Privacy Policy

App and platform

Last updated: 19.08.2021

Your privacy is one of our fundamental commitments, and therefore, we take utmost care to process your personal data in accordance with the principles set forth in the applicable legislation, including without limitation the General Data Protection Regulation no. 679/2016 (“GDPR”). We recognize the importance of maintaining the confidentiality, integrity and security of your personal information ("Personal Data") and have written this privacy policy (“Policy”) to explain how your Personal Data is collected, stored, used and disclosed by Ascendio TechVision S.R.L., a company incorporated under the Romanian law, having its headquarters at 202K Splaiul Independentei, Bldg. B3, Entr. B, 4th floor, suite 26, District 6, Bucharest, Romania, sole identification number 38091006, registered with the Trade Registry under no. J40/14259/2017 ("Ascendio", "Us"), as a data controller, with respect to (i) your access to and use of our application („App”), (ii) the access to, and use of our therapist platform available at the URL https://specialist.im-fine.app („Platform”), (iii) the access to, and use of our web database of healthcare professionals (as defined below) available at the URL https://im-fine.app/ro/psihologi-psihoterapeuti (“Web Database”), (iv) the access to, and use of our clinic platform available at the URL http://clinic.im-fine.app/ (“Clinic Platform”), (v) and the access to, and use of the content of the App, the Platform and the Web Database including of the services provided by Ascendio (collectively, “Services”).

Each time we are required by the applicable law or, otherwise, want to use this legal basis, we will request your free, informed, specific and unequivocal consent for the processing of your Personal Data. By expressing your consent, you agree that we can collect, use, reveal, process and transfer your Personal Data in accordance with this Policy.

We reserve the right to amend the provisions of this Policy from time to time. If we make changes to this Policy, we will make the updated version available on the App and on the Platform and we will update the "Last updated” date. We will also inform you on the changes that have occurred, to ensure that you are aware of how we use your Personal Data. Any amendments to this Policy will apply on the date that they are made, with the exception of changes which require your prior consent, and which will apply as of the moment when you express such consent.

For the avoidance of any doubt, we are not obliged to inform you, by using the contact details associated with your account and use of the App or of the Platform , in respect to any and all of the changes to this Policy.

Any capitalized term which is not defined in this Policy will have the meaning set forth in the terms and conditions (“Terms”) applicable to the App, the Platform and the Web Database accessible here [https://im-fine.app/legal/platform/terms-and-conditions.html]. In this Policy, the term “App User” shall mean the person installing and using the App and also the User using the Platformand the Web Database User shall mean the person using the Web Database in order to make an appointment with a Medical Professional.

• APPLICABILITY

This Policy applies strictly to the processing of Personal Data carried out by Ascendio as a data controller.

For the avoidance of doubt, this Policy does not apply to the processing of Personal Data performed by Ascendio as a data processor.

• CATEGORIES OF PERSONAL DATA, PURPOSES OF PROCESSING, AND LEGAL GROUNDS

• APP USERS

• Start using the App

When you start using the App, we might collect your nickname, gender and age range, preferred language, city on which you want to see therapists

• Registration and using the App account

• Registration directly on our App and login in with the App credentials

On our App you can register and create an account. This functionality allows you to use your account on different devices on which you install the App. In this case, we will need your email address.

• Registration and log in with Google or Apple accounts

Google

The App also offers you the possibility to register using your Google access. Before registering, you are led to a Google page where you can log in using your Google username and password. As a consequence, the App will be connected to your Google profile. The connection automatically causes the App to receive from Google the information you agreed to: email, first name, last name, profile picture. This information will be processed by us in order to offer you the possibility of creating the account and to the extent necessary to identify you in the context of the features offered by the App and to offer you the various features on our App. In addition, you can connect with and grant access to your Google Calendar. For Google Calendar synchronization, we read your Google Calendar ID, Google user ID and your personal calendar list to help you choose what calendar/s you want us to import events from.

