At Therapychat, we respect your privacy and are committed to protecting your data through complying with the General Data Protection Regulation (GDPR) and the data Protection act 2018 (DPA). This policy explains how we look after your personal data when you visit our website and/or use our app and sets out to inform you about your privacy rights and how the law protects you. Please spend some time reading this policy to ensure you understand its content and how our commitment to privacy is relevant to you.
2. Who we are
2.3. Contact details
Full name of legal entity: Altania de Mar S.L
Email address: firstname.lastname@example.org
Postal address: Paseo de la Castellana, 259D, Planta 43, 28046, Madrid
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2.5. Third-party links
3. The data we collect about you
3.1. Types of data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3.1.1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
3.1.2. Contact Data includes billing address and email address.
3.1.3. Health and Medical Data includes information about your health in response to the questions asked by our Therapychat robot.
3.1.4. Financial Data includes bank account and payment card details of therapists.
3.1.5. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
3.1.6. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our app.
3.1.7. Profile Data includes your username and password, preferences, feedback and survey responses.
3.1.8. Usage Data includes information about how you use our app and services.
3.1.9. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
3.2. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel the supply of services that we have agreed with you but we will notify you if this is the case at the time.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
4.1.1. Direct interactions. You may give us your Identity, Contact, Medical and Health and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
4.1.3. Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
5. How we use your personal data
5.1. Circumstances when we use your data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
5.1.1. where we need to perform the contract we are about to enter into or have entered into with you, including matching you with a therapist;
5.1.2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
5.1.3. where we need to comply with a legal obligation.
5.2. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
5.3.1. Promotional offers from us
5.3.2. Third-party marketing
5.3.3. Opting out
5.5. Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosures of your personal data
We may share your personal data with the therapists engaged with Therapychat.
7. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
9.1. How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see paragraph 11.2 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see paragraph 11.2 below to find out more about these rights.
If you wish to exercise any of the rights set out above, please contact us.
10.1. No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
10.2. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.3. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11.1. LAWFUL BASIS
11.2. YOUR LEGAL RIGHTS