App Web Privacy Policy

Last update: 01/10/2024

1. Identification of the Entity Responsible

This Privacy Policy describes how your Personal Data may be collected, used and disclosed by Digital Mind Solutions, S.L.U. (hereinafter “ifeel“) and how you can access it. At ifeel, we are committed to protecting and respecting your privacy. Ifeel operates in compliance with, among others, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), as well as the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (“LOPDGDD”) and its implementing regulations, hereinafter indistinctly (“Data Protection Regulations”). The party responsible for the processing of the User’s Personal Data associated with certain uses of the Web Platform and Mobile App (both jointly referred to as “Platforms”) from the moment you process your registration and/or log in, as well as for the provision of the services, is ifeel.

Owner: Digital Mind Solutions S.L.U.
Registered office: Calle de Ortega y Gasset 100, 6ª. 28006, Madrid.
TAX IDENTIFICATION NUMBER: B87593851
Public Registry: Registered in the Mercantile Registry of Madrid; in volume 34901, folio 29, General section, page number M-627653, 1st inscription.
E-mail: [email protected]

2. Our approach to privacy

2.1 This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information”) in your use of the Platforms.

2.2 This Privacy Policy applies to the Platforms. Please ensure that you have read this Privacy Policy and understand how we collect, store, use and communicate your personal information before accessing or using the Platforms.

3. Previous information about our type of accounts

User Account
Psychologist Account

We have two types of accounts, depending on whether it is a user or a psychologist, which provide different functionality to different users of the Platform:

User Account: Allows a user to access, through the platform, the emotional well-being improvement program configured by ifeel. The User Account is unique, personal and non-transferable. Ifeel is not responsible for the improper or negligent use of the User Account, nor for the use of such account by third parties other than the specific user.
Psychologist Account: Allows a professional psychologist to use the ifeel platform in order to provide personalized attention to the platform users. The psychologist account is unique, personal and non-transferable. Ifeel is not responsible for the improper or negligent use of the Psychologist Account, nor for the use of said account by third parties other than the specific psychologist to whom it has been provided.

4. Who is responsible for the use of your personal information?

ifeel as Data Controller

We act as Controller of personal data for the purposes of the GDPR, in the following situations:

The Platforms: ifeel is responsible for the processing of personal information that we hold about you in connection with your registration on the Platforms and information provided through the use of the Platform. Specifically, we act as data controllers:

(a) When we manage the registration of the User Account and the Psychologist Account on our Platform.

b) In obtaining the initial emotional health questionnaire.

c) In the provision of the health service, when the user is treated by one of our internal psychologists.

ifeel as Data Processor

We act as Data Processor for the purposes of the GDPR:

ifeel acts as data processor in relation to those users of the platform who are employees of an organization or company with which ifeel has concluded a corresponding contract for the provision of emotional well-being services, for the benefit of the employees of such organization or company, in order to carry out the pre-registration of the same on the Platform. In this case, ifeel does not have a direct relationship with the data subjects and exclusively processes the end user’s personal data on behalf of the organizations or companies and in accordance with their instructions.
In the provision of the health service carried out in the Platforms by the external Professional Psychologist, with whom ifeel maintains a business relationship, being the Data Controller of such professional health service, acting ifeel as a data processor.

5. The personal information we collect from you when you use our Platforms and how we use it.

5.1 We collect personal information that you, or your Psychologist, voluntarily submit directly to us when you use our Platform. This may include information that you or your Psychologist provides to us when you create or set up an account or use our application, as well as settings that are automatically generated through your use.

5.2 We will tell you where you are required to provide us with certain personal information in order for us to provide you with features and functionality of the Applications. If you choose not to provide such information, we may not be able to provide those parts or functionalities of the Platform to you.

5.3 When you use the Platform, the categories of information we collect may include:

a) First and last name, e-mail address, gender, age, marital status, country of residence, telephone number (optional), location, alias and password.
b) Health data (results of initial health questionnaires and professional treatment).
c) Data of the associated professional psychologist; (identification data, member number, professional association, residence).
d) Usage data collected on the Platforms through cookies or other information collection files.

