Last updated 1 December 2022.
My Trauma Therapy Limited (registered number 13175819) (“us”, “our”, “we”, “MyNARA”) is the controller of your personal data collected through either https://www.mytraumatherapy.co.uk/ (the “Website”) or our apps (each an “App”) (together, the “Platform”). MyNARA is committed to protecting and respecting your privacy.
When you supply any personal data to us we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:
2. What information can we collect?
3. Special Category Data
4. How is your personal information collected?
5. How and why do we use and share your personal information?
6. For how long do we keep your personal information?
8. International Data Transfers
9. Your Rights
10. Contact Details
It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website and/or App at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.
This Policy supplements other notices on the Website and/or App and is not intended to override or replace them.
We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let users of the Platform know. However, it is your responsibility to check this Policy before each use of the Platform– for ease of reference the top of this Policy indicates the date on which it was last updated.
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.
Please note that the Platform is not directed at children under the age of 18 (each a "Child" or "Children") and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at firstname.lastname@example.org and request that we cease processing data about your Child.
2. What information can we collect?
What is personal data?
Where this Policy refers to ‘personal data,’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.
Depending on your location, you have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about your data protection rights, please review the guidance from your data protection supervisory authority.
What types of data we collect from you when you use the Platform
The personal data we collect from you may include:
• Identity Data which includes your name, date of birth and gender.
• Contact Data which includes your e-mail address and billing address.
• Transaction Data which includes details about payments to and from you and other details or services you have purchased from us.
• Technical Data which includes your IP address, your login data, device type and browser type and version.
• Profile Data which includes your username and password, your preferences, feedback and survey responses.
• Therapy Data which includes your medical history, your notes, images and questionnaire responses and your guided advice
• Usage Data which includes information about how you use the Website and/or App.
• Marketing and Communications Data which includes your preferences in receiving marketing from us and our associated third parties.
3. Special Category Data
When you use an App, you will be providing us with race and religious information, medical history, information about your emotional thoughts and feelings and details of your relationships (including sexual relationships) with third parties and other similar wellbeing data. This type of data is classed as sensitive or special category data.
When processing sensitive or special categories of personal data, we are obliged to have additional lawful bases for processing this data. Our lawful basis for processing this data is that the processing is necessary for the purposes of providing health care or treatment pursuant to a contract with a health professional. This is subject to conditions and safeguards such that your data is processed under the responsibility of a healthcare professional who by virtue of their professional status owes you a duty of confidentiality. Please note that we specifically do not require your consent to process your personal data once you have entered a contract for our services. However, as part of our approach and commitment to your well-being, we will regularly check with you that you wish to continue with our services.
We do not collect any political opinions or trade union membership data about you Nor do we collect any systematic information about criminal convictions and offences, but users may include details of actual or alleged criminal matters in their use of the Platform.
4. How is your personal information collected?
When you use the Platform to complete a form, complete a guided questionnaire or quiz, take notes or to contact us by email or by post, request marketing be sent to you, provide payment details, order a service or browse from page to page, or when you set up an account for access to an App, we may collect, store and use the personal data that you disclose to us.
Automated technologies or interactions
We shall also collect information about you when you visit and interact with the Platform through the use of your device and associated technologies such as cookies. The following are examples of information we may collect:
• information about your device, browser or operating system;
• your IP address;
• information about links that you click and pages you view on the Platform;
• length of visits to certain pages;
• subjects you viewed or searched for;
• page response times;
• records of download errors and/or broken links;
• page interaction information (such as details of your scrolling, clicks, and mouse-overs);
• methods used to browse away from the page; and
• the full Uniform Resource Locators (URL) clickstream to, through and from this Website and/or App (including date and time).
We use the data described above for several different reasons. Firstly, we use it to ensure that the Platform works properly and that you are able to receive the full benefit of it. Secondly, we use the data to monitor how users interact with the App. Thirdly, we use the data to gain insights about user preferences We undertake these activities because we have a legitimate interest in doing so.
Third parties or publicly available sources
We do not collect information about you from anywhere else, although we may share information about you with other persons (more below.)
Updating your information
If you want to update the information you have previously given to us, you can contact us at email@example.com.
