Our Privacy Policy

Last updated: 19 April 2021

We take your privacy very seriously. Our Privacy Policy explains in detail how we collect, use and disclose your personal data.  We do not sell your information to any third party and will only use it as outlined below.
If you have any questions please reach out to us at info@valeotherapy.com

1. GENERAL INFORMATION

2. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE IT?

3. WHAT TECHNICAL (NON-PERSONAL) DATA DO WE COLLECT?

4. HOW DO WE COMMUNICATE WITH YOU?

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

6. HOW DO WE SHARE AND DISCLOSE YOUR DATA?

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

8. WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?

9. OUR CONTACT DETAILS

1. GENERAL INFORMATION

1.1 About the Privacy Policy. This Valeo Therapy Privacy Policy (the “Privacy Policy”) governs the processing of personal data collected from natural persons (“you” and “your”) through the online platform available at https://www.valeotherapy.com, the related domain names, and services (collectively, “Valeo Therapy”). The Privacy Policy does not apply to any third-party websites, applications, software, products or services that integrate with Valeo Therapy or are linked from Valeo Therapy. 

1.2 Owner of Valeo Therapy. Valeo Therapy is owned and operated by the company Valeo Therapy having a registered office at 23 Princes Street, London, United Kingdom, W1B 2LX, the United Kingdom, and the company registration number 12825506 (“we”, “us”, or “our”). 

1.3 Our role as a data controller and data processor. We act in the capacity of a data controller and a data processor with regard to the personal data processed through Valeo Therapy in terms of the applicable data protection laws, including the UK Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR). Our role depends on the specific situation in which personal data is handled by us, as explained in detail below:

  • Data controller. We are responsible for the collection and use of your personal data through ValeoTherapy and we make decisions about the types of personal data that should be collected from you and purposes for which such personal data should be used. Therefore, we act as a data controller with regard to the personal data collected directly through Valeo Therapy (e.g., when you send us an inquiry or conclude a service contract). We comply with data controller’s obligations set forth in the applicable laws.
  • Data processor. We act in the capacity of a data processor in situations when you submit information, files or generate data through Valeo Therapy for processing (“Your Data”) and Your Data contains your or other individuals’ personal data. We do not own, control, or make decisions about Your Data. We process Your Data only in accordance with the instructions issued by a respective data controller. To ensure that Your Data is processed in accordance with the strictest data protection standards, we offer for conclusion a data processing agreement. You can receive a copy of such an agreement by contacting us at info@valeotherapy.com. 

1.4 Your consent. Before you submit any personal data through Valeo Therapy, you are encouraged to read this Privacy Policy that is always available on Valeo Therapy to understand on what legal bases (other than your consent) we rely when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, you consent may be necessary if: (i) we intend to collect other types of personal data that are not mentioned in this Privacy Policy; (ii) we would like to use your personal data for other purposes that are not specified in this Privacy Policy; or (iii) we would like to transfer your personal data to third parties that are not listed in this Privacy Policy. 

1.5 Children. Valeo Therapy serves a specialised online platform connecting parents with therapists for their children’s therapy needs. Valeo Therapy should be primarily used by adult persons. Nevertheless, Valeo Therapy may be used by children if parents or legal guardians permit such a use. We reserve the right to verify your age at any time. Children younger than 18 are not allowed to conclude service contracts (e.g., book a therapist) through Valeo Therapy by themselves - it has to be done by an adult person. Therefore, we do not intentionally collect children’s personal data, unless parents decide, at their sole discretion, to provide such data to us. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay.  

1.6 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.7 Amendments. The Privacy Policy may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.


2. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE IT? 

2.1 Sources of personal data. We obtain your personal data from the following categories of sources:

  • Directly from you. For example, if you submit certain personal data directly to us when registering your user account or contacting us;
  • Directly or indirectly through your activity on Valeo Therapy. When you use Valeo Therapy, we automatically collect technical information about your use of Valeo Therapy; and
  • From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a lawful basis for disclosing your personal data to us.

2.2 Types and purposes of personal data. We respect data minimisation principles. This means that we collect only a minimal amount of personal data through Valeo Therapy that is necessary to ensure the proper provision of Valeo Therapy as described below. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying on one of the available legal bases. You can find more information about the legal bases below.

