Privacy Policy

 

This Privacy Policy outlines how your Personal Data may be collected, used and disclosed by Digital Mind Solutions, S.L. (“Ifeel”) and how you can access to them. Please read it carefully.

 

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 5 December 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 the use of the 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.
  • Registered office: Calle Goya 115, 28009, Madrid, Spain.
  • 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: info@ifeelonline.com
 

1. Key Privacy Policy Principles

Ifeel’s privacy practices comply with the GDPR, which includes the following protections:

  • Treat your Personal Data in a lawful, transparent and fair basis.
  • Limit the use of your Personal Data for legitimate purposes.
  • Limit the processing and storage of your Personal Data to the minimum necessary.
  • Ensure that the privacy notice is accurate and sufficient.
  • Maintain open and transparent privacy policies.
  • Assume responsibility towards you regarding the processing of your Personal Data.
  • Ensure that your consent is informed and easy to withdraw.
  • Define and protect your sensitive/special data categories.
  • Ensure that third parties (external professionals and/or chartered psychologists) apply similar or equivalent standards of privacy controls when processing your Personal Data on our behalf.
  • Not to transfer your Personal Data outside the EU unless the recipient has provided adequate safeguards approved by the GDPR.
  • Provide you with the right to accurate, timely and complete information regarding our processing of your Personal Data.
  • Provide you with the right to rectify incomplete, inaccurate, unnecessary or excessive Personal Data.
  • Provide you with the right to object (where applicable).
  • Ensure that we have procedures in place to support the exercise of any of the data subjects’ rights.
  • Implement security measures, including technical and procedural support for integrity, confidentiality and availability.
  • Maintain the confidentiality of your Personal Data even after our relationship with you has ended. 

2. What Personal Data is collected?

Personal Data” means any information relating to an identified or identifiable natural person (hereinafter, the “Data Subject“). An identifiable natural person is one who can be identified, directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more factors that are specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

Health-Related Data” or “Health Data” means Personal Data relating to the physical or mental health of a natural person, including the provision of health care services, that reveals information about that natural person’s health status.

 

Together and unless expressly differentiated “Personal Data“.

 

Ifeel only collects Personal Data that is relevant and necessary for the provision of the Services.

 

2.1. Personal Data that you provide to ifeel during registration

When you access and register on the Platform we collect identification and contact information about you (email address, gender, marital status, country of residence, telephone number -optional-, location, alias and your password).

 

If you do not provide this information, you will not be able to register and, consequently, we will not be able to provide you with our healthcare services through the Platform.

 

2.2. Personal data you provide to Ifeel during the provision of services

During the provision of the services Ifeel will collect your Personal Data.

 

Emails and other communications between you and Ifeel and/or Ifeel’s service providers will not be recorded; in no case will telephone calls, video conferences, images of the video conference be recorded and you will not be able to record them.

 

2.3. Personal data collected from you by Ifeel from third parties

In connection with the provision of the services and in any case with your prior authorization, Ifeel may obtain Personal Data about you from your treating therapist.

 

Also, Personal Data may be collected as long as (i) it is necessary for the provision of services, (ii) there is a legal obligation or (iii) there is another cause that legitimizes the realization of such communication.

 

2.4. Personal Data that Ifeel shares with third parties

Likewise, Ifeel may share your data with third parties such as, but not limited to, banking institutions, necessary for the purposes of their contractual relationship for the contracting of the service as well as for such companies to comply with their legal obligations; however, in no case will ifeel share with such entities part or all of your medical history.

 

3. Purposes for which your personal data is processed and legal basis

Ifeel collects, processes and potentially discloses your Personal Data as set out below for the purpose of providing you with the services requested by you and, therefore, subject to your informed consent, compliance with legal obligations and carrying out surveys.

 

Ifeel may generate de-identified information, i.e., data that does not include your name, address, date of birth or other information that can be used to identify you (hereinafter, the “Anonymized Data“) for the purposes of:

 

  • Reviewing or evaluating the performance of our systems in providing the Services.
  • Improve the quality or timeliness of our services.
  • Medical and/or academic research.
  • To demonstrate the reliability of our information management.

