WisemindApp Terms of Use

Effective from 9 September 2026.

These Terms govern the use of the wisemindapp.com website, the WisemindApp web application and future WisemindApp mobile applications (together, the “Service”).

1. Service Operator

The Service is provided by Digital Vanguard LLC, a legal entity incorporated in the Republic of Armenia on 8 January 2026:

• registration number: 56381280;
• tax identification number: 08313488;
• address: Premises 239, 2/2 Anastas Mikoyan Street, Yerevan, Republic of Armenia;
• support email: [email protected]; email for legal matters and claims: [email protected];
• additional corporate email: [email protected].

Digital Vanguard LLC is referred to below as the “Company”, “we” or “WisemindApp”.

2. Definitions and Roles

User means an adult individual who has created an account.

Client means a User who uses DBT practice features independently or together with a therapist.

Therapist means a User who uses the Service in their professional practice, including to assign work, organise DBT groups and view the data of Clients who have granted them access.

Group means a space created within the Service for running a DBT group, exchanging messages, and organising sessions and assignments.

User Content means messages, entries, answers, notes, names or pseudonyms, and other information entered into the Service by a User.

3. Acceptance of the Terms and Electronic Communications

3.1. By creating an account, ticking the relevant box, or continuing to use the Service after these Terms take effect, the User enters into an agreement with the Company on these Terms. A User who does not agree to these Terms must not create an account or use the Service.

3.2. The User confirms that they had an opportunity to read and save these Terms before accepting them. The current version is available within the Service.

3.3. A verified email address, password, one-time code and other authentication methods used by the Service may serve as the key to a simple electronic signature where permitted by applicable law. An action taken after authentication or email verification is treated as the action of the relevant User unless the User proves that their access credentials were compromised.

3.4. The User must keep passwords and codes confidential, must not transfer the account to another person, and must promptly notify the Company of suspected unauthorised access.

3.5. Clause 3.3 does not replace any special form of consent or electronic signature required by applicable law for a particular operation. In that case, the Company may require additional confirmation before making the relevant feature available.

4. Age Restriction

4.1. The Service is intended only for people aged 18 or over.

By accepting these Terms during registration, the User confirms that they are at least 18. The Service asks for the User’s date of birth and refuses to create an account for a person under 18. The Company may request reasonable proof of age and may suspend or delete an account if the User is under 18 or has provided inaccurate information.

4.3. An age rating displayed by an app store does not override the 18+ restriction in these Terms.

5. Purpose of the Service

5.1. WisemindApp is a digital platform for keeping a diary card, completing dialectical behaviour therapy (DBT) worksheets and exercises, learning skills, receiving and completing homework, interacting with a therapist, organising DBT groups and using a safety plan.

5.2. The available features depend on the User’s role, plan, device, country and the Service’s stage of development. The Company may add, change or discontinue individual features subject to section 18.

5.3. The Company does not promise any particular therapeutic, medical, educational, financial or other outcome.

6. Important Medical and Crisis Warning

6.1. WisemindApp is not a healthcare provider, medical device, emergency service, or substitute for in-person or remote help from a qualified professional. The Company does not diagnose conditions, prescribe treatment, issue medical opinions or supervise compliance with a therapist’s recommendations.

6.2. Materials in the Service are informational and supportive. The User makes decisions about their health together with a therapist or healthcare provider of their choice.

6.3. The “I’m overwhelmed” feature, safety plan, helpline numbers and therapist notifications are supporting tools. They:

• do not provide round-the-clock monitoring;
• do not guarantee that a helpline number is current or available;
• do not guarantee delivery of an email or push notification;
• do not guarantee that a therapist will see the alert, contact the Client or provide help;
• do not automatically call emergency services or determine the User’s location.

6.4. The Client decides whether to send an alert to a connected Therapist. The alert contains the Client’s name or pseudonym, the fact that an alert was sent, and a link to the Service, but not the content of the diary card, worksheets or safety plan. The Client may withdraw the alert. An unanswered alert ceases to appear as active after 24 hours, although a technical and audit record of the event may be retained for the periods described in the Privacy Policy.

6.5. If there is an immediate threat to life or health, the User must immediately contact local emergency services, a crisis line, a healthcare provider or a nearby person. The Service must not be relied upon as the only way to obtain help.

7. Account

7.1. An account is required to use the Service. The User provides current information: email address, name or pseudonym, and time zone. Date of birth, country and region are optional. The date of birth is visible to a connected Therapist because adolescent and adult DBT practice differ; country and region are used to select emergency contact numbers.

7.2. The User is responsible for activity on their account, except where it results from a security failure by the Company.

