Privacy Policy

1 Introduction and Scope

The BRIGHTHOPE App is owned and operated by 73Tec LLC (“BRIGHTHOPE,” “Company,” “we,” “us,” or “our”), which respects the privacy of the individuals who use the BRIGHTHOPE App (the “App”), whether as a Counselor (a person who provides Christian pastoral counseling) or a Counselee (a person who receives it). This Privacy Policy describes the categories of information we collect, the limited purposes for which we use it, how and when it is shared, your choices and rights, and how we protect it.

This Privacy Policy applies to information collected through the App and any related websites, features, or services that link to it (collectively, the “Services”). It does not apply to information collected by any third party, including any Counselor, Counselee, or payment processor, except as expressly described herein. Your use of the Services is also governed by the BRIGHTHOPE Terms & Conditions, into which this Privacy Policy is incorporated by reference and which this Privacy Policy likewise incorporates; in the event of a conflict on a privacy matter, this Privacy Policy controls.

2 Who We Are; Platform-Only Role

BRIGHTHOPE (73Tec LLC) is the owner and operator of the App, with its principal place of business in [City, County, West Virginia], and is the party responsible for the information practices described in this Policy. BRIGHTHOPE is only a platform that a Counselor and a Counselee use to connect for Christ-centered spiritual guidance and Christian pastoral counseling. BRIGHTHOPE does not provide the counseling itself, does not participate in or direct the counseling relationship, and does not control what is discussed. Counselors are independent contractors and not employees or agents of BRIGHTHOPE. To the extent a Counselor independently collects, stores, or uses information about a Counselee, that Counselor — and not BRIGHTHOPE — is responsible for such information and is bound by the confidentiality obligations in Section 9.

3 Anonymity and Your Code Name Privacy feature

When a Counselee registers, the App automatically generates a unique alphanumeric code that represents the Counselee on the platform. A Counselee may use the Services under that code name and remain anonymous to the Counselor, or may choose, entirely at the Counselee’s own discretion, to disclose their real name or other identifying details to a Counselor. The choice belongs to the Counselee alone, and BRIGHTHOPE does not require a Counselee to reveal their real name to a Counselor in order to receive pastoral counseling.

3.1 Scope and Limits of Anonymity

Your code name keeps you anonymous as between you and your Counselor. It does not make you anonymous to BRIGHTHOPE. Because registration requires identity and age verification, BRIGHTHOPE collects your date of birth and a government-issued photo identification and therefore holds your real identity, even when you use only a code name with your Counselor; our payment processor likewise receives your billing details. As a result, BRIGHTHOPE and our payment processor may hold information that can identify you (such as your name, date of birth, government ID, email address, device and log data, and billing details) even when you remain anonymous to your Counselor. In addition, your identity may become known to your Counselor if (a) you voluntarily reveal identifying details — by speaking, appearing on video, or sharing identifying facts; or (b) disclosure is required by law, as described in Section 13. You control how much you reveal to your Counselor.

4 Choosing Your Counselor; Your Assumption of Risk

You choose your own Counselor. BRIGHTHOPE does not assign, match, or select a Counselor for any Counselee. Counselees are free to browse available Counselors and to choose a Counselor of their own choice, and the decision of which Counselor to engage, and whether to continue, rests entirely with the Counselee.

You assume the risk of what you share. A Counselee who chooses to share their personal circumstances, struggles, or issues with a Counselor does so voluntarily and at their own risk. BRIGHTHOPE does not screen the substance of what is shared, cannot guarantee any outcome, and is not responsible for a Counselor’s conduct, advice, or use of information disclosed to them. You should share only what you are comfortable sharing and may use the anonymity feature in Section 3 to limit the personal information you reveal.

5 Information We Collect

5.1 Counselee Information You Provide

• Registration and identity information — the information needed to create and administer an account and to verify your identity and age, including your email address, a username or the App-generated code name, a password, your date of birth, and a government-issued photo identification used to confirm that you are at least 18 years old and that you are who you say you are. You provide this identity information to BRIGHTHOPE for verification; you may still remain anonymous to your Counselor by using your code name (see Section 3).
• Ratings, reviews, and support correspondence — content you voluntarily submit about your experience or when you contact us.
• Acceptance and signature records — your electronic signature, which you provide either by typing your full legal name or by uploading an image of your own signature, together with the date, timestamp, IP address, and unique agreement identifier recorded when you accept the Terms & Conditions or this Privacy Policy. Any uploaded signature image is stored securely and used only as evidence of your agreement.