  • Registration of a parent’s account. When you register your user account as a parent on Valeo Therapy, we collect your first name, email address, phone number, and password. In order to match you with the right therapist, we collect your child’s name, gender, and age. You may also provide us with any other information that you find important and add your picture. We use the said information to register and maintain your user account, enable your access to Valeo Therapy, search for the right therapists, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you,pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer Valeo Therapy), and ‘your consent’ (for optional personal data). We keep your personal data until you delete your user account.
  • Application to become a therapist. When you submit your application to become a therapist on Valeo Therapy, we collect your name, email address, phone number, qualifications, and any other information you decide to provide about yourself. We use the said information to assess your eligibility, register your user account, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you,pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer Valeo Therapy), and ‘your consent’ (for optional personal data). We keep your personal data until (i) the processing or your request is completed or (ii) if you have a user account, you delete your user account.
  • Inquiries. When you contact us by email or by using the “chat” functionality, we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data). We keep your personal data until you stop communicating with us.
  • Payments. When you make or request a payment, you will be asked to provide your payment details that depend on the chosen payment provider (like your name, credit card number, expiration date, security code, billing address, or PayPal details). Please note that we do not process payments - it is done by our third-party payment processors. Your payment data is used to process your payments and maintain our business records. The legal bases on which we rely are ‘performing a contract, pursuing our legitimate business interests’ (i.e., administer our business), and ‘complying with our legal obligations’.  We keep your personal data for 6+1 years, as required by law. 
  • IP address. When you use Valeo Therapy, we or our third-party analytics service providers (as explained in section 3 below) collect your IP address. We use your IP address to analyse the technical aspects of your use of Valeo Therapy, prevent fraud and abuse of Valeo Therapy, ensure the security of Valeo Therapy, and tailor Valeo Therapy for your location. The legal basis on which we rely when processing your IP address is ‘pursuing our legitimate business interests’ (i.e., to analyse and protect Valeo Therapy). We keep your personal data as long as it is necessary for analytics purposes. 
  • Cookies. When you browse Valeo Therapy, we collect your cookie-related data. For more information about the purposes for which we use cookies, please refer to our Cookie Policy. It also explains how long your cookies are valid. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to analyse and promote our business) and ‘your consent’ (for non-essential cookies).  

2.3 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you or your child, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your or your child’s health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation. If you provide us with such sensitive data or Your Data contains the said sensitive data, we will process such data for the purpose of fulfilling our contractual obligations. As soon as the processing is completed, we will securely delete it from our systems.  

2.4 Processing of Your Data. When you upload or create Your Data on Valeo Therapy, we process Your Data as requested by you, including any personal data Your Data may contain. Your Data may contain the following information: names, email addresses, addresses, phone numbers, identification numbers, photos, activity and behavioural data, etc. We process Your Data in order to (i) provide you with the requested services and (ii) perform our contractual obligations. The legal basis on which we rely is ‘performing a contract with you’. As soon as the processing of Your Data is completed, we will securely delete it from our systems.  

2.5 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of Valeo Therapy or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.  

2.6 Ratings. After completing a service contract, you will be provided with a possibility to rate the client or therapist with whom you have cooperated and provide accompanying remarks (the “Feedback”). Please note that the Feedback (in part or in full) may become available to other users of Valeo Therapy and the general public on the Internet. Therefore, you are required to exercise your due diligence when submitting the Feedback through Valeo Therapy and avoid disclosing your or other individuals’ personal data in the Feedback. You are not allowed to disclose personal data belonging to persons who have not provided you with their authorisation to do so, unless you have a legal basis for such a disclosure. 

3. WHAT TECHNICAL (NON-PERSONAL) DATA DO WE COLLECT?

3.1 Log files and analytics data. In order to analyse your use of Valeo Therapy, we and our analytics service provider Google Analytics automatically collect certain technical non-personal data about your use of Valeo Therapy. Such data does not allow us or Google to identify you as an individual person in any manner. The non-personal data includes the following information: 

  • Your activity on Valeo Therapy (e.g., what functionalities you use, how much time you spend on Valeo Therapy, how long it takes for Valeo Therapy to load and process your requests, and what errors occur);
  • Your device type;
  • The operating system of your device;
  • Your browser type;
  • URL addresses that you visit; and
  • Your other online behaviour.

3.2 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records. 

