Sherpa Privacy PolicyEffective Date: 12/19/2024
Version: 1.0.0Important Note: This Privacy Policy provides detailed information about how MYY LLC (“Sherpa,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards your personal data. It is intended for users aged 13 and above unless otherwise stipulated by an Institution that provides access to Sherpa. By using our app and services, you agree to the practices described in this policy. If you do not agree, please refrain from using the app.1. About MYY LLC and Contact InformationMYY LLC is the creator and provider of the Sherpa app and associated services. MYY LLC’s registered address is:MYY LLC
30 N Gould St
Sheridan, WY 82801
USASherpa is developed to provide users with guidance, insights, and tools to improve their personal and professional well-being. While Sherpa may offer support and helpful suggestions, it does not deliver medical advice. Sherpa services may be available in English and other languages based on our continuous improvements. Certain premium or specialized features may be accessible only via Institutions (e.g., employers, healthcare providers).Data Controller vs. Data Processor:When we determine why and how personal information is processed for direct-to-consumer users, we act as the “Data Controller.”When we process data on behalf of an Institution that offers Sherpa to its members or beneficiaries, we act as a “Data Processor.”If you have questions, comments, requests, or concerns about this Privacy Policy, please contact us at:
Email: support@myybrands.com2. Information We Collect and How We Use ItWe prioritize minimal data collection to safeguard your privacy. You choose what personal information to share. By limiting the data we collect, we reduce risks and enhance privacy protections.Types of Information Collected:A. Information You Provide Directly:Basic Personal Details: Name, email address, phone number, age range, preferred pronouns, or other demographic data you voluntarily share.Conversation Data: All text-based inputs within the Sherpa app, including messages you type, goals you set, well-being check-ins, or any notes you store.Feedback and Surveys: Responses to questionnaires, polls, or evaluation forms that help us improve our services.Correspondence Data: If you contact us via email or other support channels, we may collect your email address, name, and any details you provide in your message.B. Information Provided by Institutions (if applicable):
If you access Sherpa through your Institution (e.g., employer, healthcare provider), they may share limited information such as user identifiers or contact details necessary to enable access.C. Automatically Collected Information:App Usage Data: Metrics on how you interact with Sherpa, including screens viewed, features used, settings adjusted, and notification interactions.Device Data: Information about your device type, operating system, language settings, time zone, and unique device identifiers provided by app stores.Cookies & Similar Technologies: We use essential cookies and similar technologies to ensure the app works properly and to understand user engagement. We do not use these for marketing without your consent.D. Third-Party Integrations and Automated Processing:OpenAI Integration: We partner with OpenAI to enhance the Sherpa AI Coach functionalities. Your conversation data may be processed by OpenAI’s language models to provide helpful, context-aware responses.Hosting on AWS: Your data is stored and processed securely using Amazon Web Services (AWS) infrastructure.3. Legal Bases for Processing Your InformationWe adhere to applicable data protection laws and handle your personal data under one or more of these legal grounds:Consent: When you opt in or agree to specific data uses.Contractual Necessity: To provide the services you expect and fulfill our contractual obligations.Legitimate Interests: To ensure the stability, security, and improvement of Sherpa, to detect fraud, and to enhance user experience without unduly affecting your rights.Legal Obligations: To comply with applicable laws, regulations, and legal processes.4. How We Use Your InformationA. Providing and Maintaining Services:
We use your data to personalize the Sherpa experience, tailor suggestions, track progress, and ensure proper functionality. For Institution-linked services, we may use unique identifiers to confirm eligibility and align resources appropriately.B. Insights and Guidance:
Sherpa may assess your input to offer relevant strategies, tools, or exercises. This includes interpreting mood, tracking certain patterns, and proposing general well-being techniques or productivity recommendations. Sherpa does not provide medical advice. For any severe concerns, we encourage you to consult a licensed medical professional.C. AI Processing and Content Generation:
We utilize AI models (including from OpenAI) to understand user inputs, generate suitable replies, and improve conversation quality. We ensure that these processes are conducted securely and with privacy safeguards in place.D. Research, Analytics, and Reporting:
We may anonymize or pseudonymize your data for internal research, product improvements, quality checks, and compliance reporting. Aggregated insights help us understand usage trends, ensure our service’s safety, and evaluate overall effectiveness.E. Communication and Support:
Correspondence data is used to respond to your inquiries, solve technical issues, and inform you about updates or changes to our policies and terms.F. Marketing and Promotions (Optional):
We may run campaigns or promotions. Participation in these is voluntary. If you do so, we might collect your name and contact details. Your data from marketing events is not connected to your main Sherpa account.5. Data Sharing and DisclosureA. Service Providers:
We work with trusted third-party vendors who help us run Sherpa, such as analytics providers, content delivery networks, and data storage services (AWS). These providers are contractually obligated to protect your data and adhere to our privacy standards.B. Institutions (if applicable):