5.2 Counselor Information You Provide

• Registration and identity information — your email address, a password, your date of birth, and a government-issued photo identification, used to verify your identity and that you are at least 21 years old.
• Credentialing and education information — the documents of your education and credentials submitted to establish eligibility, such as evidence of ordination, licensure, or credentialing; church or denominational attestation letters; and certificates or degrees in Christian or pastoral counseling. You consent to our verifying this documentation with the issuing church, organization, or institution.
• Background-check information — information collected and processed by us or our qualified third-party screening provider to conduct the background check required before Counselor approval (Section C2.1 of the Terms), including criminal-history and sex-offender-registry results and related identity verification. This information is used only to evaluate eligibility and safety and is handled in accordance with the federal Fair Credit Reporting Act where applicable.
• Payout and tax information — the banking or payout-account details and taxpayer information needed to pay you and to meet tax-reporting obligations (for example, to issue IRS Form 1099-NEC or 1099-K).

5.3 Counseling Communications

The content of counseling communications conducted through the App (video, audio, and text chat) is exchanged between the participating Counselor and Counselee and is encrypted as described in Section 8. BRIGHTHOPE does not access, monitor, review, or use the content of these communications except as expressly described in Sections 7, 8, and 13.

5.4 Information Collected Automatically

We and our service providers collect limited technical and log information necessary to operate and secure the Services — such as device type, operating system, app version, access times, session metadata (for example, connection quality and duration), crash and diagnostic data, and IP address — together with information collected through the technologies described in Section 14. We do not collect precise geolocation unless you separately consent, and we do not use facial recognition or collect biometric identifiers from video sessions.

6 Religious and Sensitive Information

Because BRIGHTHOPE is a Christian pastoral counseling platform, the information you choose to share may reveal religious or spiritual beliefs and may be personal and sensitive. By using the Services and voluntarily providing such information, you consent to its collection, use, and disclosure for the limited purposes described in this Policy. You should provide only the information you are comfortable sharing, and you may use the anonymity feature in Section 3.

7 How We Use Information — Limited Use

To “provide the Services,” we use information to: (a) create, authenticate, and administer accounts, including by verifying your identity and age (18+) using your date of birth and government-issued photo identification, and by means of the App-generated code name; (b) enable a Counselee to connect with a Counselor of the Counselee’s own choosing and to conduct scheduled 30-minute sessions; (c) process payments, payouts, refunds, cancellations, and related transactions through a secure third-party payment processor; (d) provide customer support and respond to your requests; (e) operate, maintain, secure, and improve the Services and prevent fraud and abuse; (f) enforce the Terms & Conditions, including our session-conduct, social-media, and advertising requirements; and (g) comply with applicable law and legal process, including the mandatory reporting obligations described in Section 13.

We do not: sell or rent personal information; share personal information for cross-context behavioral or targeted advertising; use the content of counseling communications for any purpose other than transmitting them between the participating users and the narrow purposes in clauses (e)–(g) above; or build marketing or advertising profiles of Counselees. Counselor information is additionally used to verify credentials and to administer the Counselor’s account, payouts, and tax reporting.

8 Encryption and Security of Communications

Counseling communications conducted through the App — including video, audio, and text-chat communications — are encrypted in transit (for example, using Transport Layer Security) and, to the extent stored by the Services, encrypted at rest using industry-standard methods. Encryption helps protect the confidentiality of your communications against unauthorized access.

BRIGHTHOPE does not access, monitor, or review the content of counseling communications except where reasonably necessary to operate or secure the Services, to investigate a documented technical, security, or safety issue, or to comply with applicable law or legal process as described in this Policy (including Section 13). No method of transmission or storage is completely secure, and BRIGHTHOPE cannot guarantee absolute security. This Section does not apply to communications that users choose to conduct outside the App (see Section 11).

9 Counselor Confidentiality Obligations

A Counselor must not share any information of a Counselee with anyone. Each Counselor is required to keep strictly confidential all information about a Counselee that the Counselor learns through the App — including the Counselee’s identity (whether disclosed by real name or known only by code name), the fact of the counseling relationship, and the content of any communication — and must not disclose, publish, sell, or otherwise share that information with any third party.

The only exceptions are disclosures required by law (for example, the mandatory reporting of suspected abuse or neglect of a child or vulnerable adult under W. Va. Code § 49-2-803, or where there is a serious and imminent risk of harm) and any disclosure the Counselee has expressly authorized in writing. A Counselor must not record, screenshot, or share any session communication without express written permission (see Section 12). A Counselor’s breach of these obligations is a material breach of the Terms & Conditions for which the Counselor is solely responsible, and BRIGHTHOPE is not responsible or accountable for a Counselor’s misuse or unauthorized disclosure of Counselee information. These obligations are also set out in the Terms & Conditions (§8 and §C11), and the confidentiality a Counselee can expect, together with its limits, is described in §E7 of the Terms.