We are not responsible for the processing by Google of your Personal Data. For further information about Google privacy settings, please refer to Google’s privacy policy.

Apple

The App also offers you the possibility to register using your Apple access. Before registering, you are led to an Apple page where you can log in using your Apple username and password. As a consequence, the App will be connected to your Apple profile. The connection automatically causes the App to receive from Apple the information you agreed to: Apple ID, email, first name, last name. This information will be processed by us in order to offer you the possibility of creating the account and to the extent necessary to identify you in the context of the features offered by the App and to offer you the various features on our App.

We are not responsible for the processing by Apple of your Personal Data. For further information about Apple privacy settings, please refer to Apple’s privacy policy.

• Adding information to your App profile

Once you have completed the setting up process, you can fill in other details about you in order to complete your profile: nickname, image.  

• Wellness information

Our Services are designed to provide tools for you to use to reduce stress, anxiety, and depression. In order to improve the value of the Services for you, we may give you the option of providing certain information about your mood and goals for using the Services when you register and as you use the Services. We may also give you the option to let us know whether you are working with a mental health professional. We refer to this information, together with any other information about your goals, mood, health habits, thoughts, and any responses to behavioral health assessments as wellness information (“Wellness Information”).

Providing us with Wellness Information is always optional. You can refuse to provide any or all of such information to us. But providing us Wellness Information can help us tailor our Services to you and make them more effective.

• Searching for a Medical Professional

When using our App, you have the possibility to search for a Medical Professional. In such a case, we will use the location, the age range, and any other relevant Wellness Information you provided during the usage of our App.

• Connecting with a Medical Professional

When using our App, you have the possibility to connect with a Medical Professional. In such a case, we will your nickname, e-mail address, age, gender and preferred language. This Personal Data shall be made available to the Medical Professional.

In addition, when connecting with a Medical Professional you may choose to book a session with the Medical Profession. Also, you can choose to share the Wellness Information and other Personal Data with the respective Medical Professional, pursuant to section 2.8. below.

• Sharing Wellness information with a Medical Professional

When connecting with a Medical Professional you may choose to share the Wellness Information and other Personal Data with the respective Medical Professional.

• Review a Medical Professional

On our App, you have the possibility to review and/or rate a Medical Professional either as an anonymous user or as yourself. In such a case, we will use your nickname and image which, in case you consent, be displayed in your review and/or rating.

• Sharing information with other App Users

You may be able to share information with third parties, including other App Users and with other services, through use of the Services.

Our Services provide social networking features that allow you to share information with other App Users through message boards and chat groups. Any information you share through our social networking features will be made available to all App Users of our Services. We cannot control how our other App Users will use this information. We strongly recommend that you think carefully about what information you provide through our social networking features. For example, please do not share any information that other App Users could use to identify you personally, such as your real name, email address, telephone number, or social security number. You are welcome to share Wellness Information through the social networking features of our Services. But remember that any such information will be available to all of our other App Users who will be free to use it in any way they desire.

You may also be able to use the Services to share information, including Personal Data, with third-party services. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

• Research purposes

In case you consent to the anonymization of your Personal Data, we might use the Wellness Information for research purposes. In such a case, before using this data we shall anonymize the Personal Data and the research shall be performed on anonymous information.

• Contractual notifications

During the provision of our services, we will use your email address and your phone number to notify you of any changes in the Terms of the App and in connection with any other issues related to the performance of the contract between you and Ascendio.

• Contact

You can contact us in different ways: by support form, by e-mail, or, if the case might be, by using our chat. In this case, in general, we will process the following Personal Data: first name, last name, email and any other information you voluntarily provide when you contact us.

• Marketing messages

You can opt in to receive marketing messages via email or push notification.

You can revoke your prior consent at all times and without any costs, with altering consequences for the future.

• Analytical data

When using our App, we process certain information regarding your activity in order to analyze the use of our App. Such information includes, for example, your navigation.