For users who access Sherpa through an Institution, we may share de-identified or aggregated usage data reports with that Institution to help them understand engagement and effectiveness of the service. In some emergency or safety situations, and as required by applicable agreements, we may share necessary details with the Institution’s authorized representatives to ensure user well-being.C. Legal and Regulatory:
We may share your personal data to comply with legal obligations, respond to lawful requests by public authorities, or protect our rights, safety, or property as well as those of our users or the public.D. Business Transactions:
In the event of a merger, acquisition, restructuring, or sale of assets, user data may be transferred to another entity with similar privacy commitments. We will inform you by posting a notice within the app or on our website and/or by other appropriate means.6. International Data TransfersWe may process and store data in jurisdictions different from your residence. If we transfer your personal data across borders, we employ appropriate safeguards, such as contractual clauses and technical measures, ensuring your information is protected in line with this Privacy Policy and applicable laws.7. Data Retention and DeletionA. Retention Period:
We store personal data only as long as necessary to provide services, meet legal or contractual requirements, or as otherwise outlined in this Privacy Policy. If no specific retention period is legally mandated, we may retain your data for up to 10 years after your last app interaction.B. User-Controlled Deletion:
You have the option to “reset my data” within the app’s settings, which permanently deletes your personal conversation history, identifiers, and related information from our active systems. Once deleted, these details cannot be recovered. Note that backup or archival copies may remain for a limited time as required by our security and compliance obligations, but we will not use these backups for any active processing.8. Data Security MeasuresWe apply physical, technical, and administrative safeguards to protect your personal data. This includes:Encryption: Data in transit and at rest is safeguarded with encryption.Access Controls: Only authorized personnel with a valid business need and appropriate credentials can access your data.Regular Audits and Testing: We frequently test our systems and engage external experts to review compliance and security.Training: Our team members receive regular training on privacy best practices and secure data handling.No security method is infallible, but we continuously work to maintain the highest possible standards. You can help by securing your device, using strong passwords, and avoiding sharing sensitive data in insecure environments.9. Children’s PrivacySherpa is intended for individuals aged 13 and above. If your Institution’s terms differ, we follow their guidelines. We do not knowingly collect personal data from children under 13. If we discover that we have inadvertently collected such data, we will delete it. Parents or guardians who believe their child has provided personal data without proper consent should contact us at support@myybrands.com.10. User Rights and ChoicesDepending on your jurisdiction, you may have certain rights regarding your personal data:Access: Request information on how we process your data and obtain a copy of your personal details.Rectification: Correct inaccuracies or update incomplete data.Deletion: Erase your personal data when it’s no longer needed, or where legally required.Restriction/Objection: Ask us to restrict certain processing activities or object to data uses.Portability: Request a transferable, machine-readable copy of certain personal information.Withdraw Consent: If you previously consented to processing, you can opt out anytime.Marketing Opt-Out: Unsubscribe from marketing communications via a link in the communication or by contacting us.To exercise these rights, please email support@myybrands.com. We may verify your identity before fulfilling requests. We strive to respond within legally mandated timeframes.If we are unable to resolve your concerns, you may have the right to contact a local data protection authority.11. Cookies and Similar TechnologiesWe use essential cookies to ensure our app and website function correctly. These cookies do not capture sensitive personal details. We also use analytical cookies to understand usage patterns and improve our services. For details about cookies and how to disable them, check your device or browser settings. Note that disabling cookies may limit certain functionalities.12. Third-Party Websites and Social MediaSherpa may contain links to external resources or allow optional connections to social media platforms. We are not responsible for the privacy practices of these external sites. Review their respective privacy policies before sharing any personal data.13. Changes to this Privacy PolicyWe may update this policy to reflect changes in our practices, legal requirements, or service offerings. If we make significant modifications, we will notify you in-app or through other appropriate channels. Your continued use of Sherpa after these updates signifies acceptance of the revised policy.14. Contact Us and ComplaintsFor privacy-related questions, concerns, or requests:Email: support@myybrands.comWe will acknowledge your communication within a reasonable timeframe. If you are not satisfied with how we address your complaint, you may contact a relevant data protection authority or seek other legal remedies.15. Change Logv1.0.0 | 12/19/2024Initial comprehensive release of the Sherpa Privacy Policy.Important: By using Sherpa, you agree to this Privacy Policy and our Terms of Use. Your trust is important to us. We commit to continually improving our privacy and security practices to better protect your data and ensure a beneficial and respectful user experience.