepsy, we or us), explain how we collect and otherwise process personal data. This is not an exhaustive description; contracts, other data protection declarations or general terms and conditions, conditions of participation and similar documents may govern specific matters. Personal data refers to all information relating to an identified or identifiable person.

If you provide us with the personal data of other persons (e.g. your customers, family members or similar), please ensure that these persons are aware of this privacy policy and only provide us with their personal data if you are permitted to do so and if this personal data is correct. You warrant that you have collected the personal data of third parties forwarded to us lawfully, i.e. with consent to the collection and forwarding to third parties, including us.

This Privacy Policy is designed to meet the requirements of the EU General Data Protection Regulation ("GDPR**") and the Swiss Data Protection Act ("DPA**"). Whether and to what extent these laws are applicable depends on the individual case.

Responsible person / data protection officer / representative

Aepsy AG (Seilergraben 53, 8001 Zurich) is responsible for the data processing described here. Internally, Hiep Doan is responsible for data processing. If you have any data protection concerns, you can send them to us at the following contact address:

Aepsy AG, Seilergraben 53, 8001 Zurich E-mail: hey@aepsy.com.

Collection and processing of personal data

We primarily process the personal data that we receive from our customers (hereinafter "customers") and other business partners in the course of our business relationship with them and other persons involved or that we collect from their users when operating our websites, software and other applications.

When you register with us as a user, we ask you for the following contact information:

• First and last name
• E-mail address
• Telephone number

This contact information allows us to verify your identity and inform you of any changes / important situations regarding our services (for which we may send you an e-mail). The contact information is also used to enable the psychological providers to contact you at your request and to confirm bookings and/or send appointment reminders.

Our services are intended to help you find a suitable psychological provider / support and suitable forms of counseling. When you use our services, we therefore ask you about your age and any symptoms and give you the opportunity to provide further information about your well-being and your current situation. We make this data available to psychological providers so that they can get an idea of how they can best help you before a counseling session. You can also pay for certain services such as counseling sessions directly via the platform. Depending on the payment method, we may need to collect certain data, such as your credit card number.

You can also use the platform's journal function to document your development. At your request, this data can also be made available to the psychological providers of your choice.

We do not make this data available to any other third parties. The data is also used anonymously to continuously optimize security, the offer / services and user experience. You are aware that particularly sensitive data about your health may be collected and passed on to the psychological providers, and you expressly agree to this

When you contact us - for example by sending us an e-mail - we receive certain personal data about you. This data includes, in particular, contact details, the content of your communication and the content of any attachments or enclosures. We use this data to process your contact request.

If you subscribe to our newsletter, we collect your contact details and, if necessary, information that allows us to verify that you are the owner of the e-mail address provided and that the owner agrees to receive the newsletter. You can revoke your consent to this at any time - for example via the 'unsubscribe' link in the newsletter.

If you contact us as a psychological provider with the intention of joining the platform or receiving information about joining, we will ask you for a range of personal data. This data is used to process your request and, if necessary, to connect you to our platform and thus provide our services. Please note that some of this data is publicly accessible via the psychologist's page on Aepsy. The data includes in particular

• First and last name
• Profile picture
• Video and audio introduction (optional)
• E-mail address
• Phone number (optional)
• Age (optional)
• Language skills
• Short description / Bio
• Diplomas, certificates, licenses and similar
• Information on the pricing model, availability to accept new patients and other information on the psychological provider's services (e.g. location)
• List of recommended other psychological providers (optional)
• Information on time availability (e.g. via calendar function) (optional)
• Information on payment processing

Personal data that we collect when you use our services

When you use our services, we collect data about how you access our services and how you use them ("Usage Data"). This Usage Data is sent by your browser each time you visit our website and may include information such as IP address, browser type, browser version, the pages of our website you visit, the time and date of your visit, the time spent on those pages, and other anonymized data about the choices you make on the website (e.g., the psychological provider(s)). If you access our website from a mobile device, the usage data may also include information about the type of your device, its unique ID and other diagnostic data. The purpose of collecting this usage data is to provide, maintain and improve our website and your user experience. We may also share the data in anonymized form with selected research institutions for research purposes.

