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
1.2 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:
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.
2.1 Sources of personal data. We obtain your personal data from the following categories of sources:
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.
3.1 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:
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:
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.
4.1 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:
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.
5.3 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.
6.1 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:
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.
6.7 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.
7.1 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:
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.
8.1 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):
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.
Postal address: Valeo Therapy, 23 Princes Street, London, United Kingdom, W1B 2LX, the United Kingdom.