7.3. An invitation sent by email is only a means of creating a connection within the Service. It does not verify the identity, qualifications or trustworthiness of the person who sent it.

7.4. One account may have both Client and Therapist features. Changing role does not alter the User’s obligations under these Terms.

8. Relationship Between Client and Therapist

8.1. A Therapist provides professional services independently of the Company. The Company:

• does not employ the Therapist and is not a party to the Therapist’s agreement with the Client;
• does not automatically verify the Therapist’s education, licences, certifications or right to practise;
• does not determine clinical decisions, frequency of contact or the Therapist’s actions in a crisis;
• is not responsible for the quality, lawfulness, timeliness or outcome of the Therapist’s professional services.

8.2. The Client selects their Therapist and grants access to records through a separate action within the Service. Membership of a Group does not by itself give therapists access to the Client’s diary card, worksheets, health information or safety plan.

8.3. While access is active, a Therapist may read the Client records made available by the Service but may not change them on the Client’s behalf. The Client may withdraw access. Following withdrawal, new records are unavailable to the Therapist unless otherwise required by law.

8.4. Granting access to one Therapist does not grant access to every trainer or participant in a Group.

9. Therapist Obligations

9.1. By registering as a Therapist, the User confirms that they use the Service in connection with their professional activities and are solely responsible for holding any education, qualifications, authorisations, insurance and lawful bases required to work with Clients.

9.2. The Therapist must:

• comply with professional confidentiality, ethical rules and applicable law;
• use Client data only for work agreed with the Client;
• not copy, disclose or use Client information outside permitted purposes;
• not request through a Group information that is unnecessary for running sessions;
• not invite or work within the Service with a Client under 18 unless the Therapist has independently obtained and retains prior consent from the Client’s legal representative; the Service is intended only for adult Users, and the Company does not collect or retain that consent;
• end access promptly when the professional relationship ends;
• secure their device and account;
• maintain their own crisis-response process and not use WisemindApp as their only emergency-alert system;
• independently perform their duties to the Client as an independent professional and, where applicable, as a separate personal-data controller.

9.3. If, under applicable law, the Company processes particular data on the Therapist’s documented instructions, the Therapist instructs the Company to process that data only to provide the Service features. The Company will maintain confidentiality, implement reasonable security measures, engage suppliers under contractual terms and assist with mandatory data-subject requests within its technical capabilities. The Therapist must not give the Company unlawful instructions.

9.4. A Therapist must not claim to be an employee, representative or partner of the Company unless expressly agreed in writing.

10. DBT Groups and Messages

10.1. Group participants may see one another’s names or pseudonyms and messages. Other participants are not shown email addresses, telephone numbers or health information. Contact details of Group trainers or facilitators may be available to participants.

10.2. A Group is created and organised by a Therapist. The Therapist is responsible for membership, the schedule, communication rules and professional moderation. The Company may intervene following a complaint, a security risk, a breach of law or a breach of these Terms.

10.3. The User understands that the Company cannot guarantee confidentiality once another participant has seen a message: a participant may repeat it or take a screenshot contrary to the rules.

10.4. Messages must not:

• threaten, bully, harass or humiliate others;
• encourage harm to oneself or others;
• disclose another person’s personal or medical information without a lawful basis;
• contain unlawful, discriminatory or fraudulent content, or content that infringes another person’s rights;
• distribute spam, advertising or malicious links;
• impersonate another person or a professional;
• collect participant contact details for purposes unrelated to the Group.

10.5. The User retains their rights in their messages and grants the Company a limited, non-exclusive licence to store, technically reproduce and display them to participants in the relevant conversation solely to operate the Service, maintain security and comply with law.

10.6. After account deletion, messages may remain in conversation history without being linked to an active profile so that the context is preserved for other participants. Retention arrangements and periods are set out in the Privacy Policy and mandatory law.

11. Acceptable Use

11.1. The User must not:

• breach the law, third-party rights or these Terms;
• use another person’s account or transfer their own account;
• attempt to circumvent access controls, obtain another person’s records or test whether another person has an account;
• interfere with the Service, scan for vulnerabilities without written authorisation, distribute malicious code or create an excessive load;
• extract data in bulk, create user databases or use automated tools contrary to the documentation;
• decompile, copy or reproduce the Service except where expressly permitted by mandatory law;
• use the Service for advertising, fraud, discrimination or unlawful surveillance;
• register before reaching the age of 18.

11.2. The Company may restrict features, remove manifestly unlawful content or suspend an account in accordance with section 16.

12. Subscription, Trial Period and Payment

12.1. At the current stage, paid subscriptions are intended for Therapists. A Client does not pay the Company for basic use of the features made available under the Service model. If paid Client content is introduced, these Terms must be updated before sales begin.

