Companion 360 Privacy Policy
Last Updated: July 2025
Introduction
At ZANEC, as the service provider for Companion 360, we value your privacy and take the protection of your personal data seriously. Companion 360 app (iOS & Android) (the "App") is operated by ZANEC as a Digital Therapeutic as a Service (DTaaS), incorporating evidence-based Couples Behavioral Therapy (CBT) and Family-Based Interventions (FBI) to support families and loved ones in addiction recovery journeys. This Privacy Policy is intended to inform you about how we handle and protect your personal data when you use the App.
If a user registers for Companion 360 products and services, ZANEC will act as the data controller for any personal data collected, with licensed clinical service providers acting as data processors for therapeutic services.
Please review the Terms of Use for Companion 360 when you sign up for the app.
This Privacy Policy aims to provide details on how personal data is collected and processed when you interact with the Companion 360 app, including all features within the App that support families through evidence-based therapeutic interventions.
Children's Privacy
The Companion 360 app is not intended for or targeted at children under 18; we do not knowingly or intentionally collect information about children under 18. If you believe we have collected information about a child under 18, please contact us at recovery360@cyberliver.com so we may delete the information.
What Personal Data We Collect
Account Registration Data
When you sign up for Companion 360 from the App Store or Play Store, we will request that you provide personal data about yourself including:
- First name and last name
- Date of birth
- Email address
- Gender
- Relationship to person in recovery (spouse, parent, sibling, friend, etc.)
- Unique password
Therapeutic Data
As part of our evidence-based Couples Behavioral Therapy and Family-Based Interventions, you may provide:
- Relationship status and dynamics information
- Communication patterns and challenges
- Family history and recovery support experiences
- Therapeutic goals and progress tracking
- Stress levels and coping strategies
- Behavioral activation and engagement metrics
- Family therapy session notes and feedback
Optional Data
- Profile photo (can be uploaded and removed at any time)
- Contact information for other family members or support network (with consent)
- Location data for finding local therapeutic resources
- Notification preferences
Technical Data
We may collect information your device sends whenever you use the App (Log Data):
- Device Internet Protocol (IP) address
- Device model and operating system version
- App usage patterns and session duration
- Pages visited within the App
- Time and date of visits
- Crash reports and error logs
How We Use Your Personal Data
Therapeutic Services
- Deliver evidence-based Couples Behavioral Therapy modules
- Provide Family-Based Intervention tools and resources
- Track therapeutic progress and milestone achievements
- Coordinate with professional therapists and counselors
- Provide personalized therapeutic content and recommendations
App Functionality
- Create and maintain your account
- Provide customer support and technical assistance
- Send therapeutic reminders and motivational messages
- Facilitate communication with professional support services
- Improve app performance and user experience
Analytics and Research
- Analyze usage patterns to improve therapeutic interventions
- Conduct research on family-based recovery support effectiveness
- Generate anonymized insights for clinical research
- Improve evidence-based therapeutic approaches
Legal Basis for Processing
Our legal basis for collecting and using your personal data depends on the specific context:
- Consent: When you voluntarily provide therapeutic data for CBT and FBI services
- Contract Performance: To provide the Companion 360 therapeutic services
- Legitimate Interests: To improve our services and ensure app functionality
- Legal Obligation: To comply with healthcare regulations and data protection laws
Data Sharing and Disclosure
We Never Sell Your Data
We will never sell your personal data to third parties.
Service Providers
We may share your data with:
- Licensed therapists and counselors providing clinical services
- Technical service providers for app functionality
- Research collaborators for clinical studies (with anonymized data)
- Professional advisers including lawyers and auditors
- Regulators and authorities when legally required
Family and Support Network
With your explicit consent, we may share relevant therapeutic progress and resources with:
- Family members participating in Family-Based Interventions
- Partners engaged in Couples Behavioral Therapy
- Designated support persons in your recovery support network
Data Security
We implement comprehensive security measures to protect your personal data:
- Encryption of data in transit and at rest
- Secure server infrastructure with access controls
- Regular security audits and penetration testing
- Staff training on data protection and confidentiality
- Incident response procedures for data breaches
Your Rights
You have the following data protection rights:
- Access: Request copies of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your personal data
- Portability: Receive your data in a structured, machine-readable format
- Restriction: Limit how we process your data
- Objection: Object to processing based on legitimate interests
- Withdraw Consent: Remove consent for data processing at any time
International Data Transfers
If we transfer your data outside the European Economic Area (EEA), we ensure adequate protection through:
- European Commission-approved standard contractual clauses
- Adequacy decisions for specific countries
- Binding corporate rules for intra-group transfers
- Other appropriate legal safeguards
Data Retention
We retain your personal data only as long as necessary for:
- Providing therapeutic services and support
- Complying with legal and regulatory requirements
- Resolving disputes and enforcing agreements
- Conducting legitimate research with anonymized data
Third-Party Links and Services
The App may include links to third-party websites, social media features, and integrated services. This Privacy Policy does not apply to these external services. We encourage you to review the privacy policies of any third-party services you access through our App.
Marketing Communications
We may send you therapeutic reminders, progress updates, and educational content related to recovery support. You can opt out of marketing communications at any time by:
Updates to This Privacy Policy
We keep this Privacy Policy under regular review and will post any changes on this page. If changes are significant, we will provide more prominent notice through the App or via email. We encourage you to review this Privacy Policy periodically.