ONLINE DATA PROTECTION POLICY
TALKTIME MENTAL HEALTH SERVICES LIMITED and/or its affiliates and entities (collectively “we” or “us”) values your security and privacy. TALKTIME MENTAL HEALTH SERVICES LIMITED (the “Company”), as a DIFC registered entity, must comply with Data Protection Law, DIFC Law No. 5 of 2020 with its subsequent amendment DIFC Law No.2 of 2022 (the “DP Law”), and may for certain types of personal data processing, be subject to laws from other jurisdictions.
As such, it is the policy of the Company to respect the privacy of its website services and app users. In accordance with DIFC DP Law and as applicable our Terms of Use, the Company collects information about you when you use or access our websites and other web-based products, information or services (collectively, the “Website Services”) as well as through other interactions and communications you have with us, such as through the Company App (the “App”). This data protection policy (the “Policy”) sets out the basis on which any information, including any personal data, we collect from you, or you provide to us, will be processed by the Company. Each time you access or use the Website Services or provide us with information, by doing so you are accepting and, where possible, consenting to the practices described in this Policy.
SECTION 1: SCOPE AND APPLICATION
This Policy applies to persons anywhere in the world who access or use the Company’s Website Services or the App (“Users”).
SECTION 2: COLLECTION OF INFORMATION
2.1 This is information you give us about you by providing information or filling in forms on the App or any Company -owned Website Services, or by corresponding with us (for example, by telephone, e-mail or any other digital or electronic form). It includes for example information you provide when you register using the Company-provided online client portal, or download and register to use the App, search for the App in app stores (including but not limited to Apple App Store and Google Play Store), share data via the App’s social media functions, and when you report a problem with the App, or any of our Website Services. If you contact us, the Company will keep an electronic record of such correspondence, including personal information shared at that time. The personal information you give us may include your name, address, e-mail address and phone number, certain device information, username, password, residential building, work address, photograph, emergency contact infromation and other registration information you choose to provide (“Personal Information” or “Personal Data”).
2.2 The Website Services or App collect and process Personal Data for specific and/or lawful purposes only, or for the performance of tasks carried out in the interests and business of the Company.
2.3 The Website Services or App are not targeted, intended or expected to be of use to children or minors (aged below 18 years old). Apart from providing information for specific services or purposes, as directed by the Company’s processes, User-provided contributions of content or contact information regarding or about children or minors are expressly prohibited.
2.4 Each time you use our Website Services or App we will automatically collect the following information: (1) technical information, including the type of mobile device you use, a unique device identifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, time zone setting (“Device Information”); (2) details of your use of our Website Services or App including, but not limited to traffic data, weblogs and other communication data, and the resources that you access (“Log Information”); and/or (3) location information, if the Website Services or App uses GPS technology to determine your current location. If you wish to use the particular feature, you may be asked to consent to your data being used for this purpose. You can alter your consent and sharing selections at any time via your mobile device settings.
2.5 When you use any Website Services or the App, we may collect Personal Information as well as demographic information, for example information that you submit, or that we collect, which may include, but is not limited to, post code, hometown, gender, username, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, transaction information, age/birth date, browsing history information, searching history information, and registration history information (“Demographic Information”).
SECTION 3: USE OF PERSONAL DATA
3.1 We may use Personal Data which you provide to us or we collect from you to: (1) Provide, maintain, and improve our App and Website Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information about them), develop new features, provide customer support to Users, authenticate users, and send administrative messages, whether information or required by applicable law; (2) Perform internal administration and operations, including, for example, to prevent fraud and abuse of our Website Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends; (3) Send you communications we think will be of interest to you, including information about products, services, promotions, news, and the Company’s events, where permissible under DIFC Laws and according to any other applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards; (4) Notify you about changes to our App and Website Services; (5) Allow you to participate in any interactive features of our App or Website Services; (6) Keep our App and Website Services safe and secure; and/or (7) Personalize and improve the Website Services, including to provide or recommend features, content, social connections, referrals, and advertisements.
SECTION 4: PROCESSING, STORAGE AND TRANSFER OF PERSONAL DATA
4.1 We will take all steps reasonably necessary to ensure your data is processed fairly and lawfully, in accordance with the DP Law, other applicable laws and this Policy. By submitting your Personal Data (including Log, Device and / or Demographic Information), you agree to such transfer, storing or processing in order for the Company to perform its general administrative, commercial and regulatory functions, including but not limited to responding to enquiries you raise via the App or Website Services or maintaining contacts for future informational or promotional activities. Unless otherwise notified, the Company does not ordinarily engage in automated decision making when processing your Personal Data.
4.2 You agree that we have the right to transfer the Personal Data described in this Policy to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. Where this is the case, we will endeavor to take appropriate security measures to protect your Personal Data in accordance with this Policy. All information security policies are strictly enforced.
4.3 To preserve the integrity of our databases, to carry out on-going Website Services on behalf of all Users, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Users for a reasonable length of time unless otherwise prescribed by applicable law. The Company is not responsible for the accuracy and authenticity of the information you provide, and will modify or update your Personal Data in our databases upon your request, as further outlined below. We will erase or archive your Personal Data upon request, unless we are required to retain it in accordance with the Company or other applicable laws and regulations or to perform agreed services. By accessing or using the App or Website Services, you do hereby represent and warrant that you understand that all information submitted by you through the App or Website Services or otherwise to the Company may be used by the Company in accordance with applicable laws, regulations and company’s policies.
