This privacy policy applies to your use of:
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our website, App and services are not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Psyma Mental Health Technologies Limited (Psyma) is the data controller and is responsible for your personal data (collectively referred to as "we", "us" or"our" in this policy).
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Fullname of legal entity: Psyma Mental Health Technologies Limited
Email address: info@psyma.co.uk
We always try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive aboutt his very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. If you do have a complaint, contact our Data Protection Officer, Dr Saeema Ghafur who will investigate the matter on your behalf.
If you are not satisfied with the response from us or believe we are not processing your personal data in accordance with the law you have the right toraise your complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We keep our privacy policy under regular review. This version was last updated in February 2024. It is important that the personal data wehold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website and the Psyma App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App or our website, we encourage you to read the privacy policy of every website you visit.
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:
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
We do not collect any other Special Categories of Personal Data about you (this includes details about religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Psyma does not keep credit card details such as name, credit card number, card expiry date, CVV code and billing address. The Psyma App uses a specialist payment processing organisation, called Stripe, who keeps this information secure. Note that Stripe will process this information in accordance with its privacy policies and terms from time to time, a copy of which can be found at https://stripe.com/gb/privacy and by providing your payment details, you agree to Stripe processing those details in accordance with their privacy policy.
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 our therapy or referral services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
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:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent when collecting sensitive data (such as health information). You have the right to withdraw consent at any time by contacting us.
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 do not actively send marketing materials to our clients. However, if you have opted into our email updates we may send you information about our services that might be of interest to you.
If you have not opted in, we are unlikely to send you any marketing communications. However, under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
We will not share your personal information with third-parties for marketing purposes, nor will we ever sell your information to others.
You can ask us to stop sending you marketing messages, such as our email updates if you are subscribed, at any time by contacting us. You can also request that your personal contact information is deleted to prevent future proactive contact from ourselves.
Our website and the Psyma App uses cookies to distinguish you from other users of our website and App. This helps us to provide you with a good experience when you browse our website or use our App and also allows us to improve our website and App functionality for you.
A cookie is a small file of letters and numbers that we store on your browser, your device or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive or device.
We use the following cookies:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
We do not share the information collected by the cookies with any third parties.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
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.
We hold information about each of our clients and the details of any referral or therapy they receive in confidence. This means that we will not normally share your personal information with anyone else other than to therapists and counsellors who you have opted to provide you with services.
We will tell your mental health professional the time and date of your appointment. They will also have access to your user profile that contains your name, date of birth, your presenting problem and GP details.
In exceptional circumstances, we may share your personal data with the parties set out below, or in the below circumstances, for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer any of your data outside the United Kingdom and European Economic Area (EEA).
Once we have received your information, we will use strict procedures and security features to try to prevent your data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Personal information is minimised in the App and email communication. If email communication is required, sensitive personal data will be sent to clients in an email attachment that is password protected. The Psyma App will never use open or unsecure Wi-Fi networks to send any personal data.
Personal information is also stored on secure servers. Mobile devices are protected with a passcode/thumbprint scanner, mobile security and antivirus software.
The security of your personal information is important to us, but no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Should there be any breach of your personal data, we will inform you within 72 hours of knowing of it. We strive to ensure your personal information is protected at all times.
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.
By law we have to keep medical information about patients for 7 years after treatment has finished. After this time, this data is deleted at the end of each calendar year. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights 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.
Occasionally we may store your information longer, for example, if there is an unresolved complaint.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. For example, if you would like to deactivate an unused account. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. To request this, you are able to email info@psyma.co.uk
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
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.
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.
We try to respond to all legitimate requests within 30 days or receiving a request. 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. We may also require further evidence from you to confirm your identity.
A copy of your personal information will usually be sent to you in a permanent form (that is, a printed copy).