12.2. The price, currency, subscription period, trial length, first charge date, taxes and available features are shown immediately before purchase. The information on the payment screen takes precedence for that purchase.

12.3. International payments may be processed through Polar Software, Inc., acting as merchant of record and authorised reseller. In that case, the purchaser buys the subscription from Polar and the Company supplies a licence and access to WisemindApp. Polar’s terms shown at purchase also apply to checkout, payment, taxes, receipts, automatic renewal, cancellation and refunds.

12.4. Payments from Russia may be processed through Boosty or another payment service identified on the payment screen. The party to the payment transaction and the arrangements for charges, receipts, cancellation and refunds are determined by the information and terms shown by that platform before payment.

12.5. The Company does not receive full payment-card details. It may receive a customer or subscription identifier, status, plan, currency, billing-period dates and other information required to manage access and provide support.

12.6. If automatic renewal is disclosed before payment, the subscription renews and payment is charged for each new period until cancelled. The User may cancel renewal through the payment platform account or by another method specified there. Cancellation takes effect for future periods and will not normally end a period that has already been paid for.

12.7. If a trial automatically converts to a paid subscription, this must be clearly shown before activation. To avoid being charged, the User must cancel before the trial ends.

12.8. If the price changes, the new price will apply no earlier than the next period following notice and consent where required by law or the payment platform’s rules.

13. Refunds and Payment Disputes

13.1. Refunds are handled by the payment platform acting as seller or as a party to the payment transaction, under its rules and applicable mandatory law.

13.2. For a purchase through Polar, a subscription may be cancelled at any time for future periods. Fees for a completed period are not normally refundable except where required by law or Polar’s terms, or where access was not provided or the charge was erroneous, fraudulent or duplicated.

13.3. A request should be submitted through the relevant platform’s support service. The Company will provide reasonable assistance at [email protected] but cannot promise an outcome decided by the payment platform, bank or payment scheme.

13.4. This section does not limit the User’s inalienable rights or the right to dispute an unauthorised transaction with their bank.

14. Intellectual Property

14.1. The Service, software code, design, texts, catalogue of skills and exercises, illustrations, audio and other materials belong to the Company or its licensors and are protected by applicable law.

14.2. The Company grants the User a limited, revocable, non-exclusive and non-transferable right to use the Service for the Client’s personal purposes or the Therapist’s internal professional practice while the account and subscription remain active.

14.3. Names of methods, links to external materials and references to third parties do not transfer rights in the relevant trade marks or materials.

14.4. The User warrants that they are entitled to submit their User Content and is responsible for any infringement of third-party rights.

15. Privacy and Personal Data

15.1. The Company processes personal data as described in the Privacy Policy and, for health data and other special-category data, under separate explicit consent. For Users in the EEA, the relevant Article 6 GDPR lawful bases include performance of the contract under Article 6(1)(b), compliance with legal obligations under Article 6(1)(c), and the Company’s or a third party’s legitimate interests under Article 6(1)(f), depending on the purpose. Equivalent provisions of the UK GDPR apply to Users in the United Kingdom. Health data is processed under Article 9(2)(a) GDPR or UK GDPR on the basis of the User’s explicit consent, together with an Article 6 basis. The Company does not rely on legitimate interests instead of explicit consent where Article 9 requires that consent.

15.2. The Service uses product analytics as described in sections 4.8 and 13 of the Privacy Policy. The texts of clinical records are not sent to analytics providers, but a crisis-path event may itself reveal or allow an inference about health.

15.3. A Client grants and withdraws a Therapist’s access to the Client’s records separately. Access to a Group is not consent to view individual records.

15.4. A User who adds details of a family member or another third party to a safety plan must have a reasonable lawful basis for privately storing them, must not add unnecessary data, and, where safe and practicable, should tell that person how the details are used.

16. Suspension, Restriction and Account Deletion

16.1. The Company may temporarily restrict or suspend an account without advance notice where necessary to prevent a threat, data breach, fraud, unauthorised access, harassment, harm to users, breach of payment-platform requirements or breach of law.

16.2. Where a breach can be remedied, the Company will, where possible, explain the reason and provide a reasonable opportunity to remedy it. The Company may permanently terminate access for a material or repeated breach.

16.3. The User may initiate account deletion. The account is deactivated for 30 calendar days: ordinary features cannot be accessed, but deletion may be cancelled using a dedicated button. Merely signing in does not cancel deletion.

16.4. At the end of that period, the Company deletes or anonymises data as described in the Privacy Policy. Consent records, audit records, financial data, messages, Group data and other information may be retained to a limited extent where necessary for other participants, compliance with law, security or the defence of legal claims.