SECTION 5: SHARING OF PERSONAL DATA
5.1 We may share Personal Data which we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows: (1) With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us; (2) With third parties with whom you choose to let us share your Personal Data, for example other apps or websites that integrate with our API or Website Services, or those with an API or Service with which we integrate; and Other Types Of Data Sharing; (3) With the Company’s subsidiaries, joint ventures and affiliated entities; (4) With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them; (5) In response to a request for information by a regulatory authority or government entities if we determine that such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process; (6) With law enforcement officials, government entities or authorities, or other third parties as required by applicable law; (7) With third parties in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; (8) If we otherwise notify you and you consent to the sharing; and/or (9) With third parties in an aggregated and/or anonymized form which cannot reasonably be used to identify you.
5.2 All sharing of Personal Data aligns to the extent possible with the Company’s Government Data Sharing Policy, which is an internal Company’s policy that governs fair and lawful sharing of Personal Data requested by government entities within the DIFC, the UAE and elsewhere.
SECTION 6: YOUR RIGHTS AND CHOICES
6.1 The Company supports Users’ legal rights to opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our App or Website Services.
6.2 You may change your preferences at any time.
6.3 Please note that we may continue to send you transactional or service-related emails despite your desire to not receive promotional or marketing e-mail messages. Additionally, please note that if you elect to opt-out of receiving promotional emails from one of our Website Services or the App, you may continue to receive promotional emails from our other websites, providers or other, non-affiliated marketers whose services you may have accessed via the Company’s Website Services or App.
6.4 Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a different third party’s marketing directory through your request or election, you will need to request removal with such third party directly.
SECTION 7: ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION
7.1 You have the right to access information held about you. Your right of access can be exercised in accordance with DIFC and other applicable laws. Any access request generally comes at no cost to you, but may, where permissible, be subject to a fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.
7.2 When you contact us about a potential Personal Data error, we will endeavor to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavor to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required and / or appropriate. However, some third parties and third party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files.
7.3 You may also request that we restrict, erase or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the DP Law.
SECTION 8: CHANGES TO THIS POLICY
8.1 We may change this Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavor to provide you notice through the App or Website Services or by some other means, such as email. Your continued use of the App or Website Services after such notice constitutes your acceptance of the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices. We provide links to it through: (1) The App or Website Services; (2) Referencing it in our Terms of Use; and/or (3) Incorporating it into our contracts, agreements, and other documents as necessary or appropriate
SECTION 9: SECURITY PRECAUTIONS
9.1 The Company makes every effort to ensure that your Personal Data is secure on its system. The Company has staff dedicated to maintaining our data protection and security policies, periodically reviewing them and making sure that the Company’s employees are aware of our data protection and security practices. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, the Company does not warrant or guarantee whatsoever the security of any Personal Data you transmit to us, and you do so at your own risk and responsibility.
9.2 The Company has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We continually assess our data privacy, information management and security practices. We do this in the following ways: (1) Establishing policies and procedures for securely managing information; (2) Limiting employee access to viewing only necessary information in order to perform his or her duties; (3) Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required; (4) Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements; (5) Monitoring our websites through recognized online privacy and security organizations; and/or (6) Conducting background checks on employees and providing training to our employees.
9.3 If you have any further questions about our security and processing activities, please contact the Data Protection team / Officer or refer to our Terms of Use. To the extent permitted by applicable law, the Company expressly disclaims any liability that may arise should any other third parties obtain the Personal Data you submit.
SECTION 10: COOKIES
10.1 A cookie is a small text file that is unique to the web browser on your computer or mobile device, which is used to retain user preferences, and enhance browsing experience (“Cookie”). The Company uses Cookies to track overall site usage and enables us to provide a better user experience. We do not use Cookies to “see” other data on your computer or determine your email address.
10.2 Types of cookies we drop and the information collected using them include: (1) Google Tag Manager – helps make tag management simple, easy and reliable by allowing marketers and webmasters to deploy website tags all in one place; (2) Google Analytics – gives website owners the digital analytics tools needed to analyze data from all touchpoints in one place, for a deeper understanding of the customer experience; (3) Pingdom – monitors sites and servers on the internet, alerting the website owners if any problems are detected; and/or (4) Hotjar – by combining both analysis and feedback tools, Hotjar helps website owners understand what users want, care about and interact with on their website by visually representing their clicks, taps and scrolling behavior.
10.3 Alternatively you may wish to visit an independent source of information, , which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual or network operator for advice.
SECTION 11: EXTERNAL LINKS
11.1 The Website and the App may contain links to other websites on the Internet that are owned and operated by third parties (the “External Sites”). These links are provided solely as a convenience to you and not as an affiliation or endorsement by the Company of the contents of or reliability or safety on such External Sites. You acknowledge that the Company is not responsible whatsoever for the availability of, or the information and content of any External Site. You should contact the site administrator or webmaster for those External Sites if you have any concerns regarding such links or the content located on such external Sites. If you decide to access linked third party websites, you do so at your own risk and responsibility. The Company does not accept any kind of liability whether direct, indirect or consequential, and shall not be liable to you for any type of loss or damage arising from or as a result direct or indirect of your acting upon the content of another website to which you may link from the Website Services or the App.
SECTION 12: THE COMPANY’s BUILDINGS SECURITY
12.1 Building security records containing sign in and sign out information collected at the time of visiting and departing a Company-owned building will be maintained in accordance with this Policy.
SECTION 13: CONTACT US
If you have any questions, comments, suggestions and requests related to this Policy, or if you have any complaints related to how the Company processes your personal data, please contact us via electronic email.