Privacy Policy
Last updated 10/03/2023
Introduction
The services provided through the websitewww.mytherapist.gr, through the mobile application under the distinctive title/name “myTherapist”, as well as through any other medium bearing the distinctive title/name “myTherapist”, belong to the company “INOVAT PC”, hereinafter the “Company”, which has been incorporated and operates in accordance with the laws of Greece and is managed by it.
This personal data protection policy, hereinafter the “Policy”, applies to all “Users” who make use of the means provided by the Company. The term “Users” refers to clients, psychologists, and simple visitors of our platform. This Policy is governed by the provisions of the applicable legislation regarding the protection of personal data and by the decisions of the competent authorities.
The purpose of this Policy is to inform data subjects with regard to the EU General Data Protection Regulation 679/2016. The Company requires the “User’s” consent prior to the creation of the User’s personal account. Such consent constitutes consent for the collection and processing of Users’ personal data as described in this Policy.
This Policy concerns only the means provided by the Company and not third party websites and media to which links may exist. The Company bears no responsibility for the protection of personal data that you enter on third party websites, nor for the policy applied by such third parties.
Changes to the personal data protection policy
The Company reserves the right to amend/update this personal data protection policy, in whole or in part, at its sole discretion and at any time. Any amendment to this personal data protection policy shall take effect upon publication of the new version across all Company media and applications. For each amendment/update, the Company notifies Users by using at least one means, such as by sending an informational email, sending a relevant notification through the mobile application, posting a relevant notice on the website, or by any other means the Company may use. If the “User” continues to use the means provided by the Company following the above update, the User shall be deemed to have accepted such amendments.
Collection of personal data
The Company collects Users’ personal data for the purpose of ensuring the efficient operation of the platform and the Company’s means. By accepting this Policy, each “User” of the platform accepts the collection of the following data:
- For all Users, we collect the username/nickname, which is used to facilitate communication between Users.
- For all Users, we collect the email address for the creation and maintenance of a personal user account.
- For all Users, we collect the password, which is necessary for access to the personal user account.
- In the case of logging into the platform using access credentials from third party providers (e.g. Facebook, Google, Apple), we collect the declared username, the user image, as well as the email address, for access to the personal user account.
- For all Users, we collect the IP address, the device type, and the location, with the aim of providing an optimal user experience.
- For clients, we collect the first name, last name, and address. Such details are stored in the Company’s systems and are used for the issuance of lawful tax documents (receipts for services).
- For clients, we collect contact details of a person close to them, an “emergency contact”. These details, as entered by the client, are used by the client’s psychologist only in emergency situations (for example, suicidal ideation).
- The Company may use remarketing techniques. For example, it may use Google and Facebook Ads for Conversion Tracking. In such case, through tracking we collect information regarding the locations visited by the User, the User’s preferences, etc.
- For psychologists, we collect first name, last name, contact details (for example, contact phone number and email), a copy of identity card or passport, Tax Identification Number (VAT), a copy of the license to practice the profession of psychologist, a supervision certificate, a psychotherapy training certificate, and CV details such as a short description, image, specialization, seminars, etc. The above list of data collected for psychologists is indicative and not exhaustive, and the Company may at any time request additional information from each psychologist, with the aim of effectively carrying out corporate processes. All of the above data are collected in order to enable communication with psychologists who express interest in cooperating with the Company, to enable the conclusion of cooperation with psychologists, to enable the Company’s communication with psychologists, to enable the assessment of psychologists’ qualifications, and to inform clients.
It is clarified that, with respect to the electronic payments process, the Company does not store data. All data collected from Users are stored and processed on Stripe’s secure infrastructure. With respect to the terms of use and the data protection policy related to payments, you may refer to the relevant Stripe terms of use page (https://www.stripe.com/en-gr/privacy).
Mandatory provision of personal data
The provision of Users’ personal data is mandatory, as failure to provide such data prevents the proper provision of the offered services.
Disclosure and availability of personal data
Recipients of the personal data of registered Users are the Company and the psychologist(s) with whom the User has been connected. Recipient of the personal data of visitors(not registered users) and psychologists is the Company.
We do not transfer Users’ personal data to third parties, except to the Company’s employees and partners who are responsible for providing specific services, and always under conditions that fully ensure that Users’ personal data are not subject to any unlawful processing. All third party providers with whom the Company cooperates (third party companies, applications, or persons), such as payment service providers, telecommunications service providers, infrastructure service providers, etc., are bound to use the data we transfer to them only for the purpose for which they were provided, and to ensure that any processing they perform is lawful and complies with the provisions of the applicable personal data legislation as defined by Greek and European law. Finally, part of Users’ data (behavioral data, tracking data) may be transferred to advertising platforms (e.g. Google, Facebook, etc.) for statistical purposes.
In any case, the Company does not sell, transfer, or disclose Users’ personal data to third parties, with the exception of the above cases, without the User’s explicit consent. An exception applies in the case of compliance with relevant legal requirements, such as search warrants, court subpoenas, etc.
Why we use your personal data
The Company collects, stores, and processes the minimum and strictly necessary personal data. In particular, we use Users’ personal data for the following purposes:
- For your registration on the platform and the provision of services.
- For invoicing purposes in relation to the provided services.
- For customer service purposes (e.g. telephone or online support).
