TFW provides a platform through which individuals may access counseling, coaching, assessments, educational resources, and related personal development services.
For purposes of this Privacy Policy, “TFW,” “we,” “us,” or “our” refers to TFW and the entity responsible for operating the Services.

“You” or “your” refers to any individual who visits our website, creates an account, submits information, purchases a service, communicates with us, or otherwise uses our Services.

We may collect information directly from you, automatically when you use our Services, or from third parties where appropriate and permitted by law.

2.1 Information You Provide

Depending on how you use TFW, we may collect:

• •Name and preferred name
• •Email address
• •Telephone or mobile number
• •Country, city, or general location
• •Date of birth or age where necessary
• •Gender or other demographic information where voluntarily provided
• •Account login credentials
• •Profile information
• •Emergency contact information, where applicable
• •Information provided when contacting our support team
• •Information submitted through forms, questionnaires, assessments, surveys, or feedback
• •Information provided when registering for counseling or coaching
• •Information relating to your preferences, goals, concerns, or areas in which you are seeking support
• •Information contained in communications with TFW
• •Information necessary to process payments and subscriptions

You should only provide information that is relevant to your use of the Services.

If you use TFW to access counseling or coaching services, you may voluntarily provide information that is personal or sensitive in nature.

This may include information relating to:

• •Personal circumstances
• •Relationships and family
• •Emotional wellbeing
• •Personal challenges
• •Life experiences
• •Goals and aspirations
• •Behavioral patterns
• •Personal development
• •Family or parenting matters
• •Work or career circumstances
• •Other information you choose to share with a counselor or coach

Such information is treated with care and is only collected, used, accessed, or disclosed as reasonably necessary to provide, manage, protect, and improve the relevant Services, subject to applicable law and the professional obligations of the relevant counselor or coach.

Important distinction regarding confidentiality

TFW's platform privacy practices and the professional confidentiality obligations of an individual counselor or coach are related but are not identical.

Information shared during a counseling or coaching relationship may be subject to professional confidentiality obligations applicable to the counselor or coach. However, confidentiality may have legal or ethical exceptions in certain circumstances, including where disclosure is required or permitted by applicable law, where there is a serious and imminent safety concern, or where disclosure is otherwise necessary to comply with legal or professional obligations.

Your counselor or coach may provide additional information about confidentiality and its limitations before or during your sessions.

TFW may provide assessments, questionnaires, screening tools, self-reflection exercises, or similar features.
Information submitted through these tools may include personal or sensitive information depending on the nature of the assessment.

We may use assessment information to:

• •Provide the requested service
• •Help you understand your responses or results
• •Support counseling or coaching where applicable
• •Personalize your experience
• •Improve our programs and services
• •Conduct internal analysis and quality improvement
• •Generate aggregated or de-identified insights where appropriate

Unless specifically stated otherwise, an assessment or questionnaire provided through TFW is not intended to constitute a medical diagnosis or replace professional medical or mental health care.

When you access or use our website or platform, certain information may be collected automatically.

This may include:

• •IP address
• •Browser type and version
• •Device type
• •Operating system
• •General location information
• •Language preferences
• •Pages or features accessed
• •Date and time of access
• •Referring website or source
• •Usage patterns
• •Technical and diagnostic information
• •Information relating to errors or performance

We may use this information to operate, secure, maintain, analyze, and improve our Services.

TFW may use cookies, pixels, tags, local storage, analytics tools, and similar technologies.

These technologies may be used to:

• •Keep you signed in
• •Remember preferences
• •Maintain session functionality
• •Understand how users interact with our website
• •Improve website performance
• •Analyze traffic and usage
• •Detect fraud or security threats
• •Support marketing activities where permitted

You may be able to control cookies through your browser or device settings. Certain cookies may be necessary for the website or platform to function correctly.
Where required by applicable law, we will obtain appropriate consent before placing non-essential cookies or similar technologies.

We may use personal information for the following purposes:

Providing Services

To:

• •Create and manage your account
• •Provide counseling and coaching services
• •Schedule and manage sessions
• •Process assessments and questionnaires
• •Provide resources and personalized content
• •Process subscriptions and payments
• •Respond to inquiries and requests
• •Provide customer support

Operating and Improving TFW

We may use information to:

• •Maintain and improve our website and platform
• •Develop new services and features
• •Understand user needs and preferences
• •Monitor platform performance
• •Conduct research and analysis using aggregated or de-identified information
• •Improve user experience
• •Troubleshoot technical issues

Safety and Security

We may use information to:

• •Protect users and our Services
• •Detect and prevent fraud, abuse, and unauthorized access
• •Investigate security incidents
• •Enforce our Terms of Use and other policies
• •Protect the rights, property, and safety of TFW, our users, counselors, coaches, and others