5. How and why do we use/share your personal data?
Lawful basis for processing your information
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:
● Where you have asked us to do so;
● Where we need to do so in order to perform a contract we have entered into with you;
● Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests;
● Where it is in your vital interests and
● Where we need to comply with a legal or regulatory obligation.
Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.
Marketing and Communications
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased counselling services from us and you have not opted out of receiving that marketing.
We will not share your personal data with any third party for marketing purposes.
Opting Out of Marketing
To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us or the third party directly if you do not wish to receive any marketing materials from us or them.
Sharing your personal data
Depending on how and why you provide us with your personal data we may share it in the following ways:
• we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
• with selected third parties to which we sub-contract to provide various services and/or aspects of the Platform’s functionality(see “Service Providers” below);
We may also disclose your personal data to third parties in the following events:
• if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that transaction;
• if MyNARA or substantially all its assets are acquired by a third party, in which case personal data held by us about our patients and contacts will be one of the transferred assets;
Service Providers (Data Processors)
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We do not share special category data with any service providers. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. We do not allow our third-party service providers to use your personal data for their own purposes.
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. For how long do we keep your personal data?
We will hold your personal information on our systems in accordance with the professional standards for medical professionals. We will also take into consideration other 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 with 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 ‘Your Rights’ below for further information, although it is not possible to delete all your data where we re obliged to retain the data for compliance purposes. We also know that a feature of coercive control is for an abuser to take control of your device or your choice to seek counselling. We will continue to hold your personal information after you delete your App or cease counselling and if you ask for data to be erased. We shall use special techniques called pseudonymisation to protect your personal data after you have asked for it to be erased in order to further protect the personal data and to meet your wishes as far as we are able. Should you seek to restart your use of the Platform, or law enforcement authorities request your personal data, we will be able to recover your personal data.
In some circumstances we may 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.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.
MyNARA takes the protection of your information very seriously. We have put in place technologically and organisationally appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Where we have given you a password that enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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.
8. International Data Transfers
Where we transfer your data to a service provider, we seek to ensure that appropriate safeguards are in place to make sure that personal data is held securely and that data subject rights are upheld. Where we use certain service providers, we may use either specific contractual clauses mandated by regulators or require additional safeguards to be in place in order to give personal data greater protections. Such contractual clauses and/or additional safeguards shall be approved by the UK and EU regulators as compliant with the UK and EU GDPR regulations, respectively.
9. Your Rights
You may have the following privacy rights:
If you wish to access, correct, update or request deletion of your personal data, you can do so at any time within the app.
In addition, if you are a resident of the EEA or the United Kingdom, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects. Due to the nature of the personal data we process, it may not always be possible to fully respond to your requests.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local supervisory authority In the UK this is the Information Commissioner's Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance at firstname.lastname@example.org.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Users of our Website have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing communications we send you.
You can manage your cookie preferences by visiting our Cookie Consent Manager.
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Further Detail: Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Further Detail: Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase some personal data if you do not believe that we need to continue processing it but due to the nature of the services we provide and the nature of the personal data processed, it may not always be possible to erase all personal data.
You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
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. 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.
10. Contact Details
You may also lodge a complaint to the supervisory authority about the way we process your personal data. We would however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.
|Activity||Examples of the types of data we may collect||Lawful basis for processing|
|To register you as a user and deliver counselling services to you||Identity, contact, financial, profile and transaction information||Performance of a contract with you and to meet a legal obligation|
|To provide counselling services||Identity and Therapy data||Performance of a contract with you|
|To manage our relationship with you including notifying you of any changes to the Platform or services provided on the Platform.||Identity, contact, profile and marketing communications information.||We have a legitimate interest in doing this|
|To administer and protect our business and this Platform (including troubleshooting, data analysis and system testing.)||Identity, contact and technical information.||We have a legitimate interest in doing this|
|To deliver relevant content to you.||Identity, contact, profile, usage, marketing and communications and technical information.||We have a legitimate interest in doing this|
|To protect your physical wellbeing and to aid law enforcement||Identity, Profile and Therapy data||Protect your vital interests and fulfil a legal obligation|
|To use data analytics to improve the Platform, services||Technical and usage information.||We have a legitimate interest in doing this|