We and our partners (e.g. our advertising and analytics partners) use cookies and related tracking technologies to track your use of our services and to collect certain data. For more information, please see section 11 of this Privacy Policy and our separate Cookie Policy.

Personal data we receive from third parties

Other users of our services may provide personal data about you when they contact us. For example, we may receive data about you as part of a support request from another user. We use this data to process the corresponding requests from other users.

We may receive data about you and your activities on and off our website from our partners (e.g. from our advertising and analysis partners). We may thus receive information about your interest in and activities in connection with our services. We may use this data to improve our services and your user experience and to advertise them.

Other features on our platform may require us to collect data from third parties on behalf of our users. Details of the individual services can be found in the following sections:

Notes feature

Psychological providers can use a notes function on our platform. This allows them to create notes about patients and update them on an ongoing basis. We take appropriate technical and organizational measures to protect the notes from access by third parties. If you as a client do not want the notes or request that the notes be deleted, Aepsy is entitled to hand these notes over to your psychological provider and irrevocably delete them from the Aepsy server. Aepsy assumes no liability for the notes created and does not review them. The note function serves to simplify your treatment. The psychological provider bears full responsibility for the content of the notes created. The right to delete one's own data, which flows from data law, is regularly opposed by the documentation obligations of psychological providers as medical professionals. These are imposed on them, for example, by cantonal health laws (up to 20 years retention obligation, depending on the canton) or statutory retention periods (e.g. due to the statute of limitations). As a rule, a psychological provider cannot comply with your request to delete all data or hand over all original documents because otherwise it would be in breach of its statutory retention obligations. Aepsy is not involved in your treatment and will therefore delete all notes from your psychological provider on request.

Connection with external calendar applications (e.g. Google Calendar, Outlook Calendar and other calendar applications)

An Aepsy provider can use the external calendar application integrations (e.g. Google Calendar or Outlook Calendar) to connect their calendar to Aepsy and thus simplify scheduling. Aepsy is structured in such a way that it only accesses the minimum data required from connected calendars in order to provide its service. For example, Aepsy only checks the duration and free/busy status of appointments in your external calendar so that we don't book when you are busy. Aepsy is designed not to store details about the appointments in your calendar, such as the person you are meeting with, their email, the title of the meeting or other details about the appointments in your calendar.

We collect and access them:

• The date, time and duration of the appointment
• Whether it is a busy or non-busy event
• Email of the owner of the external calendar

We use this data for:

• Anonymous display of external calendar events in the Aepsy calendar. No information about the participants, the name and description of the event is stored and used.
• Changing events that come from Aepsy in the provider's external calendar. If, for example, an event is updated or canceled, we also update or delete the corresponding event in the provider's calendar.

We do not pass on, sell, give away, etc. any information that we collect, retrieve or store via the external calendar to third parties.

Publicly accessible sources

Where permitted, we also take certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, press, Internet) or receive such data from authorities and other third parties. In addition to the data that you provide to us directly, the categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and court proceedings, information in connection with your professional functions and activities (so that we can, for example to conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we process transactions with you personally), information about you that people in your environment (business partners, service providers, family, consultants, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or with your involvement (e.g. References, your address for deliveries, powers of attorney, information on compliance with legal requirements such as the fight against money laundering and export restrictions, information from banks, insurance companies, sales and other contractual partners of ours on the use or provision of services by you (e.g. payments made, contracts processed), information from the media and Internet about your person (insofar as this is appropriate in the specific case, e.g. in the context of a job application, press releases, etc.).E.g. in the context of an application, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other socio-demographic data (for marketing), data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location data).

As part of our business relationship with our customers and other business partners, we may receive particularly sensitive personal data from them and other persons involved. This includes, in particular, data relating to health and privacy. In these cases, we work to ensure that the responsible customers and other business partners obtain written consent from the persons concerned.

If we collect particularly sensitive personal data from you ourselves, which we avoid whenever possible, we will obtain your express and informed consent in advance.

