1.  INTRODUCTION

Welcome to the Plumm Privacy Policy.

Plumm Health Ltd (“Plumm”) takes your privacy very seriously. This document is our "Privacy Policy" and it contains details on issues related to your privacy when using our services. It is intended to inform you of our policies, procedures, and practices regarding the collection, use, and disclosure of any information that you provide through the Platform or in the course of the Therapy Services. This Privacy Policy has been prepared in line with the relevant regulations and legislation such as the General Data Protection Regulation (GDPR).

The Platform and Therapy Services are not intended for children and we do not knowingly collect data relating to children.

The Privacy Policy is part of our Terms of Use which can be found on our website. The defined terms in the Privacy Policy (such as, but not limited to, “Plumm”, "we", "our", “us", "Platform", “Therapist", "Therapy Services" etc.) have the same meaning as in our Terms of Use document. When you use our Platform you accept and agree to both the Terms of Use and to the Privacy Policy. If you do not agree to be bound to the Privacy Policy you should stop using the Platform immediately. By accessing and using our Platform you affirm that you have read the Terms of Use and the Privacy Policy and that you understand, agree and acknowledge to all the terms contained in both of them.

We are the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Protecting your personal data is a top priority for us. We will never sell or rent any personal data you shared in the Platform. Other than in the limited ways detailed in this Privacy Policy, we will never use or disclose any of your personal data unless you specifically and explicitly requested or approved us to do so.

There are certain situations in which we may share access to your personal data without your explicit consent; for example, if required by law, to protect the life of an individual, or to comply with any valid legal process, government request, rule or regulation.

2.  WHAT PERSONAL DATA WE COLLECT

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
  2. Contact Data includes address, email address and telephone numbers.
  3. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Platform.
  4. Profile Data includes your username and password and Session bookings made by you.
  5. Usage Data includes information about how you use our Platform and the Therapy Services.
  6. Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  7. Therapy Background Data includes information you choose to give us to enable us to find a Therapist, at your request.
  8. Therapy Session Data includes any information you share in a Therapy Session.

If you are a Therapist, we may also collect, use, store and transfer additional types of personal data which we have grouped together as follows:

  • Financial Data includes bank account details.
  • Transaction Data includes details about payments to and from you.
  • Qualification Data includes your professional qualifications and experience.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from any of your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may keep an anonymous, aggregated record of the number of Therapy Sessions used from an allowance purchased by a particular employer so that we can share this with the employer without revealing who has been using the Therapy Sessions. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Other than any information you choose to share with us as Therapy Background Data and Therapy Session Data, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to arrange the Therapy Services). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

You should not supply any other person's personal data to us unless you have their permission and you are responsible for any data protection, confidentiality or privacy implications of doing so.

We ensure that we collect and manage your personal data transparently, fairly and securely. Whenever we collect Information from you we make sure that we do so transparently, and you will always be able to access the following information from us

  • data we have collected from you
  • the basis on which we are holding it (e.g. because you gave us consent)
  • what we will do with it
  • how long we will hold it for
  • where it is stored
  • who it might be shared with
  • your rights in relation to the data, and
  • information on how you can access and manage this data.
3.  HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Therapy Background, Therapy Session and (where relevant) Financial and Qualifications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
    • apply for our products or services;
    • create an account on our Platform;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie information (section 15, below) for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • analytics providers such as Google; and
      • advertising/affiliate networks.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    • Qualifications Data from publicly available sources. from the therapists directly or from third party referees (where relevant).
4.  HOW WE USE YOUR PERSONAL DATA

CLIENTS

We use your personal data for the below purposes. We have also indicated the type of personal data and the lawful basis we rely on. For more detail on the different lawful bases, see below.