Legal and Regulatory Purposes

We may process information where necessary to:

• •Comply with applicable laws and regulations
• •Respond to lawful requests from government authorities
• •Establish, exercise, or defend legal claims
• •Meet professional, regulatory, or contractual obligations

Where applicable law requires us to identify a legal basis for processing personal information, we may rely on one or more of the following:

• •Your consent
• •Performance of a contract with you
• •Compliance with a legal obligation
• •Protection of vital interests
• •Our legitimate interests, where permitted by law
• •Other lawful grounds recognized by applicable law

Where we rely on consent, you may withdraw your consent where permitted by law. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

TFW does not sell your personal information.
We may share information in limited circumstances and only where reasonably necessary, including with:

Counselors and Coaches

Information may be made available to the counselor or coach providing services to you so that they can deliver the requested service.

Service Providers

We may use trusted third-party providers to support our operations, including providers for:

• •Hosting and cloud infrastructure
• •Payment processing
• •Email and communications
• •Scheduling
• •Video or audio communications
• •Customer support
• •Analytics
• •Security
• •Data storage
• •Technical development and maintenance

These providers may only process information as necessary to provide services to us and subject to appropriate contractual or legal protections.

Legal and Regulatory Authorities

We may disclose information where required or permitted by applicable law, court order, legal process, or governmental request.

Safety-Related Circumstances

We may disclose information where reasonably necessary to address a serious safety concern, protect an individual from significant harm, or comply with applicable legal or professional obligations.

Business Transactions

If TFW is involved in a merger, acquisition, restructuring, financing, sale of assets, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable legal requirements.

TFW does not sell or rent your personal information to advertisers or other third parties.
We also do not permit advertisers to access private counseling or coaching information for their own purposes.
Where analytics, advertising, or similar technologies are used, we will handle information in accordance with applicable law and the choices available to you.

If you purchase a subscription or paid service, payment information may be processed by third-party payment providers.

TFW may receive limited payment-related information, such as:

• •Transaction amount
• •Transaction date
• •Payment status
• •Subscription information
• •Payment method type
• •Limited payment identifiers

We generally do not store complete payment card details on our own systems where payment processing is handled by a third-party payment provider.
Payment providers may process your information under their own privacy policies and terms.

TFW may communicate with you through email, SMS, telephone, in-app notifications, or other communication methods.

These communications may relate to:

• •Account activity
• •Counseling or coaching appointments
• •Service updates
• •Payments and subscriptions
• •Security notices
• •Customer support
• •Important changes to our Services

Where permitted by law, we may also send promotional or informational communications.
You may opt out of marketing communications by using the unsubscribe option provided in the communication or by contacting us.

You may continue to receive essential service-related communications even after opting out of marketing communications.

Where TFW facilitates online or virtual counseling or coaching sessions, certain technical information may be processed to enable the session.

Depending on the technology used, this may include:

• •Participant name
• •Session date and time
• •Connection information
• •Device and browser information
• •Audio or video connection data
• •Technical logs

TFW will not record counseling or coaching sessions unless this is clearly communicated to the relevant participants and appropriate consent or other lawful basis has been obtained.

If session recording is introduced as a feature in the future, TFW will provide appropriate notice regarding recording, storage, access, and retention.

TFW may use technology, including artificial intelligence or automated tools, to support certain administrative, operational, educational, or platform functions.
Where such technologies are used, TFW will take reasonable steps to protect personal information and limit access to information to what is necessary for the relevant purpose.

TFW does not use automated technology as a substitute for professional judgment where professional counseling or coaching judgment is required.

Where a specific TFW feature uses AI to interact with, analyze, summarize, or generate content based on information you provide, we will provide appropriate notice where required by applicable law.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• •Provide Services
• •Maintain accounts and records
• •Meet contractual obligations
• •Comply with legal, regulatory, or professional requirements
• •Resolve disputes
• •Enforce agreements
• •Protect our legitimate business interests
• •Maintain security and audit records

Retention periods may vary depending on the type and sensitivity of the information.
Information that is no longer required may be securely deleted, anonymized, or otherwise disposed of in accordance with applicable requirements.

TFW takes reasonable technical, administrative, and organizational measures designed to protect personal information against:

• •Unauthorized access
• •Unauthorized disclosure
• •Loss
• •Misuse
• •Alteration
• •Destruction

Security measures may include access controls, authentication mechanisms, encryption where appropriate, secure infrastructure, monitoring, backups, and internal security procedures.

However, no internet-based system can be guaranteed to be completely secure. We therefore cannot guarantee absolute security of information transmitted through the internet.