10 How We Share Information

BRIGHTHOPE shares information only as described below, consistent with the limited-use principle in Section 7:

10.1 Between a Counselor and a Counselee

To enable a session the Counselee has chosen to book, the App shares with the chosen Counselor the information necessary to conduct it — which, if the Counselee elects anonymity, may be limited to the Counselee’s code name and scheduling details. Any further identifying information is shared only if the Counselee chooses to reveal it.

10.2 Secure Payment Processor

Payment information is shared with our secure third-party payment processor to process transactions and, for Counselors, payouts, as described in Section 16.

10.3 Essential Service Providers

We share limited information with vendors who provide infrastructure necessary to operate and secure the Services (such as cloud hosting, encrypted communications infrastructure, analytics and crash diagnostics, and security and fraud-prevention tools). These providers are bound by contract to use information only as necessary to provide services to us and consistent with this Policy.

10.4 Identity-Verification and Background-Screening Providers (Counselors)

For Counselor applicants, we share the information needed to verify identity and to conduct the background check required before approval (Section C2.1 of the Terms) with a qualified third-party screening provider. That provider processes the information to perform the check and return results to us, under its own terms and consistent with the federal Fair Credit Reporting Act where applicable.

10.5 Legal, Safety, and Mandatory Reporting

We may disclose information when we believe in good faith that doing so is necessary to comply with a subpoena, court order, search warrant, law, or other legal process; to respond to a lawful request by public authorities; to protect the rights, property, or safety of BRIGHTHOPE, our users, or others; or to fulfill mandatory reporting obligations, including reporting of suspected child abuse or neglect under W. Va. Code § 49-2-803.

10.6 Business Transfers; With Your Consent

Information may be transferred as part of a merger, acquisition, financing, reorganization, or sale of assets, subject to this Policy, and may otherwise be shared with your consent or at your direction. BRIGHTHOPE does not sell personal information and does not share it for cross-context behavioral advertising.

11 Communications Between Users; Off-Platform Activity

BRIGHTHOPE does not monitor, supervise, control, or take part in the substance of communications between users. We do not control, and this Policy does not govern, any information that users exchange with one another outside the App — for example, by personal phone, email, text message, social media, or in person — whether or not that communication began through the App, and the encryption described in Section 8 does not extend to off-platform communications. Any decision to communicate off-platform, or to share personal information with another user directly, is made at your own risk and outside our knowledge and control. We encourage users to keep their interactions within the App.

12 Session Recording and Content Storage

Users are prohibited from recording, screenshotting, or sharing any session communication without express written permission, as set out in the Terms & Conditions. BRIGHTHOPE does not itself record counseling sessions for content purposes.

Storage of session content. The retention of any counseling communication content is governed by Section 18. Account, payment, and acceptance records are retained for the longer periods described there; the content of counseling communications, by contrast, is retained only for the limited period stated in Section 18 and is then deleted or de-identified.

13 Not Healthcare; No HIPAA; No Clergy-Penitent Privilege; Mandatory Reporting

Not a healthcare provider; not HIPAA. The Services are spiritual and pastoral in nature and are not clinical, medical, or psychiatric services. BRIGHTHOPE is not a healthcare provider and is not a “covered entity” or “business associate” under the Health Insurance Portability and Accountability Act (HIPAA); accordingly, communications through the App are not “protected health information” under HIPAA.

No clinical information; no clinical services. BRIGHTHOPE does not permit any Counselor to gather, request, collect, record, store, or use any clinical information through the App or in connection with the Services. “Clinical information” includes, without limitation, medical or psychiatric diagnoses; mental-health or medical history; medication, prescription, or treatment records; clinical assessments, test results, or symptom evaluations; and any protected health information. This prohibition applies to every Counselor, including any Counselor who is separately a licensed clinical, medical, mental-health, or other healthcare professional, and no Counselor may provide clinical, medical, psychological, or psychiatric services through the App. A Counselor who is separately a licensed professional may conduct clinical practice only outside the App, on their own platforms and at their own responsibility; any such practice is not part of, and is not authorized by, the Services, and BRIGHTHOPE is not responsible for it. If a Counselor incidentally learns information that is clinical in nature, the Counselor remains bound by the confidentiality obligations in Section 9 and the scope-of-practice restrictions in the Terms & Conditions, and must not record, retain, or use it as clinical information.

