Welcome to the MENDALITYs privacy policy. This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.mendality.com.
MENDALITY takes the privacy rights of all its clients seriously and adopts a high standard of compliance and confidentiality when dealing with your data. MENDALITY wants you to understand that this is a safe place for you to discuss your feelings and concerns and MENDALITY operates in a highly confidential environment.
This privacy policy aims to give you information on how MENDALITY collects and processes your personal
data through your use of this website, including any data you may provide through this website when you
purchase our services or any products or sign up to our newsletter.
This website is not intended for children, and we do not knowingly collect data relating to children via our
website.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal or sensitive data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
MENDALITY sole trader SAIRA KHAN is the data controller, and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
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.
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the
following ways:
Full name of legal entity: Dr Saira Khan
Email address: saira@mendality.com
Postal address: PO Box 70493, London W7 9EP
Telephone number: + 44 07860 710278
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.
We keep our privacy policy under regular review. This version was last updated in January 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
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:
We need to collect the following sensitive data about you if you are using our psychological services in order to comply with the standards for ethical practice set out by the Health and Care Professionals Council. Sensitive data includes information about your health, including information about your existing
and previous medical conditions, medication details, psychiatric history and any other relevant health information to enable us to carry out our services to you.
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have
to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at drsairakhan@protonmail.com . In case we need
to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted
by law.
We do not carry out automated decision making or any type of automated profiling.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from 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 aggregate your Usage Data
to calculate the percentage of users accessing a specific website feature. 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.
We do not collect any other 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 and genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.
If you fail to provide personal data
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 provide you with services or goods). In this case, we may have to
cancel a service or product you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal
data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get
your consent when collecting sensitive data (such as health information) and before sending third party
direct marketing communications to you via email or text message. You have the right to withdraw consent
to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data,
and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are
where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific
purpose for which we are using your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in
the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To provide our services and to
process and deliver any orders
including:
(a) provide our services to you
(b) Manage payments, fees and
charges
(c) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(f) Sensitive Data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to recover debts due to us)
(c) Explicit consent (in the case of
Sensitive Data).
To manage our relationship with
you which will include:
(a) Notifying you about changes
to our terms or privacy policy
(b) Asking you to leave a review
or take a survey owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(f) Sensitive Data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to recover debts due to us)
(c) Explicit consent (in the case of
Sensitive Data).
To enable you to partake in a
prize draw, competition or
complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to study how customers use our
products/services, to develop them and
grow our business)
To administer and protect our
business and this website
(including troubleshooting, data
analysis, testing, system
maintenance, support, reporting
and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests
(for running our business, provision of
administration and IT services, network
security, to prevent fraud and in the
context of a business reorganisation or
group restructuring exercise)
(b) Necessary to comply with a legal
obligation
To deliver relevant website
content and advertisements to
you and measure or understand
the effectiveness of the
advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to
study how customers use our
products/services, to develop them, to
grow our business and to inform our
marketing strategy)
To use data analytics to improve
our website, products/services,
marketing, customer relationships
and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products
and services, to keep our website updated and relevant, to develop our business and
to inform our marketing strategy)
To make suggestions and
recommendations to you about
goods or services that may be of
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
Necessary for our legitimate interests (to
develop our products/services and grow
our business)
Marketing
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
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 purchased goods or 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 contacting us.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
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.
We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.
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.
We may transfer your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
How long will you use my personal data for?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, 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.