This information is not collected in order to be associated with identified persons. However, insofar such information leads to the identification of an App User, the provisions of this Policy shall become applicable.

• WEB DATABASE USERS

• Book a session with a Medical Professional using the Web Database

On the Platform, you have the possibility to book a session with a Medical Professional. In such a case, we will need your name, telephone number and meeting details. This Personal Data shall be made available to the Medical Professional.

• MEDICAL PROFESSIONALS

• Registration on our Platform and Web Database

On our Platform you can register as a Medical Professional and create an account. In this case, we will need your first name, last name, phone number, email address, education (studies, certifications). In addition, optionally you can also indicate your experience, spoken languages, personal description, Skype ID, facebook page URL, LinkedIn page URL, website, location and working hours, supplied services.

When you create an account on our Platform, we need to validate your account and your profile. For this purpose, we will verify the information you have provided during the onboarding process.

All the profile information shall be publicly available to any user accessing and navigating on the App and Web Database.

• Adding information to your profile

During the onboarding process or once you have completed the onboarding process and created your account, you can fill in other details about you in order to complete your profile (either additional information or skipped information during the onboarding process): your image, your telephone number, medical office address, personal description, experience, spoken languages, fee range, specialization.

All the profile information shall be publicly available to any user accessing and navigating on the App and Web Database.

• Log in with Google account

The Platform also offers you the possibility to register using your Google access. Before registering, you are led to a Google page where you can log in using your Google username and password. As a consequence, the Platform will be connected to your Google profile. The connection automatically causes the Platform to receive from Google the information you agreed to: email, first name, last name, profile picture. This information will be processed by us in order to offer you the possibility of creating the account and to the extent necessary to identify you in the context of the features offered by the Platform and to offer you the various features on our Platform. In addition, you can connect with and grant access to your Google Calendar. For Google Calendar synchronization, we read your Google Calendar ID, Google user ID and your personal calendar list to help you choose what calendar/s you want us to import events from.

We are not responsible for the processing by Google of your Personal Data. For further information about Google privacy settings, please refer to Google’s privacy policy.

• Invoicing

When using our Platform, we will issue invoices for the subscription fee. In this case, we will process your first name, last name and address.

• Payments and bank cards

When you pay the subscription fee, we will process your bank card details (first and last name, card number, CCV, expiring date).

• Contractual notifications

During the provision of our services, we will use your email address and your phone number to notify you of any changes in the Terms and in connection with any other issues related to the performance of the contract between you and Ascendio.

• Contact

You can contact us in different ways: by support form, by e-mail or, if the case might be, by using our chat. In this case, in general, we will process the following Personal Data: first name, last name, email and any other information you voluntarily provide when you contact us.

• Marketing messages

You can opt in to receive marketing messages via email.

You can revoke your prior consent at all times and without any costs, with altering consequences for the future.

• Browsing data

Computer systems and software procedures used for the Platform's operation acquire, during their normal operation, some Personal Data (so-called log files), the transmission of which is implicit in the use of internet communication protocols.

This information is not collected in order to be associated with identified persons, but due to its nature can, by means of processing and integration with data held by third parties, allow users to be identified. Such information includes the IP addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, and other parameters concerning the user's operating system and computer environment.

Insofar such information leads to the identification of a user, the provisions of this Policy shall become applicable.

• FAILURE TO PROVIDE PERSONAL DATA

You may refuse to provide certain Personal Data (indicated above) but, in such a case, you may not be able to benefit from certain App or Platform features, including, but not limited to, the creation of a user account or contacting you to solve your problem and to provide support.

• PROCESSING PERSONAL DATA BASED ON OUR LEGITIMATE INTEREST

When we process on the lawful basis of legitimate interest, we apply the following tests to determine whether it is appropriate:

• The purpose test – is there a legitimate interest behind the processing?
• Necessity test – is the processing necessary for that purpose?
• Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?