  1. To create your account on our Platform and let you log in to your account and use the Platform (we use Identity and Contact data and our lawful basis is the performance of a contract with you).
  2. To manage your account, provide you with customer support, and ensure you are receiving quality service (we use Identity and Contact data and our lawful basis is the performance of a contract with you).
  3. To contact you or provide you with information, alerts, and suggestions that are related to the service (we use Identity, Contact, Technical, Usage, Profile and Marketing data and our lawful bases are (a) the performance of a contract with you; and (b) this is necessary for our legitimate interests to develop our products and services).
  4. To send you email reminders prior to your scheduled sessions (we use Identity, Contact and Profile data and our lawful basis is the performance of a contract with you).
  5. To match and connect you with a Therapist (we use Identity, Contact, Profile, Therapy Background and Therapy Session data and our lawful basis is the performance of a contract with you).
  6. To enable and facilitate the Therapy Services (we use Identity, Contact, Profile, Technical, Usage, Therapy Background and Therapy Session data and our lawful basis is the performance of a contract with you).
  7. To supervise, administer and monitor the services (we use Identity, Contact, Technical and Usage data and our lawful bases are (a) performance of a contract with you; and (b) our legitimate interest in running our business).
  8. To measure and improve the quality, the effectiveness and the delivery of our services (we use Identity, Contact, Technical, Profile and Usage data and our lawful basis is our legitimate interest in monitoring and improving our services).
  9. To provide you with more information about our platform including sending email newsletters, social media marketing, communicating promotions and offers (we use Identity, Contact and Marketing data and our lawful basis is that this is necessary for our legitimate interests to develop our products and services and grow our business).
  10. To send weekly newsletters and occasional ad-hoc emails for promotions and feature updates (we use Identity, Contact and Marketing data and our lawful basis is that this is necessary for our legitimate interests to develop our products and services and grow our business).
  11. To reach out to you, either ourselves or using the appropriate authorities, if either we or a therapist have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act (we may use Identity, Contact, Profile, Usage Therapy Background and Therapy Session data and our lawful basis would be that this is necessary for the protection of your vital interests or the vital interests of another person).
  12. To support the administration of our business including in the exercise or defence of legal claims (we may use any of the personal data and our lawful basis is that this is necessary for our legitimate interests in administrative record keeping, processing transactions and maintaining business records or for the protection and assertion of our legal rights).

THERAPISTS

If you are a Therapist, in addition to the purposes set out above for clients, we collect your personal data for the below-mentioned purposes:

  • To verify your suitability to deliver Therapy Services (we use Identity, Contact and Qualifications data and our lawful bases are (a) performance of a contract with you; and (b) our legitimate interest in working with appropriately qualified Therapists).
  • To send billing-related and payment-related information (we use Identity, Contact, Profile and Financial data and our lawful basis is performance of a contract with you).
  • To match and connect you with a Client (we use Identity, Contact and Qualifications data and our lawful bases are (a) performance of a contract with you; and (b) our legitimate interest in providing services to Clients).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or requested services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out above.

  • Other companies in the Plumm Group who may provide IT and system administration services and undertake leadership reporting.
  • The following external third parties:
    • Service providers acting as processors who provide IT and system administration services.
    • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
    • Specific third parties listed in section 4 (How We Use Your Personal Data) above such as Therapists acting as independent controllers who provide the Therapy Sessions directly to you (where you are a Client booking Therapy Sessions).
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS

We may transfer personal data to a country outside of the UK, for example if a Therapist is located outside of the UK or if a third party we share data with has servers located outside of the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7.  KEEPING YOUR DATA SECURE

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

  • We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8.  DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see section 10 (“Your rights”) below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.  LINKS

The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an authorization, representation or endorsement of our affiliation or association with that third party, nor is it an endorsement of their information or privacy or security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use or agreements that you may enter into with them.

10.  YOUR RIGHTS

Here is a list of the right you have as a user in regards to your Information on our Platform:

  1. the right to be informed about the collection and use of your personal data
  2. the right of access to your personal data and any supplementary information
  3. the right to have any errors in your personal data rectified
  4. the right to have your personal data erased
  5. the right to block or suppressing the processing of your personal data
  6. the right to move, copy or transfer your personal data from one IT environment to another
  7. the right to object the processing of your personal data in certain circumstances, and
  8. rights related to automated decision-making (i.e. where no humans are involved) and profiling (i.e. where certain personal data is processed to evaluate an individual).

If you wish to exercise any of these rights, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11.  CHANGES TO PRIVACY POLICY

Plumm may revise this Privacy Policy from time-to-time. Any revised Privacy Policy will apply to the use of the Platform and Therapy Services from the date of the publication of the revised Privacy Policy on this website. Please check this page regularly to ensure you are familiar with the most current version. Plumm is not obligated to update you on variations of this Privacy Policy and you agree to regularly check this page to ensure that you are up-to-date with our policies, and terms at all times.

12.   LAW ENFORCEMENT AND COMPLIANCE WITH LAWS

Plumm cooperates with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process including but not limited to subpoenas, and to prevent or stop an activity that may be illegal or dangerous or unethical. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment. In addition, you should be aware that Therapists may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities.

13.  CONTACT US

We are Plumm Health Ltd and our address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, England. If you would like to get in touch about anything in this policy or about your personal data then please contact Nabil Ismail, our Data Protection Officer at nabil@plummhealth.com.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you are in a crisis or any other person may be in danger - please don't use this site. Kindly Contact your Local Emergency Helpline immediately.

This Agreement was last updated on 17th December 2021.