We use this information to provide you with the functionality of our application that makes up the Platform, and to provide user support.

The basis of legitimacy for the processing of personal data for registration as a user or as a therapist on our platform is the provision of our services on the basis of the contractual relationship between the Parties (Art. 6 para. 1 lit. b) of the GDPR).
The basis of legitimacy for the processing of your personal health-related data is based on the express consent given by you (Art. 6 para. 1 lit. a) of the GDPR).
The basis of legitimacy for the processing of data related to the use of the platform is based on our legitimate interest (Art. 6 para. 1 lit. f) of the GDPR).

5.4 At ifeel we employ artificial intelligence (AI) technologies as part of the triage process required to deliver our psychology services. This process uses advanced AI tools to analyze data provided by users through questionnaires, identifying relevant patterns and risks.

The results of this analysis allow us to assign the most appropriate therapeutic approach to the user, optimizing the quality of care provided and offering a more personalized experience. It is important for ifeel to emphasize that all final decisions on the most appropriate therapeutic approaches are reviewed and validated by our qualified clinical team.

AI serves only as an adjunct to professional human judgment, and no automated decisions are made without the supervision of our clinical team. This ensures that AI-generated recommendations are monitored and supplemented by our clinical team, thus ensuring an ethical and responsible approach in the delivery of our services.

By registering on our platform and accessing our services, you consent to the processing of your personal and health data through these technological tools, in accordance with the purposes described in our privacy policy.

The processing of your personal and health data through our AI solution is carried out in accordance with the General Data Protection Regulation (GDPR) and the Artificial Intelligence Regulation of the European Union.

We are committed to ensuring that our AI technology is used ethically, transparently and in strict compliance with applicable regulations. We conduct regular audits to ensure that the system is operating fairly, reliably and without bias.

If you have any questions about the use of artificial intelligence in our services or how your data is handled, please do not hesitate to contact us at [email protected].

6. Personal data of end users received from Google and Facebook.

If you choose to access our Platform through the website using the Google login tool, Google Ireland Limited will share with us your full name, email address, language preferences and profile picture for authentication purposes. By logging in to your Facebook account, you acknowledge and consent that by using this registration method, ifeel will have access to certain information from your Facebook account. For more information, please refer to the privacy terms of Google and Facebook.

7. How long we keep your personal information

We will generally store the personal information we collect about you for no longer than is necessary for the purposes described above, consistent with our legal obligations and legitimate business interests. However, we may need to retain your personal information for longer if we are required to do so by law. After the retention period, all personal data will be deleted or anonymized. We may anonymize and aggregate any personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes including testing our IT systems, research, data analysis, improving the Platform and our applications, and developing new products and features.

8. Recipients of personal information

In some cases, only when necessary, ifeel will provide user data to third parties. However, the data will never be sold. External service providers (e.g. hosting providers) with whom ifeel works, may use the data to provide the relevant services, but will not use this information for their own purposes or pass it on to third parties. Ifeel endeavors to ensure the security of personal data when it is sent outside the company and ensures that third party service providers respect confidentiality and have adequate measures in place to protect personal data. These third parties are obliged to ensure that the information is treated in accordance with data privacy regulations. For the provision of professional services, your data may be communicated, through the platform, to professional psychologists with whom ifeel maintains a business relationship, for the proper provision and care of services. In some cases, the law may require the disclosure of personal data to public bodies or other parties, only what is strictly necessary for the fulfillment of such legal obligations will be disclosed. They have been appointed as sub-processors by ifeel in accordance with Article 28 of the Regulation:

i) Amazon Web Services: For, among other things, the provision of infrastructure and platform services, computing capacity, storage and database services, security services and technical maintenance services, which we use to operate our solutions and thereby provide the service. Your information is stored on its servers located in Ireland (EU-West-1 Zone).

ii) Google Inc. (Gmail): For, among others, the management and resolution of technical issues and communications via e-mail.
iii) Zoom Video Communications: Provider of the video chat service on the platform.
iv) Stripe and Paypal: Payment service provider.