- For security purposes.
- For statistical purposes.
- In order to improve the provided services and the platform.
- For promotional purposes (for example, sending informational emails/SMS, etc.).
- To inform Users on matters related to mental health.
- For cases where the processing of your personal data is necessary for the protection of the Company’s legitimate interests and for the Company’s compliance with national and/or European legislation.
For how long we retain and/or process your personal data
Users’ personal data are retained for as long as the User uses the Company’s means without deleting the User’s personal account. In the event of a request for permanent deletion from the platform, the Company will delete all data within the period prescribed by Regulation (EU) 2016/679. For promotional activities (for example, emails/SMS), we retain Users’ personal data until the User states that they do not wish to receive updates. Specifically for psychologists, we may retain their data even after deletion of their account, if there are tax or legal reasons.
Protection of your personal data
The Company is committed to protecting Users’ personal data and managing them securely. Access to Users’ personal data is granted only to specific authorized personnel of the Company through the use of secure access codes. The Company takes all necessary organizational and technical measures required to prevent potential loss, unauthorized access, disclosure, alteration, or destruction of Users’ data. Access to Users’ personal data is restricted solely to authorized persons for the specific purposes, and unauthorized access is monitored and detected through the Company’s systems. Finally, the Company has established procedures to address any security breach incidents.
Users’ rights in relation to their personal data
According to Regulation (EU) 2016/679, the User may exercise the following rights:
- Right of access to personal data, so that the User can learn which data we process, for what purpose we process them, and the recipients of the data.
- Right to rectification of personal data, so that the User can correct any inaccurate data.
- Right to erasure, the right to be forgotten, so that the User may request deletion of data, under specific conditions and in accordance with the applicable personal data protection legislation.
- Right to restriction of processing of personal data, under specific conditions and in accordance with the applicable personal data protection legislation.
- Right to data portability, so that we can provide the personal data to the User and the User may use them elsewhere.
- Right to object to the processing of personal data, so that the User may object to the processing of their personal data.
- Right to withdraw consent, so that the User may withdraw their consent for the use of part or all of their personal data, without affecting the lawfulness of processing for the period prior to the withdrawal of consent.
- Right to lodge a complaint, so that the User may submit a complaint to the competent Greek independent authority, in the event of an alleged breach of the personal data rules concerning the User. The Hellenic Data Protection Authority accepts the submission of relevant complaints either in writing to its protocol office (Kifisias 1 to 3, P.C. 115 23, Athens) or electronically (https://www.dpa.gr/).
If the User withdraws their consent for the use or disclosure of their personal data, the User’s access to the website, the platform, and all Company means may be withdrawn, as we may not be able to provide our services. In certain cases, we may continue to process the User’s information after the User withdraws consent if there is a legal basis for doing so, or if the withdrawal of consent was limited to specific processing activities.
To exercise their rights and for any question regarding their personal data, the User may contact the Company. The Company will make every possible effort to respond to each request within thirty days from receipt of the request. The Company reserves the right not to satisfy a request if it is deemed unfounded or excessive, informing the User of the reasons for not satisfying it.
Use of cookies
What cookies are?
“Cookies” are small text files stored on the User’s device when visiting a website. The information stored on the User’s device may include details such as which pages were visited, the date and time of the visit, etc. Cookies do not contain personal information, such as a telephone number, full name, etc., and in no case can we reveal the User’s personal identity from cookie information. In addition, the use of cookies does not provide access to files on the User’s computer.
Through the use of cookies, our Website is able to store useful browsing information and read such information in order to provide the User with an optimal browsing experience and the effective operation of our website. Cookies help us monitor the performance and traffic of our website (for example through Google Analytics, etc.) and to improve its presentation and content in accordance with Users’ preferences. Cookies are also used for the promotion of advertising messages or targeted actions.
Which cookies do we use on our website
In general, the following categories of cookies are used across the Company’s means.
Necessary cookies
Necessary cookies are vital for the proper operation of the means and allow the User to use all provided functionalities. These cookies do not recognize individual identity. Without these cookies, we cannot offer effective and proper operation.
Functionality and preference cookies
These cookies allow our means to remember the User’s choices such as language, or region, in order to provide improved and personalized functionalities. The information collected by these cookies may be anonymized. If you do not accept these cookies, the performance and functionality of the means may be affected and your access may be restricted.
Performance and statistical cookies
These cookies collect information about how Users use our means, for example, which pages they visit most often and whether they receive error messages from web pages. These cookies collect aggregated, anonymous information that does not identify any visitor. They are used to improve performance and for statistical purposes.
Marketing cookies
These cookies are used to provide content that is more relevant to the User and the User’s interests. They may be used to deliver targeted advertising/offers or to measure the effectiveness of an advertising campaign. These cookies may be used to remember the websites you have visited in order to determine which online marketing channels are most effective, and they allow us to reward external websites and partners that referred you to us.
Cookie control and settings
The User may configure their browser so that it either warns them about the use of cookies or does not allow the acceptance of cookies under any circumstances. If the User does not wish to use cookies, they may not be able to access these services further, or they may access them without the proper functioning of our services. Finally, it is at the User’s discretion to control and/or delete cookies from their computer or device.
Contact
If you have any questions or need clarifications, please contact our Company at info[at]mytherapist.gr.