No clergy-penitent privilege. As disclosed in the Terms & Conditions, pastoral counseling conducted through the App may not be protected by the clergy-penitent privilege under West Virginia law (W. Va. Code § 57-3-2), because the communication occurs through a third-party platform. You should not assume that communications through the App are legally privileged.

14 Cookies, Analytics, and Tracking Technologies

We and our service providers use cookies, software development kits (SDKs), and similar technologies to operate and secure the Services, remember your preferences, authenticate sessions, diagnose crashes, and understand and improve performance. We may use analytics and diagnostic tools ([e.g., Google Analytics for Firebase / other]) for these purposes. We do not use these technologies for cross-context behavioral or targeted advertising, and we do not use them to build advertising profiles of Counselees. To the extent any use of analytics technologies is treated as a “sale” or “sharing” of personal information under an applicable state privacy law, you may exercise the choices described in Sections 20 and 21. You may also control cookies through your browser or device settings; disabling certain technologies may affect functionality.

Do Not Track. Because there is no common industry standard for interpreting “Do Not Track” browser signals, the Services do not currently respond to them; we do, however, honor recognized opt-out preference signals to the extent required by applicable law.

15 Marketing; No Sale; No Targeted Advertising

BRIGHTHOPE does not advertise or promote individual Counselors and does not use Counselee information for marketing. We do not sell personal information, and we do not share personal information for cross-context behavioral or targeted advertising. Counselors are responsible for their own marketing, and any social media or advertising that references the App must align with the App’s policy that it is exclusively a Christian pastoral counseling platform, as required by the Terms & Conditions. If you interact with BRIGHTHOPE on a third-party social media platform, that platform’s own privacy practices apply. We may send you service-related communications (such as account, transaction, and security notices), which are not promotional; any non-essential informational messages will include a means to opt out.

16 Payment and Counselor Financial Data

Payments are processed by one or more secure third-party payment processors ([e.g., Stripe / PayPal]). When you provide payment-card or bank-account information, that information is collected and processed directly by the payment processor under its own terms and privacy policy, and BRIGHTHOPE does not store full payment-card numbers. We receive only the limited transaction information (such as confirmation of payment, amounts, any discount or coupon applied, and the status of payouts, refunds, and chargebacks) necessary to operate the Services and maintain records. For Counselors, we collect and use payout-account and taxpayer information solely to remit payouts and to meet tax-reporting obligations (for example, issuing IRS Form 1099-NEC or 1099-K).

Payment authorization and authentication. To book a session, a Counselee provides a valid payment method and completes the processor’s authentication (which may include card verification, CVV, and strong-customer-authentication or 3-D Secure steps) and authorizes charges for the Session Fee and the booking fee, as described in the Terms & Conditions (E4). Authentication and card data are handled by the secure third-party processor; BRIGHTHOPE receives and retains only the limited authorization and transaction records (such as an authorization or transaction identifier, date, timestamp, and payment status) needed to evidence the authorization and operate the Services.

17 Data Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, alteration, and destruction, including the encryption of counseling communications described in Section 8. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for the reasonable security of your own devices and networks, and you agree to notify us promptly of any unauthorized use of your account.

18 Data Retention

We retain information only for as long as reasonably necessary for the purpose for which it was collected, applying the following general categories:

• Counseling communication content — retained only for [Insert period — e.g., the duration of the session and up to [X] days thereafter], after which it is deleted or de-identified. [If BRIGHTHOPE does not store session content at all, state: “BRIGHTHOPE does not retain the content of counseling communications after a session ends.”]
• Account and registration records — retained while your account is active and for a reasonable period thereafter to administer the account, resolve disputes, and enforce our agreements.
• Identity-verification documents — your date of birth and government-issued photo identification (and, for Counselors, education and credentialing documents) are retained only as long as needed to verify identity, age, and eligibility and to meet legal and recordkeeping obligations, after which they are deleted or de-identified. [Confirm retention period for ID images]
• Payment, payout, and tax records — retained for the periods required by applicable tax, accounting, and financial-recordkeeping laws.
• Acceptance and signature records — your electronic signature (typed name or uploaded signature image), the acceptance date, timestamp, IP address, and agreement identifier are retained for the duration of your account plus the applicable statute-of-limitations periods (for example, generally two (2) years for personal-injury claims and ten (10) years for written contracts under West Virginia law) to evidence agreement to our terms.
• Technical, log, and diagnostic data — retained for a limited period for security, troubleshooting, and analytics.