You are responsible for keeping your account credentials confidential and should notify us promptly if you believe your account has been accessed without authorization.

TFW recognizes the importance of protecting information relating to an individual's health and wellbeing.
Where TFW is subject to the U.S. Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations, TFW will take appropriate measures to comply with the requirements applicable to its role and activities.

This may include implementing appropriate administrative, physical, and technical safeguards for protected health information where HIPAA applies.

Where TFW acts as a service provider to a HIPAA-covered entity or business associate, TFW may enter into appropriate contractual arrangements, including a Business Associate Agreement (BAA), where required.
It is important to note that HIPAA does not apply to every organization that handles health-related information.
Whether HIPAA applies to TFW, a counselor, coach, healthcare provider, or particular service depends on the nature of the entity and the services being provided.

Accordingly, TFW does not represent that every service, interaction, counselor, coach, or third-party service available through the platform is independently subject to HIPAA.

Where HIPAA does not apply, TFW will continue to protect personal information in accordance with applicable privacy laws, contractual obligations, professional standards, and this Privacy Policy.

Where applicable, TFW is committed to handling personal information in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Where GDPR applies, TFW will take appropriate measures regarding:

• •Lawful, fair, and transparent processing
• •Purpose limitation
• •Data minimization
• •Accuracy
• •Storage limitation
• •Security and confidentiality
• •Accountability

Where applicable, individuals may exercise rights provided under the GDPR, including rights relating to access, correction, deletion, restriction of processing, objection, data portability, and withdrawal of consent.

Certain information associated with counseling, mental health, or wellbeing may constitute special category data under GDPR. Where such information is processed and GDPR applies, TFW will identify and rely on an appropriate legal basis and applicable condition for processing such information.

Where required, TFW will also maintain appropriate records, contracts, safeguards, data processing arrangements, and procedures relating to personal data protection.

TFW and our service providers may operate in different countries. As a result, your information may be transferred to, stored in, or processed in a country other than the country in which you live.

Where applicable law requires safeguards for international transfers, we will take reasonable steps to implement appropriate safeguards.

Where GDPR applies, such safeguards may include an adequacy decision, Standard Contractual Clauses, or another lawful transfer mechanism recognized under applicable law.

By using the Services, you acknowledge that your information may be processed in jurisdictions other than your own, subject to applicable legal requirements.

TFW recognizes the importance of protecting children's privacy.

Our Services are not intended for children below the minimum age permitted under applicable law to independently use such Services.

Where TFW provides services involving children or minors, such services may require the involvement, consent, or authorization of a parent or legal guardian, depending on the child's age, the nature of the service, and applicable law.
We do not knowingly collect personal information from children in circumstances where such collection is prohibited by law.

If you believe that a child has provided personal information to TFW without appropriate authorization, please contact us so that we can review the situation and take appropriate action.

TFW is committed to making its website and digital Services accessible and usable by as many people as reasonably possible, including individuals with disabilities.

We aim to design and maintain our digital experiences in a manner that supports accessibility and aligns, where reasonably practicable, with recognized accessibility standards such as the Web Content Accessibility Guidelines (WCAG).

Our accessibility efforts may include:

• •Providing clear and consistent navigation
• •Using appropriate headings and page structures
• •Supporting keyboard navigation where reasonably practicable
• •Providing alternative text for meaningful images
• •Maintaining sufficient text readability and contrast
• •Supporting assistive technologies where reasonably practicable
• •Designing forms and interactive elements with accessibility in mind
• •Continuously reviewing and improving the accessibility of our digital Services

Accessibility is an ongoing process, and despite our efforts, some areas of the website or platform may not yet be fully accessible.

If you encounter an accessibility barrier or require assistance accessing any TFW Service, please contact us at:
Email: [info@faithworks.org]

When contacting us, please describe the page, feature, or content you are having difficulty accessing and, where possible, the nature of the accessibility issue. We will make reasonable efforts to assist you and address accessibility concerns.

TFW provides access to counseling, coaching, educational resources, assessments, and personal development services.
However, not all TFW Services constitute clinical or medical care.

Unless expressly stated otherwise, information, content, assessments, coaching, educational materials, and other resources provided through TFW are not intended to:

• •Diagnose a medical or mental health condition
• •Replace medical or psychiatric care
• •Replace treatment provided by a licensed healthcare professional
• •Prescribe medication
• •Provide emergency medical or psychiatric services
• •Guarantee a particular therapeutic or personal outcome

Counseling and coaching are distinct services and may differ in scope, purpose, training requirements, professional regulation, and applicable standards depending on the jurisdiction.