4. Data Retention

Ifeel will retain your Personal Data for as long as it is necessary for the provision of the services and, after that, for the legal periods exclusively for the purpose of meeting any liabilities that may arise from the provision of the services.

 

At the end of that retention period, your Personal Data is either securely destroyed or permanently anonymized in accordance with the Data Protection Regulation. Such permanently anonymized data ceases to be Personal Data and Ifeel retains it indefinitely for the purposes set out in point 4 above.

 

5. Access to your Personal Data

We will never share your Personal Data for any purpose that is not strictly necessary to provide the services for your benefit.

 

For that reason, healthcare professionals contracted by Ifeel will be able to consult and receive your Personal Data.

 

Our technology service providers (e.g. the hosting company) may also have access to your Personal Data for the sole purpose of providing the contracted service.

 

Please be aware that any duly authorized public body or court in any country of citizenship of our patients may require Ifeel to disclose your Personal Data, including your Health Data.

 

Also, some of your Personal Data may be communicated to or shared with banking entities, based on the contract you have made for the product, for the purposes of the execution of the referred contract, management of claims and procedures, management, control and analysis of the use of the Platform and the services, management of the quality of the services and compliance with legal obligations.

 

Ifeel restricts access to information about you to those employees who need to know that information as part of their job responsibilities. We also educate our employees about the importance of customer confidentiality and privacy through various operating procedures, special training programs and our code of conduct. We also take appropriate disciplinary action to enforce employees’ privacy responsibilities. We have developed compliant procedures to ensure the security and confidentiality of customer records and information, to protect against any anticipated threat or danger to the security or integrity of such records, and to protect against unauthorized access to or use of such records or information that could result in substantial harm or inconvenience to our customers or our employees.

 

 

6. International transfers of your Personal Data

No international transfers of your Personal Data are planned.

 

However, it is likely that, in order to provide services to you, we will transfer your Personal Data to psychologists located in another country.

 

You are made aware, and you accept, that the local data protection regulations applicable to the processing of your Personal Data in that third country or region may not provide a similar level of protection to that afforded by the Data Protection Regulations in the country from which it originates.

 

Nevertheless, we insist that the professionals we hire to provide support services to Ifeel comply with our privacy policy and principles, as well as with all applicable data protection laws and regulations worldwide.

 

7. Security Enforcement

 

We protect your personal data with tested and certified technical and organizational security controls in accordance with the Data Protection Regulation.

 

Our staff and external professionals receive training on our privacy policy and principles, as well as on the Data Protection Regulation.

 

8. Your rights as a user

We strive to keep your Personal Information accurate and up to date and will update or disclose it at your request.

You are responsible for informing us of any changes, corrections or additions to your Personal Data so that Ifeel can modify it accordingly and keep it up to date.

 

You can access the Personal Data we hold about You and correct or delete it if it is incorrect.

 

When the Data Protection Regulation applies, you are entitled to a number of rights, namely:

 

  • Right of access: the right to ask Ifeel for a copy of your Personal Data.
  • Right of rectification: the right to request Ifeel to rectify the Personal Data that you consider inaccurate. You also have the right to ask Ifeel to complete the information that you consider incomplete.
  • Right to withdraw your consent to the processing of your Health Data.
  • Right to erasure: the right to request Ifeel to delete your Personal Data in certain circumstances.
  • Right to restrict processing: the right to request Ifeel to restrict the processing of your Personal Data in certain circumstances.
  • Right to object to processing: the right to object to the processing of your Personal Data in certain circumstances.
  • Right to data portability: the right to request that Ifeel transfer the information you provided to another organization, or to you, in certain circumstances.

Note that the rights of data subjects do not apply to anonymized data.

 

You may exercise your rights as a Data Subject by sending an email to support@ifeelonline.com with your name, the service used and your telephone number, and attaching your identification document or any other document that allows us to identify you.

 

9. Contacting Us for Additional Information

If you have any questions regarding this Privacy Policy, would like a copy of this Privacy Policy, would like to file a complaint or believe your privacy rights have been violated, you may contact the data protection officer at support@ifeelonline.com. There will be no retaliation for filing a complaint or exercising your data subjects’ rights.

 

You also have the right to lodge a complaint with your local data protection authority: https://www.aepd.es/es.

 
Last update: MaRCH 1st, 2022