Purposes of data processing and legal bases

We primarily use the personal data we collect to conclude and process our contracts with our customers and business partners, in particular in connection with the use of our platform for the placement of psychological providers, the associated app and the website under the domain <www.aepsy.com> and any subdomains, as well as to comply with our legal obligations in Switzerland and abroad. If you work for such a customer or business partner, your personal data may of course also be affected in this function.

In addition, we also process personal data of you and other persons, where permitted and where we deem it appropriate, for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

• Offering and further development of our offers, services, websites, software and other platforms on which we are present;
• Support services for the users of our offers, services, websites, software and other platforms
• Communication with third parties and processing their inquiries (e.g. applications, media inquiries)
• Examination and optimization of procedures for needs analysis for the purpose of direct customer contact and collection of personal data from publicly accessible sources for the purpose of customer acquisition;
• Advertising and marketing (including the organization of events), provided you have not objected to the use of your data (if we send you advertising as an existing customer, you can object to this at any time and we will then place you on a blacklist against further advertising mailings);
• Market and opinion research, media monitoring;
• Assertion of legal claims and defense in connection with legal disputes and official proceedings;
• Prevention and investigation of criminal offenses and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud, compliance and adherence to regulatory requirements);
• Ensuring our operations, in particular IT, our websites, apps and other platforms;
• Video surveillance to safeguard domiciliary rights and other measures for IT, building and facility security and protection of our employees and other persons and assets belonging to or entrusted to us (e.g. access controls, visitor lists, network and mail scanners, telephone recordings);
• Acquisition and sale of business divisions, companies or parts of companies and other transactions under company law and the associated transfer of personal data as well as measures for business management and, where necessary, compliance with legal and regulatory obligations and Aepsy's internal regulations.

If you have given us your consent to process your personal data for specific purposes (for example, when you register to receive newsletters or carry out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and require one. Consent that has been given can be withdrawn at any time, but this has no effect on data processing that has already taken place and to which you have (possibly implicitly) consented.

We only process particularly sensitive personal data if this is absolutely necessary in order to conclude and process our contracts with our customers and business partners. In particular, this data is not used for advertising and marketing purposes or passed on to third parties without compelling necessity.

Cookies / tracking and other technologies in connection with the use of our website

We typically use "cookies" and similar technologies on our websites and platforms to identify your browser or device. A cookie is a file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our website or use a platform. This enables us to recognize you when you return to this website, even if we do not know who you are. In addition to cookies that are only used during a session and are deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time (e.g. two years) ("permanent cookies"). However, you can set your browser so that it rejects cookies, only stores them for one session or otherwise deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that you can save user settings (e.g. language, auto-login), so that we can better understand how you use our offers and content, and so that we can show you offers and advertising tailored to you (which can also happen on websites of other companies; however, we will not tell them who you are, if we know this at all, because they will only see that the same user is on their website who was also on a particular page on our website). Some of the cookies are set by us, some are also set by contractual partners with whom we work. If you block cookies, certain functionalities (such as language selection, contact forms, platform processes, etc.) may no longer work.

In some of our newsletters and other marketing emails, we also include visible and invisible image elements, where permitted, which we can retrieve from our servers to determine whether and when you have opened the email so that we can measure and better understand how you use our offers and tailor them to you. You can block this in your email program; most are pre-set to do this. By using our websites and agreeing to receive newsletters and other marketing emails, you consent to the use of these techniques. If you do not want this, you must set your browser or e-mail program accordingly.

If Google Analytics or other statistical services are used to which no personal data (such as e-mail addresses) is transmitted:

We sometimes use Google Analytics or similar services on our websites. This is a service provided by third parties, which may be located in any country in the world (in the case of Google Analytics, it is Google Ireland (based in Ireland), Google Ireland relies on Google LLC (based in the USA) as a processor (both "Google"), www.google.com, with which we can measure and evaluate the use of the website (non-personal). Permanent cookies set by the service provider are also used for this purpose. We have configured the service so that the IP addresses of visitors to Google in Europe are truncated before being forwarded to the USA and therefore cannot be traced. We have switched off the settings "Data transfer" and "Signals". Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can use this data for its own purposes to draw conclusions about the identity of visitors, create personal profiles and link this data to the Google accounts of these persons. If you have registered with the service provider yourself, the service provider also knows you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider only informs us how our respective website is used (no information about you personally).