9. International data transfers

The information we collect from you may be processed in third countries, as understood in Article 44 of the GDPR. Some third countries, such as the United States, have not currently received an adequacy decision from the European Union under Article 45 of the GDPR, which means that your data may not receive the same level of protection there as under the GDPR. International data transfers are usually carried out on the basis of contractual or other rules provided for by law, which aim to ensure adequate protection of your data and which you can consult upon request. In doing so, we rely on the safeguards provided for in Article 46 of the GDPR or, where applicable, the provisions set out in Article 49 of the GDPR. We and our processors intend to apply appropriate safeguards to protect the privacy and security of your personal data. Therefore, we only process your personal data in accordance with the practices described in our Privacy Policy.

10. Exercise of your personal rights

According to the GDPR, you have certain rights when it comes to our processing of your personal data:

Right to be informed: You have the right to receive clear, transparent and easily understandable information about how we use your personal data and your rights.
Right of access: You have the right to obtain access to your personal data.
Right of rectification: You have the right to have your personal data rectified if it is inaccurate or incomplete.
Right of erasure: This right allows you to request the deletion or removal of your personal data when there is no compelling reason for us to continue to use it. This is not an absolute right of erasure and exceptions apply.
Right to restrict processing: You have the right to “block” or delete further use of your personal data. When you restrict processing, we may continue to store your personal data, but we may no longer use it.
Right to data portability: You have the right to obtain and reuse your personal data for your own purposes in different services.
Right to object to processing: You have the right to object to certain types of processing.
Right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority.
Right to withdraw consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time.
Right not to be subject to an automated decision: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal (or similarly significant) effects for you.

You may address your communications and exercise your rights by sending a written communication to the following e-mail address [email protected]. In some cases, the request may be denied if the deletion of data necessary for the fulfillment of legal obligations is requested.

11. Processing of personal data of minors

In principle, our services are not specifically directed to minors. However, in the event that any of them are aimed at minors under fourteen years of age, in accordance with Article 8 of the RGPD and Article 7 of the LO 3/2018, of December 5 (LOPDGDD), ifeel will require the valid, free, unequivocal, specific and informed consent of their legal guardians for the processing of the personal data of minors. In this case, the identity document or other form of identification of the person giving consent will be required. In the case of those over fourteen years of age, the data may be processed with the consent of the user, except in those cases in which the law requires the assistance of the holders of parental authority or guardianship.

12. Security measures applied to the processing of your data

We apply security measures to ensure the confidentiality, availability and resilience of personal data processing systems. Likewise, we carry out verification and evaluation processes of the technical and organizational measures implemented, in order to guarantee the security of personal data at all times.

13. Information on the use of AI

At ifeel we employ artificial intelligence (AI) technologies as part of the triage process necessary for the provision of our psychology services. This process uses advanced AI tools to analyze the data provided by users through questionnaires, identifying relevant patterns and risks. The results of this analysis allow us to assign the most appropriate therapy typology to the user, optimizing the quality of care provided and offering a more personalized experience.

It is important for ifeel to emphasize that all final decisions on therapist assignment are reviewed and validated by our qualified clinical team. AI acts only as an adjunct to human professional judgment, and no automated decisions are made without oversight from our clinical team. This ensures that AI-generated recommendations are monitored and supplemented by our clinical team, thus ensuring an ethical and responsible approach to the delivery of our services.

By registering on our platform and accessing our services, you agree that your personal and health data will be processed through these technological tools, in compliance with the purposes described in our privacy policy. The processing of your personal and health data through our AI solution is carried out in compliance with the General Data Protection Regulation (GDPR) and the Artificial Intelligence Regulation of the European Union.

If you have any questions about the use of artificial intelligence in our services or how your data is handled, please do not hesitate to contact us at [email protected].

14. Modification of the privacy policy

This privacy policy is subject to change. We recommend that you review the privacy policy from time to time.