What Personal Information do we process about you and for what purpose
When you sign up to the Platform, update your account details, provide your billing information and your emergency contact information, or make any other use of our services, we may ask you to provide personally identifiable information. The Personal Information may include, but not limited to, your name, your email address, your phone number, your address and your emergency contact. We may use the Personal Information, either by itself or in conjunction with other information, for the following purposes:
- Create your account at our Platform, let you login into the account, administer your account, monitor your account, provide customer services and contact you with information, alerts and suggestions that are related to your account;
- Billing related purposes;
- Reach out to you, or to your emergency contact, either ourselves, or using the appropriate authorities, if either we or a Service Provider has a good reason to believe that you, or any other person, may be in danger or may be either the cause, or the victim, of a criminal act;
- Let a Service Provider know your first name so he or she can communicate with you effectively;
- Let a Service Provider know your emotional and psychological state to ensure he is licensed and qualified to provide a service to you.
We may ask you several questions about you and your needs. This will include data concerning your health, and other special category data which you may voluntarily provide including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation. We may use this information either by itself or in conjunction with other information, for the following purposes:
- To help us and our Service Providers to get to know you and your needs;
- To collect and analyse statistical or aggregated information, which is not personally identifiable.
When you use the Platform, our servers or servers of third party services automatically record information that your browser sends (“Log Data”). This Log Data may include, but not limited to, information such as your computer, internet Protocol address (“IP”), pages that you visit and the time spent on those pages, actions that you take and other statistics. We may use this information to monitor, analyse and improve the use and functionality of the Platform, the Platform’s technical operation and the match of the Platform functionality to your needs and preferences. For more information kindly refer to our Cookies Policy.
While using the Platform you and a Service Provider would likely write or say things by means of text-based communication through chat. The Session Content is shared with the Service Provider/s that work with you. The session content may be used by the Service Provider to:
- Let a Service Provider provide the service to you;
- Supervise, administer and monitor the service provided to you;
- Allow professional supervision to the Service Provider by qualified professionals.
Note that all communications transmitted through the Platform, may be recorded or monitored by the Service Provider for quality assurance and training purposes and become part of your file and records, which records are retained by the Service Provider.
On what basis do we use your personal information?
- For the performance of a contract: We process your personal data as necessary in order to provide you with our services when you sign up to the Platform.
- With your consent: We will process your personal information when you have given your consent to the processing of your personal data for one or more specific purposes set out above. You have various rights where we are processing your information on the basis of your consent. For example, if you no longer wish to be on one of our mailing lists, you can choose to opt out at any time by following the “unsubscribe” instructions at the bottom of our promotional emails. If you have an online account with us, you can also opt out by updating your preferences.
- For legitimate business purposes: There may be instances where we are compelled to process your personal information in order to safeguard our professional interests and reputation. Where we use your personal information for this purpose, rest assured that we will take measures to protect your personal information
- To comply with a legal obligation: There may be instances where we are legally obliged to process your personal information.
Online identity theft and account hacking, including the practice currently known as “phishing” are of great concern. You should always suspect when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information, your credit card information, in a non-secure or unsolicited communication (e-mail, phone or otherwise).
Transfer of Business
We may sell or transfer some or all of our assets, including your Personal Information, in connection with a merger, acquisition, consolidation, joint venture, reorganization or sale of assets. Such a transfer will be in compliance with the Data Protection Act.
We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks, which are related to the Platform or to provide audit, legal, operational or other services for us. When needed we may disclose information, including personal information, to such third parties, but we will try to limit the Personal Information disclosed to the minimum necessary to perform their task.
We do not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by persons under the age of 18. If you are aware that this has happened please contact us and we will delete that information.
Your information may be transferred to – and maintained on –computers located outside your country where the privacy laws may not be as protective as those in your jurisdiction. Where appropriate, we will take steps to ensure your information is transferred subject to appropriate safeguards, such as by entering into data transfer agreements. Where we have put data transfer agreements or similar safeguards in place, we may be able to make a copy of this available to you if you contact us via one of the methods set out under the header “Contact Us” below.
Compliance with Law and Law Enforcement
We cooperate with government and law enforcement officials to enforce and comply with the law. We will disclose any information to government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal process, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. You should be aware that Service Providers may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires psychotherapists and conselors to provide information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court ordered presentation of treatment (e) terrorism.
We have a data retention policy that sets out how long we keep your information. This policy is based on the type of information, the purpose of collection, and the system within our digital platforms in which the information is held. As a general rule, we keep your personal information for as long as we need to in order to carry out those purposes for which your data has been collected.
We are concerned about safeguarding your information. The security of your Personal Information is very important to us. Therefore, we employ measures to protect this information from unauthorized access, use, and disclosure. However, the confidentiality of any communication transmitted through the Platform or stored with us cannot be guaranteed. Please remember that while your therapist will take every measure to safeguard your information, no method of electronic transmission over the internet or method of storage can be 100% secure.
It is also possible that you may save the transcripts of the information discussed in your online counselling session in printed or electronic form. You are encouraged to take steps to ensure that your information remains confidential
You have the right to:
- Withdraw your consent when your personal data is processed on the basis of your consent. The withdrawal of your consent shall not affect the lawfulness of processing before the withdrawal of your consent.
- Ask us about the processing of your personal information, including to be provided with a copy of your personal information held by ListeninToYou;
- to request the correction and/or deletion of your personal information, or restrict or object to the processing of your personal information;
- to request to obtain and reuse your personal information for your own purposes across different services; and
- to complain to a competent supervisory authority, or to a court of law, if your data protection rights are violated or you have suffered as a result of unlawful processing of your personal information.
If you would like access to the information that we hold about you, if any of the information that we hold about you is inaccurate or out of date, or if you wish to withdraw your consent to the processing of your data or to restrict or object to us processing it, please let us know by getting in touch via one of the methods set out under the header “Contact Us“ below.
If you object to our processing of your personal information, we will respect such requests in accordance with our legal obligations. Your objection may mean that we may not be able to perform the actions necessary to achieve the purposes set out above.
We may be required or entitled to retain your information to comply with legal and regulatory obligations and to protect and exercise our legal rights and legitimate interests.
In addition to those rights outlined above you also have an unconditional right to object at any time to the processing of your personal information for direct marketing purposes by contacting us via one of the methods set out under the header “Contact Us” below.
ListeninToYou is the controller of your personal information.
Last revised: 8th November 2018