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This Privacy Policy outlines how TalaThrive Ltd (“TT”) collects and processes personal data when you access and use TT's platform (the "Services") via iOS or Android applications (the “Application”) or by visiting our website talathrive.com (the “Website”).
This document also outlines your rights and how they can be asserted. The terms and conditions for use of the Services are set out in the current Terms and Conditions.
When using the Services, TT is the data controller for the processing of your personal data. TT is processing personal data according to the General Data Protection Regulation (EU) 2016/679 (GDPR) as incorporated into domestic law of the United Kingdom, Data Protection Act 2018 and other applicable data protection regulation.
TalaThrive Ltd (Company Number: 14703044), 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
Your privacy and safety are of utmost importance to us. We strive to make our policies clear and understandable. We want you to feel secure about how we process your personal data. All treatment is strictly confidential and never under any circumstances are your communications with a Service Provider shared with an unauthorised party.
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. All information collected by TT through the Website or the Application will be governed by our most recent Privacy Policy, posted on the Website. If you have any queries, please contact us at support@talathrive.com.
TT has appointed Sonia Kaurah / Tala Thrive as Data Protection Officer (DPO). If you have any questions or complaints about our compliance with this Privacy Policy or how we process your personal data, please contact our DPO via email at support@talathrive.com.
TT needs a legal basis to process your data. We only collect and process data which is relevant and necessary to properly fulfil our purposes. For each purpose we state the personal data collected, the purpose(s) for processing, and the legal basis TT relies on.
Contact information
Health data
Information regarding your physical and mental health, collected by a Service Provider through meetings, registration forms, self-assessment forms, self-led programs in the Application and notes in your medical records. Images, videos and sounds shared during the use of the Services are neither recorded nor stored.
Payment information
Technical data
We aim to share our anonymised and aggregated insights with governmental bodies, academic partners and the general public, making sure that TT, together with you, can help improve mental healthcare for all.
Legal basis. The legal basis for this processing is the performance of a contract (UK GDPR Art. 6.1.b) and general legal obligation (UK GDPR Art. 6.1.c). Health data is processed with support of UK GDPR Art. 9.2.h and DPA 2018; health data collected through self-assessment forms is processed with your explicit consent (UK GDPR Art. 9.2.a).
We process contact information, technical data, cookie data and (with explicit consent) health data to contact you about your bookings, inform you of important changes, and, where you have consented, send you promotional emails and newsletters. You have the right to withdraw consent and opt out of any marketing communications at any time using the unsubscribe link in every message.
We process contact information, technical data, health data, customer service inquiry data and payment information to improve availability, user flows, video quality and the general experience, to analyse how wellbeing changes during treatment, and to resolve complaints. Any personal data processed for this purpose is always handled and stored unidentifiably through pseudonymisation, and aggregated so individuals cannot be identified.
This website stores a small amount of information on your device. You can review and change your advertising choice at any time using the “Cookie settings” link at the bottom of any page.
Essential
Required for the website to function. This covers the bot-protection check that guards our enquiry forms against automated abuse, and a record of the cookie choices you make, so that we do not ask you again on every page. These are always active.
Analytics
We use Google Analytics and PostHog to count visits and see which pages are read, so that we know what to improve. These run on every visit to this marketing website. We use the results for our own measurement and do not share them with advertisers.
Advertising
Only with your consent, we use the Meta pixel, which tells Meta Platforms (the operator of Facebook and Instagram) which pages you view on this website so that we can measure how our advertising performs. It is not loaded at all unless you accept it. You can withdraw your consent at any time through “Cookie settings”, which stops any further data being sent.
Third-party forms
Our newsletter sign-up forms are provided by Klaviyo and may set their own cookies when displayed. Subscribing to our newsletter is always your choice, and every message we send includes an unsubscribe link.
Your personal data is saved for as long as you still have your TT account. If your account is inactive for two (2) consecutive years, it is automatically erased along with some of your personal data. Some data may need to be retained to meet legal obligations:
Your personal data belongs to you. You have a right to obtain information on and determine how it is processed. A brief summary of your rights:
To exercise your rights, send a letter or email to support@talathrive.com including your name, address and phone number. We will respond without undue delay, at the latest within one (1) month of the request (extendable to two months for numerous or complex requests).
Your personal data may be shared, where necessary and under confidentiality, with: authorised TT employees involved in your treatment (analysts only access pseudonymised data); suppliers and subcontractors bound by the same confidentiality obligations; medical referrals agreed with your Service Provider; authorities where required by law or with your approval; and scientific research on an anonymised group level only.
Your medical record data will not be transferred to, or processed in, any country outside the EU/EEA or the UK. Where other personal data is transferred outside these areas, we take appropriate legal, technical and organisational measures to ensure an adequate level of protection in line with UK GDPR Chapter V.
We take all reasonable and appropriate technical, security and organisational measures, including, where appropriate, encryption, firewalls, secure facilities and access-rights systems, to protect against unauthorised access, alteration, disclosure or destruction of personal data. Should a security breach likely to result in a high risk to your rights occur, we will inform you without undue delay.
Our Services may contain links to third-party websites and services which are governed by their own privacy policies. This policy may be updated occasionally; minor changes are communicated through our Website and major changes through the Application, Website and email. We will not reduce your rights without providing you notice.
If you believe we have processed your personal data incorrectly, you have the right to contact and file a complaint with the Information Commissioner's Office (ico.org.uk).