3.3 Purposes of technical (non-personal) data. We use your technical (non-personal) data for the following purposes:

  • To analyse what kind of users visit Valeo Therapy;
  • To examine the relevance, popularity, and engagement rate of Valeo Therapy; 
  • To investigate and help prevent bugs, security issues and abuse; 
  • To develop and provide additional features to Valeo Therapy; and
  • To personalise Valeo Therapy for your specific technical needs (e.g., to adjust the design and resolution for your device). 

3.4 Aggregated and de-identified data. If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data and make sure that we have a legal basis for processing it. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.

4. HOW DO WE COMMUNICATE WITH YOU?

4.1 Newsletters. If we have your email address, we may, from time to time, send you a newsletter informing you about the latest developments related to Valeo Therapy and our special offers. You will receive our newsletters in the following instances:

  • If we receive your express (“opt-in”) consent to receive marketing messages; or
  • If you voluntarily subscribe for our newsletter; or
  • If we decide to send you information closely related to services already used by you.

4.2 Opting-out. You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.

4.3 Tracking pixels. The newsletters sent by us may contain tracking pixels that allow us to conduct analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We use such information to conduct analytics and pursue our legitimate business interests.

4.4 Service-related notices. If necessary, we will send you important informational messages, such as confirmation receipts, booking reminders, payment information, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices but you can adjust the setting of such notices through your user account. 

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

5.1 Retention of personal data. We store your personal data in our systems only for as long as such personal data is required for the purposes described in section 2 of this Privacy Policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.

5.2 Retention of technical (non-personal) data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. For example, we can store it for the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

5.3 Retention as required by law. In certain cases, we are required by law to store your personal data for a certain period of time (e.g., for business records or accountancy purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.

6. HOW DO WE SHARE AND DISCLOSE YOUR DATA?

6.1 Disclosure to data processors. From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:

  • Ensuring the proper operation of Valeo Therapy;
  • Ensuring the delivery of the services ordered by you;
  • Providing you with the requested information;
  • Pursuing our legitimate business interests;
  • Enforcing our rights, preventing fraud, and security purposes;
  • Carrying out our contractual obligations; or 
  • If you provide your prior consent to such a disclosure. 

6.2 List of our data processors. We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that have access to your personal data are: 

  • Our hosting, database, and cloud storage service provider Amazon Web Services located in the United States; 
  • Our newsletter service provider SendGrid located in the United States;
  • Our technical support and chat service provider Zendesk located in the United States;
  • Our payment service provider Stripe located in the United States;  
  • Our video call service provider Twilio located in the United States; and
  • Our independent contractors and consultants.

6.3 Disclosure of technical (non-personal) data. Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving Valeo Therapy, responding to lawful requests from public authorities or developing new products and services. 

6.4 Legal requests. If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

6.5 Successors. In case Valeo Therapy is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy. We will notify you of any changes of the data controller. 

6.6 Selling personal data. We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetisation purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross-device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your personal data used for such purposes as described in our Cookie Policy.

6.7 International transfers. Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

7.1 Our security measures. We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include:

  • Access control;
  • Secured networks;
  • SSL protocol;
  • Encryption;
  • Strong passwords;
  • Multi-factor authentication;
  • Anonymisation of personal data (when possible); and
  • Carefully selected data processors.

7.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law. 

8. WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?

8.1 The list of your rights. You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):

  • Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
  • Right to rectification: you can rectify inaccurate personal data that we hold about you;
  • Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
  • Right to restriction: you can ask us to restrict the processing of your personal data;
  • Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
  • Right to object: you can ask us to stop processing your personal data;
  • Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
  • Right to complaint: you can submit your complaint regarding our processing of your personal data.

8.2 How to exercise your rights? If you would like to exercise any of your rights, please contact us by email at info@valeotherapy.com or by post (you can find our postal address at the end of this Privacy Policy) and explain your request in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

8.3 Complaints. If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

8.4 Non-discrimination. We do not discriminate against you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with lower quality services.

8.5 Requests regarding Your Data. If we get a request regarding the personal data included in Your Data, we will forward such a request to the respective controller. This is because we, as a data processor, do dot accommodate data subjects’ requests with regard to personal data that we process on behalf of our users. 

9. OUR CONTACT DETAILS

If you have any questions about this Privacy Policy or our data protection practices, please contact us by:

Email: info@valeotherapy.com

Postal address: Valeo Therapy, 23 Princes Street, London, United Kingdom, W1B 2LX, the United Kingdom.