Privacy & Policy

Introduction

Welcome to Afmental. When you use our platform and our services, we may need to collect information, and you may want to share information with us.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our platform. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

Please note that you must be over the age of 18 to use the Afmental platform.

Why we collect and use your data.

In order to provide the Afmental platform and services we will collect and use your data for one or more of the following legal reasons:

Contractual Obligations. We will need information from you to respond to a request from you to access Afmental platform and the therapy services. In joining as a service user, we will contract with you to provide access to therapy services through the Afmental platform, which will include information that we need to know to send a log on to access our platform and for billing purposes.

Consent. The Afmental platform is interactive, and you are invited to voluntarily contribute information, including personal data. The extent to which you engage with the interactive features is entirely at your discretion, and you may supply as much or as little information as you choose. Where you provide information about third parties, you should make sure you have their permission to do so.

Legal Compliance. We may use your personal data to enforce or defend our legal rights for safeguarding purposes or where we may be required by law.

Legitimate Interests. We will process your personal data to support the day-to-day running of Afmental in order to manage and provide the Afmental platform and the relationships between you, as a service user, and the therapists offering their services. We will manage accounts, deal with questions, comments and complaints and develop the platform and activities further. From time to time, we may invite you to provide feedback.

We have a legitimate interest to make Afmental safe and suitable for all visitors, and these rules tell you what information we need to help us do that.

We will collect information about the pages you visit, and how long you spend on each page – this helps us to improve Afmental’s services for you and other visitors. We may also collect information about the type of device you are using, or from where you are visiting Afmental. We try to collect and use information about users of Afmental in an anonymous format to protect individuals. We also use software cookies to monitor activity which may collect some information. If you have any questions, please contact us.

Personal Data

We try to limit the amount of your personal information that we ask you to provide. Personal information is information that identifies you, such as your name. If you share any personal information, Afmental will keep a copy but we will not share it with anyone else other than the payment provider and the therapy service provider you are connecting with.

The personal data we collect about you depends on the particular activities carried out through our platform, and may include:

• your name, address and contact information, including email address and telephone number.
• information to check and verify your identity, e.g. date of birth.
• your gender, if you choose to give this to us.
• location data.
• your billing information, transaction and payment card or other payment method information.
• bank account and payment details.
• details of any information, feedback or other matters you give to us by phone, email, post or via social media.
• your account details, such as username and login details.
• your activities on, and use of, our platform.
• information about the services we provide to you.

Special categories of personal data

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law. You may provide this information when engaging in or selecting services through the Afmental platform. This may include personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or data concerning health, sex life or sexual orientation.

Where we process such special category personal data, we will explain this to you, and seek your specific consent and agreement to allow us to use it. Special categories of personal data are only collected and used in connection with the recording of any therapy sessions (where this occurs, you will be notified, and have the option to decline).

From time to time, we may request you to comment on the general nature of mental health support you are seeking to enable us to provide relevant services; this information is voluntary and will be held anonymously.

Who we share your personal data with

We may share your personal data with third parties who provide services to us so we can deliver the platform and related services to you, to process your membership and payments, and for other necessary purposes.

We only allow third parties to hold your personal data where we have taken steps to be satisfied that they take appropriate measures to protect your personal data and limit any use where we can.

All therapy services are offered by independent third parties who operate as separate data controllers with their own privacy notices. When you approach them through the Afmental platform, you will be able to liaise with them directly through the platform to benefit from the therapy support offered. We will not share personal details with therapists unless you initiate the contact.

The Afmental platform may include links to third-party websites or applications. Using these links may allow third parties to collect and use your data. We do not control these third parties and we encourage you to read the privacy policy of each third-party website you visit.

We or the third parties mentioned above occasionally also share personal data with:

• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations.
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency, usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

We reserve the right to share data with third parties to comply with any legal or safeguarding duties where necessary, including to protect your vital interests.

How long we hold onto your personal data.

We will keep information that you provide through the Afmental platform whilst you have an account and for up to six years after your account is closed. Recordings of therapy sessions for quality control purposes will only be held for 12 months. Anonymous information (that does not include your own name) may be kept for longer.

We may transfer and store your data at a location outside the UK and your data may be processed by our agents, or subcontractors operating outside the UK. Where an individual therapist is located outside the UK, we will make this clear to you. When we transfer your data outside of the UK or EU we have appropriate measures in place that comply with UK data protection laws, and the EU GDPR, to ensure your data is secure and protected.

Please help us to maintain your privacy and protect your data by keeping your log-in information secret.

We have measures in place to help keep your data secure and to protect and prevent any loss, misuse, alteration or disclosure of your data. Our measures include: strong password policies, two-factor authentication, encryption, HTTPS technology, PCI-DSS compliant payment technology, IDS systems, regular audits, secure coding practices, regular updates and patch management. All data is stored securely and can only be accessed with passwords

• We use ‘https’ technology for all transactional areas on the Afmental platform
• We monitor our systems for possible vulnerabilities and attacks
• Our staff are aware about secure data handling

Your rights

Where we do hold your personal information, you have certain rights, and there are things you can ask us to do with your information. You can ask us to:

• Give you your information – but we may have to keep some copies
• Fix your information if it is wrong - we will do the best we can to help
• Stop using your information – but we may have to keep using some
• Delete your information – if you no longer want us to use it
• Give your information to another person – we will try our best to do so
• Change your answer to 'no' so we can no longer use your information – if you do, you may no longer be able to use Afmental
• Pause our use of your information – this means we would stop using your information for a set time

If you have any worries or concerns, please contact Afmental by writing to support@afmental.org

Complaints

If you have any concerns or questions about how we use your data, please contact us using the contact information provided on our platform.

You can complain about our use of your information, or how we deal with your request, by talking to the Information Commissioner’s Office. The Information Commissioner is in charge of information in the UK. You should ask an adult to do this for you. They can call 03031231113 or visit the website: www.ico.org.uk/ concerns

What if you do not live in the UK?

If you do not live in the UK, we still collect and use your information the same way. You can also still complain about our use of your information to the relevant data governance body in that jurisdiction.

Please note that countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

Updates to our Policy

We keep this policy under review. This version was last updated on 30th May, 2024.