When information is no longer needed, we delete, de-identify, or archive it in accordance with applicable law.

19 Children’s Privacy

The Services are intended only for adults: an individual must be at least 18 years of age to use the Services (and a Counselor must be at least 21). We do not knowingly collect personal information from anyone under 18, and we will take reasonable steps to delete any such information if we learn we have collected it. We enforce this age requirement in part through the identity and age verification described in Section 5 (date of birth and government-issued photo ID). If you believe someone under 18 has provided us information, please contact us using the details in Section 27.

20 Your Privacy Choices and Requests

Subject to applicable law and our legal and recordkeeping obligations, you may request to access, correct, delete, or receive a portable copy of personal information we hold about you, and you may opt out of any non-essential communications. A Counselee may also use the App-generated code name to limit the information disclosed to a Counselor (Section 3).

How to submit a request. Contact us using the details in Section 27. We will acknowledge and respond within the time required by applicable law (generally within 45 days, which may be extended where permitted). Identity verification. To protect your information — particularly for Counselees who use a code name — we may ask you to verify your identity through the email address associated with your account or other reasonable means before we act on a request; if we cannot reasonably verify you, we may be unable to fulfill the request. Where permitted by law, you may use an authorized agent to submit a request. We will not discriminate against you for exercising your privacy rights.

Closing your account. You may close your account at any time through the App or by contacting us (Section 27). When you close your account, we deactivate it and delete or de-identify your personal information, except information we are permitted or required to retain under Section 18 — such as payment, payout, and tax records; acceptance and signature records; identity-verification records for the required period; and information needed to comply with law, resolve disputes, or enforce our agreements.

21 State Privacy Rights Multi-state

BRIGHTHOPE is based in West Virginia but may be used by residents of other states. Your rights depend on the law of your state of residence.

21.1 West Virginia

As of the effective date of this Policy, West Virginia has not enacted a comprehensive consumer data privacy statute. Our practices are governed by West Virginia and applicable federal law, including the breach-notification provisions described in Section 23.

21.2 Residents of States With Comprehensive Privacy Laws

If you reside in a state that has enacted a comprehensive consumer privacy law — for example, California, Virginia, Colorado, Connecticut, Utah, or another such state — you may have the right, subject to that law’s conditions and exceptions, to: (a) confirm whether we process your personal information and access it; (b) correct inaccuracies; (c) delete personal information; (d) obtain a portable copy; and (e) opt out of the sale of personal information, of targeted/cross-context behavioral advertising, and of certain profiling. BRIGHTHOPE does not sell personal information and does not engage in targeted advertising or such profiling. Where a state law provides a right to appeal a denial of a request (for example, in Virginia, Colorado, and Connecticut), we will honor that right; instructions will be provided with our response.

21.3 California

California residents may exercise the rights above under the California Consumer Privacy Act, as amended. We do not sell or share (as those terms are defined under California law) personal information, and we do not knowingly process the personal information of consumers under 16 for sale or sharing. California’s “Shine the Light” law does not apply because we do not share personal information with third parties for their own direct marketing.

21.4 Consumer Health Data and Biometric Laws

Some states regulate “consumer health data” or biometric information. Because information you share may relate to your spiritual and emotional wellbeing, to the extent any such law applies to us we will honor its requirements, and we will not sell consumer health data or share it without any consent required by law. We do not use facial recognition or collect biometric identifiers (such as faceprints or voiceprints) from video sessions.

22 Third-Party Links and Services

The Services may link to or integrate third-party services we do not control, including payment processors and social media platforms. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their privacy policies before providing information to them.

23 Data Breach Notification

In the event of a breach of the security of computerized personal information that we maintain, we will provide notice to affected individuals and, where applicable, to other parties in accordance with the West Virginia breach-notification law (W. Va. Code § 46A-2A-101 et seq.) and any other applicable state or federal law, without unreasonable delay and consistent with the legitimate needs of law enforcement and the measures necessary to determine the scope of the breach and restore the integrity of the system.

24 Nationwide Users; Processing in the United States

BRIGHTHOPE operates from the State of West Virginia, and information is processed in the United States. If you access the Services from another state, your information will be handled in accordance with this Policy and applicable law, which may differ from the laws of your state. By using the Services, you consent to such processing.

The Services are intended for users located in the United States. We do not direct the Services to, or design them for, individuals located outside the United States. If you access the Services from outside the United States, you do so on your own initiative and are responsible for compliance with local law, and you understand your information will be processed in the United States.