Where TFW connects you with a counselor or other professional, you are responsible for reviewing the professional's qualifications, scope of practice, and applicable licensing or registration where relevant.

TFW does not guarantee that counseling, coaching, assessments, or other Services will produce a particular result.

TFW is not an emergency or crisis-response service.

Do not rely on TFW, the website, messaging features, counselors, coaches, assessments, or other platform features for immediate assistance in an emergency.

If you believe that you or another person is in immediate danger, experiencing a medical emergency, or at risk of serious harm, contact your local emergency services or seek immediate assistance from an appropriate qualified healthcare or mental health professional.

Depending on where you live and applicable law, you may have rights relating to your personal information.

These may include the right to:

• •Request access to personal information we hold about you
• •Request correction of inaccurate or incomplete information
• •Request deletion of personal information
• •Request restriction of certain processing
• •Object to certain processing
• •Withdraw consent where processing is based on consent
• •Request portability of certain information
• •Opt out of certain marketing communications
• •Lodge a complaint with an applicable privacy or data protection authority

Some rights may be subject to legal exceptions or limitations.

To exercise your rights, please contact us using the details provided below. We may need to verify your identity before completing certain requests.

You may request deletion of your TFW account by contacting us or using the account-management functionality made available through the platform, where applicable.

Deleting your account does not necessarily mean that all information will be immediately deleted. Certain information may need to be retained where required by law, professional obligations, legitimate business requirements, dispute resolution, security purposes, or other lawful grounds.

Where information is retained, we will continue to protect it in accordance with this Privacy Policy.

Our website or Services may contain links to third-party websites, applications, resources, or services.
TFW is not responsible for the privacy practices, security, or content of third-party services.

We encourage you to review the privacy policies of third parties before providing them with personal information.

TFW may maintain social media pages or provide features that allow users to interact with content.

Information that you voluntarily post in publicly accessible areas may be visible to others and may not be protected in the same way as information submitted privately to TFW.

Please exercise caution when sharing personal or sensitive information in public forums, comments, testimonials, or other publicly accessible areas.

If you voluntarily provide a testimonial, review, photograph, story, or other content for publication, TFW may use that content in accordance with the permission or consent you provide.

We will not publish sensitive personal information as a testimonial without an appropriate legal basis or permission where required.

You should avoid including confidential counseling information or information about another person in content you submit for publication without appropriate authorization.

If TFW becomes aware of a security incident involving personal information, we will assess the incident and take reasonable steps to contain, investigate, and remediate it.

Where required by applicable law, we will notify affected individuals and/or relevant authorities within the legally required timeframe.

Certain counseling or professional records may be subject to retention requirements imposed by applicable law, professional standards, licensing bodies, contractual obligations, or other regulatory requirements.

Where such requirements apply, TFW and/or the relevant professional may retain information for the required period even where you request deletion.

The applicable retention period may therefore differ depending on the type of information, the service provided, the professional involved, and the jurisdiction concerned.

We may update this Privacy Policy from time to time to reflect changes in:

• •Our Services
• •Technology
• •Legal or regulatory requirements
• •Business practices
• •Security practices

When we make material changes, we may provide notice through the website, platform, email, or other appropriate means.

The updated Privacy Policy will be posted with a revised “Last Updated” date.

Your continued use of the Services after an updated Privacy Policy becomes effective constitutes acknowledgment of the updated policy, to the extent permitted by law.

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your information is handled, please contact us:

TFW (The FaithWorks)

Privacy Email: [info@thefaithworks.org]

Website: [www.thefaithworks.org]

Address: FAITH WORKS GLOBAL LLC
105 OLD FARM ROAD SOUTH
NEW HYDE PARK, NY 11040

For privacy-related requests, please include sufficient information for us to understand and respond to your request. We may contact you to verify your identity where necessary.

This Privacy Policy shall be interpreted in accordance with the laws applicable to TFW and the jurisdiction in which TFW operates, subject to any mandatory privacy rights or protections applicable to you under the laws of your jurisdiction.

Where required, applicable local privacy and data protection laws will take precedence over any inconsistent provision of this Privacy Policy.

TFW is committed to maintaining responsible privacy and data protection practices as the platform evolves.
Because privacy obligations may differ depending on the user's location, the nature of the service, the type of information collected, the professional providing the service, and the technologies used, TFW may maintain additional privacy notices, consent forms, professional confidentiality policies, cookie notices, or service-specific disclosures where appropriate.

This Privacy Policy should be read together with TFW's Terms of Use, Counseling and Coaching Terms, Cookie Policy, and other applicable policies and agreements.

By using TFW, you acknowledge that you have read and understood this Privacy Policy and understand how TFW may collect, use, protect, and disclose your information as described above.