If social media plug-ins are used:

We also use so-called plug-ins from social networks such as Facebook, Twitter, YouTube or Instagram on our websites. This is visible to you in each case (typically via corresponding symbols). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.

Data transfer and data transmission

As part of our business activities and for the purposes set out in section 3), we also disclose data to third parties where permitted and where we deem it appropriate, either because they process it for us or because they wish to use it for their own purposes. This applies in particular to the following bodies:

• Service providers of ours, including their contract processors (such as IT providers);
• Dealers, suppliers, subcontractors and other business partners;
• Authorities, official bodies or courts;
• The media;
• The public, including visitors to websites and social media;
• Competitors, industry organizations, associations, organizations and other bodies;
• Acquirers or parties interested in acquiring business units, companies or other parts of Aepsy;
• other parties in potential or actual legal proceedings;

all together hereinafter referred to as "Recipients".

These recipients are domestic.

Particularly sensitive personal data will only be passed on if this is absolutely necessary in order to conclude and process our contracts with our customers and business partners or if we are legally obliged to do so.

Duration of the storage of personal data

We process and store your personal data for as long as is necessary for the fulfillment of our contractual and legal obligations or otherwise for the purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) and beyond in accordance with the statutory retention and documentation obligations. It is possible that personal data may be stored for the period in which claims can be asserted against our company and insofar as we are otherwise legally obliged to do so or legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized as far as possible. For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply.

Data security

We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse, such as issuing instructions, training, IT and network security solutions and encryption of data carriers and transmission.

Particularly sensitive personal data is only processed by qualified employees who have signed a corresponding confidentiality agreement.

Obligation to provide personal data

As part of our business relationship, you must provide the personal data required to enter into and conduct a business relationship and to fulfill the associated contractual obligations (you do not generally have a legal obligation to provide us with data, unless this is requested by court or supervisory authorities). Without this data, we will generally not be able to enter into or perform a contract with you (or the entity or person you represent). It will also not be possible to use the website if certain information to secure data traffic (e.g. IP address) is not disclosed.

Profiling and automated decision-making

We process your personal data partially automatically with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to provide you with targeted information and advice about products. In doing so, we use evaluation tools that enable us to provide needs-based communication and advertising, including market and opinion research.

As a matter of principle, we do not use fully automated decision-making (as regulated in Art. 22 GDPR) to establish and conduct the business relationship or otherwise. Should we use such procedures in individual cases, we will inform you of this separately if this is required by law and inform you of the associated rights.

Rights of the data subject

You have the right to information, correction, deletion, the right to restrict data processing and otherwise to objection to our data processing, in particular for the purposes of direct marketing, profiling for direct advertising and other legitimate interests in processing as well as to the disclosure of certain personal data for the purpose of transfer to another body (so-called data portability) within the framework of the data protection law applicable to you and to the extent provided for therein (as in the case of the GDPR). Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, have an overriding interest in doing so (insofar as we are entitled to invoke this) or require it for the assertion of claims. If you incur costs, we will inform you in advance. We have already informed you about the possibility of withdrawing your consent in section 3. Please note that exercising these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract or cost consequences. We will inform you in advance if this is not already contractually regulated.

The exercise of such rights generally requires that you provide clear proof of your identity (e.g. by means of a copy of your ID where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 1.

Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner.

Changes

We may amend this privacy policy at any time without prior notice. The current version published on our website applies. If the privacy policy is part of an agreement with you, we will inform you of the change by e-mail or other suitable means in the event of an update.

Contact

If you have any questions about this privacy policy, please contact us:

Aepsy AG Seilergraben 53, 8001 Zurich hey@aepsy.com