For more information on how we process the Personal Data on the lawful basis of legitimate interest, please contact us at imfineapp@gmail.com.

• AUTOMATIC PROCESSING OF PERSONAL DATA

Your Personal Data will not be processed for taking decisions based solely on automatic processing that would result in legal effects concerning you or could similarly significantly affect you.

• STORAGE PERIOD

As a rule, we will process your Personal Data as long as you use the App/Platform and/or during the existence of your account in our App/Platform.

Personal Data collected based on your consent will be processed until the date of withdrawal of the consent.

In certain circumstances, we may retain your Personal Data for longer periods of time, for example if we are obliged to do so in accordance with the legal, regulatory, tax or accounting requirements.

We may also keep your Personal Data for longer periods of time so that we have accurate records of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

• TRANSFER OF PERSONAL DATA

Your Personal Data is filed and stored on the servers of our contractual partners that are helping us to provide our services to you.

We may transfer Personal Data, as far as necessary, to the following categories of recipients:

• subcontractors;
• payment processors;
• companies offering IT services;
• marketing companies;
• public authorities, courts of law or arbitral tribunals, and authorities competent to investigate criminal offence.

These recipients can be located in the European Union and/or in the European Economic Area. Where recipients are located outside the European Union and the European Economic Area, including in countries not recognized as ensuring an adequate level of protection, the transfer of Personal Data shall be carried out only if there are appropriate guarantees, in accordance with applicable law. In this respect, we rely on several guarantees, such as the Privacy Shield certificate or the standard contractual clauses issued by the European Commission. You may receive from us a list of recipients from third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data. For any request to this effect, please contact us at the contact details mentioned below.

In addition, in connecting the App Users with Medical Professionals, some Personal Data of the App Users shall be made available to the Medical Professionals and some Personal Data of the Medical Professionals shall be made available to the App Users.

• SECURITY

The security of your Personal Data is important to us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure environments. However, despite our efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.

You are also responsible for helping to protect the security of your Personal Data. For instance, never give out your password, and safeguard your personal credentials when you are using the Services, so that other people will not have access to your Personal Data. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.

• RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA

• Your rights

You have the following rights in connection with the processing of your Personal Data:

Access right: You have the right to obtain from us confirmation that your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority, the source of your Personal Data.

Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data.

Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based according and where there is no other legal ground for the processing; (iii) you exercise the right to object to the processing; (iv) the Personal Data have been unlawfully processed. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise or defense of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data.

Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify the accuracy of the Personal Data; (ii) the processing is unlawful and then you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise or defense of legal claims or (iii) for the protection of the rights of another natural or legal person.

Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.

Right to opposition: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, or for the purpose of sending marketing messages, you have the right to object to the processing of your Personal Data by us. In the event of unjustified objection, Ascendio is entitled to continue processing Personal Data.

Revocation of consent: Insofar you consented to the processing of your Personal Data, you can at all times revoke your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.

Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with The National Supervisory Authority for Personal Data Processing (“DPA”) in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of the DPA are: 28-30 Gheorghe Magheru Boulevard, District 1, Postal Code 010336, Bucharest, Romania; e-mail: anspdcp@dataprotection.ro

• How to exercise your rights

To learn more about the manner in which you may exercise the aforementioned rights, please contact us at imfineapp@gmail.com,  

Identity verification: We take utmost care of the confidentiality of all Personal Data and we reserve the right to verify your identity if you make a request in relation to your Personal Data

Fees: As a rule, you can exercise your rights free of charge. However, we reserve the right to request a reasonable fee if your claims are manifestly unfounded or excessive, in particular because of their repetitive nature.

Response Time: We make every effort to respond to your request within one month of receiving the request. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests, in which case we will inform you of any such extension and of the reasons for the delay

• CONTACT

If you have any questions or concerns about this Policy or its implementation, you may contact us at imfineapp@gmail.com.