16.5. When a Therapist’s account is deleted, their access to Client data ends. Client records remain with the Clients. A Group may remain without that Therapist, together with its schedule, attendance records, internal payment log and messages.

17. Third-Party Services and Links

17.1. The Service relies on third-party providers for infrastructure, analytics, email, storage and payments. A failure by one of them may temporarily affect WisemindApp.

17.2. By following an external link, the User interacts with an independent service on that service’s terms. The Company does not control the external resource and is not responsible for its content, availability or data processing.

18. Changes to the Service and Terms

18.1. The Company may update the Service and these Terms. Changes required for security, compliance with law or correction of an obvious error may take effect without a lengthy notice period.

18.2. The Company will give advance notice in the Service or by email of material changes that adversely affect the User’s rights where reasonably practicable and required by law.

18.3. Fresh consent will be requested separately if a change concerns the purposes for processing special-category data, new recipients or another operation for which the law requires fresh consent.

18.4. If the User does not agree to a change, they must stop using the Service and may delete the account before the change takes effect.

19. Availability and Disclaimer of Warranties

19.1. The Service is provided “as is” and “as available”. The Company takes reasonable measures to keep it secure and operational but does not guarantee that it will be error-free, continuously available, compatible with every device or that every feature will be retained permanently.

19.2. The Company does not guarantee the accuracy of information entered by users, a Therapist’s qualifications, the behaviour of other participants, a therapeutic outcome, delivery of external notifications or the currency of an external resource.

19.3. Nothing in these Terms excludes guarantees that cannot be excluded under mandatory law.

20. Limitation of Liability

20.1. To the fullest extent permitted by law, the Company is not liable for indirect, incidental or consequential loss, loss of profit, loss of business opportunity, the acts of an independent Therapist or another User, or the failure of an external provider outside the Company’s reasonable control.

20.2. The Company is not liable for harm resulting from using the Service instead of emergency, medical or professional help, or from expecting a guaranteed response to a crisis alert, because these limitations are expressly disclosed in section 6.

20.3. The Company’s total liability to a paying Therapist for claims connected with the Service is limited to the amount of WisemindApp licence fees actually attributable to that Therapist’s subscription during the 12 months before the event. Liability to a User of free features is limited to the equivalent of USD 100 unless mandatory law requires a higher amount.

20.4. The limitations in clause 20.3 apply only to contractual monetary claims that applicable law permits to be limited. They do not apply to liability that cannot lawfully be limited, including liability for intentional misconduct, gross negligence, breach of confidentiality caused by the Company, death or personal injury where exclusion is prohibited, mandatory consumer rights under the law of the User’s habitual residence, or claims arising from a breach of data-protection law.

21. Indemnity by Therapist

To the extent permitted for a professional user, the Therapist will indemnify the Company for documented direct losses and reasonable costs arising from the Therapist’s intentional or grossly negligent breach of law, professional confidentiality, Client rights, section 9 or unlawful data-processing instructions. The Company must give prompt notice of a claim and a reasonable opportunity for the Therapist to participate in the defence. This section does not transfer responsibility for the Company’s own breach to the Therapist.

22. Governing Law and Disputes

22.1. These Terms are governed by the law of the Republic of Armenia, without regard to its conflict-of-law rules.

22.2. This choice of law does not deprive the User of mandatory protections under the law of their country of habitual residence where those protections apply irrespective of the choice of law. The GDPR and UK GDPR govern relevant processing of personal data where they apply; they do not replace the contractual choice of Armenian law in clause 22.1.

22.3. Before bringing court proceedings, a party should submit a claim to [email protected]. The other party has up to 30 calendar days to respond, except for urgent relief, data-protection claims and cases in which mandatory law permits immediate proceedings.

22.4. Disputes with Therapists acting as professional users are subject to the competent courts of Yerevan, Republic of Armenia, unless mandatory law confers exclusive jurisdiction elsewhere. This does not restrict a Client’s right to use a court whose jurisdiction is mandatory for that Client.

23. Miscellaneous

23.1. If a provision is held invalid, the remaining provisions continue in force. The invalid provision applies to the greatest lawful extent that most closely reflects its purpose.

23.2. A failure by the Company to exercise a right in a particular case is not a waiver of that right.

23.3. The User may not assign the agreement or account to another person. The Company may assign the agreement to a successor in a reorganisation or sale of the business or Service, provided the User’s rights are preserved and proper notice is given.

23.4. The Russian version prevails until other language versions are published.

24. Contacts

Support: [email protected]. Legal matters and claims: [email protected].

Company-related enquiries: [email protected].

Postal address: Premises 239, 2/2 Anastas Mikoyan Street, Yerevan, Republic of Armenia.