www.theraflo.co.uk and app.theraflo.co.uk (together, our website) is provided by Theraflo Ltd (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used. We also provide our practice management tool designed specifically for therapists and counsellors in the UK.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website or the provision of our services. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the United Kingdom General Data Protection Regulation (UK GDPR). Our ICO registration number is ZC155176.
This privacy policy is divided into the following sections:
What this policy applies to
Personal data we collect about you
How your personal data is collected
How and why we use your personal data
Marketing
Who we share your personal data with
How long your personal data will be kept
Transferring your personal data out of the UK
Cookies and other tracking technologies
Your rights
Keeping your personal data secure
How to complain
Changes to this privacy policy
How to contact us
What this policy applies to
This privacy policy relates to your use of our website and our practice management tool for therapists and counsellors.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website and how you use our services. We will collect and use the following personal data about you:
your name, address and contact information, including email address and telephone number and business details
your billing information, transaction and payment card or other payment method information collected by Stripe
counsellor/therapist information inputted into our practice management tool
details of any information, feedback or other matters you give to us by phone, email, post or via social media
your activities on, and use of, our website and services, including account credentials (e-mail address and hashed password (managed by Supabase Auth; passwords are never stored or seen by us in plain text))
professional information — qualifications, accrediting body / membership number (e.g. BACP, UKCP, BABCP)
information about the services we provide to you
your purchase history
information about how you use our website and technology systems, including technical and device data (IP address, browser type and version, device type, operating system, and referrer URL. This is captured automatically by Cloudflare (edge) and Sentry (error logs) for security and debugging).
your responses to surveys and promotions and support correspondence content
marketing site analytics data, including pseudonymous identifiers, page-view sequences, referrer, device, approximate geolocation (city/region) and ad-attribution data
You must provide this personal data to use our services unless we tell you that you have a choice.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on, e.g., your use of our website or any services on it.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data:
from you directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase our services, and complete customer surveys or participate in competitions via our website,
inputted into our practice management tool, and
from you indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies’ below.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract
for the purposes of a recognised legitimate interest, or
for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
What we use your personal data for | Our reasons |
|---|---|
Providing services | To perform our contract with you or to take steps at your request before entering into a contract, or for our legitimate interests in providing our services |
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations, or for our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us |
Enforcing legal rights or defend or undertake legal proceedings | Depending on the circumstances:
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Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances:
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Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices | Depending on the circumstances:
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Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
Statistical analysis to help us understand our customer base | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
Updating and enhancing customer records | Depending on the circumstances:
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Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant | To comply with our legal and regulatory obligations |
Marketing our services to existing and former customers | For our legitimate interests, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information |
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency | Depending on the circumstances:
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Voluntarily sharing relevant personal data with public authorities, regulators or other bodies exercising official functions in response to written requests where we consider disclosure is necessary and appropriate | For a recognised legitimate interest, namely to respond to a request from another organisation that needs the personal data for the purposes of carrying out its task in the public interest or exercising its official authority |
How and why we use your personal data - in more detail
More details about how we use your personal data and why are set out in the table below.
Purpose | Processing operation | Lawful basis relied on under UK GDPR | Relevant categories of personal data |
|---|---|---|---|
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices | Addressing and sending communications to you as required by data protection laws, i.e. UK GDPR or Data Protection Act 2018 | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(c)) | your name, address and contact information, including email address and telephone number and company details |
Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | your name, address and contact information, including email address and telephone number and company details |
Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
data concerning health, sex life or sexual orientation.
How and why we use your personal data - sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We may use your personal data to send you updates (by email, text message, or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
contacting us at data@theraflo.co.uk
using the ‘unsubscribe’ link in emails or replying STOP to text messages.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
third parties we use to help deliver our services to you, e.g. payment service providers, IT support and software design companies
other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers
our bank.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
public authorities, regulators and other bodies exercising official functions, where they make a written request for personal data they need for their public task or official functions and we decide it is necessary and appropriate to disclose it
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency - usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
Who we share your personal data with - in more detail
More details about who we share your personal data with and why are set out in the table below.
Recipient | Processing operation (use) by recipient | Relevant categories of personal data transferred to recipient |
|---|---|---|
Supabase Pte. Ltd., a Singapore private company limited by shares, UEN 202005760H, registered office 970 Toa Payoh North, #07-04, Singapore 318992. | Database, file storage and authentication customer data at rest. | Any of the personal data we collect about you (see above) |
Functional Software, Inc. (trading as Sentry), a Delaware corporation, registered office c/o Incorporating Services, Ltd., 3500 S Dupont Hwy, Dover, DE 19901, USA; principal office 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA. | Application error monitoring and performance telemetry diagnostic logs and stack traces from our app. | Technical data (IP address, browser/device data, page URL), user identifier (UUID) and any personal data incidentally included in error messages or stack traces. |
OhMySMTP Ltd (trading as MailPace), a company incorporated in England and Wales, company number 13200428, registered office Unit G32, The Light Box, 111 Power Road, London, W4 5PY. | Transactional email delivery (account, billing, appointment and password-reset emails) on our behalf. | Recipient name, email address and the content/metadata of transactional emails sent to or from users. |
Cloudflare, Inc., a Delaware corporation, principal office 101 Townsend Street, San Francisco, CA 94107, USA. | CDN, DNS, edge security/WAF and hosting of the application (Cloudflare Pages). All app traffic is proxied via Cloudflare. | All personal data we collect about you transits Cloudflare in encrypted form, plus connection metadata (IP address, request headers, user-agent, approximate location). |
Stripe Payments UK Limited, a company incorporated in England and Wales, company number 08480771, registered office 9th Floor, 107 Cheapside, London, EC2V 6DN. | Payment processing (card payments and subscription billing) and fraud prevention. Stripe acts as a separate data controller for payment data under PCI-DSS and AML rules. | Billing name, billing email, billing address, payment card details (card number is handled directly by Stripe and not stored by us), transaction history and IP address. |
Three Hearts Digital Ltd (trading as EmailOctopus), a company incorporated in England and Wales, company number 09897211, registered office 86-90 Paul Street, London, EC2A 4NE. | Marketing email distribution (newsletters and product updates) to users who have opted in. | Subscriber name, email address, opt-in status and source, engagement data (opens/clicks) and IP address. |
Google Ireland Limited, a company incorporated in Ireland, company number 368047, registered office Gordon House, Barrow Street, Dublin 4, D04 E5W5, Ireland (parent Google LLC, Mountain View, CA, USA). | File storage and document collaboration via Google Drive/Google Workspace used internally to store operational documents which may include customer correspondence and exported records. | Any personal data contained in documents we choose to store in Google Drive typically business contact details, correspondence and operational exports. |
GitHub, Inc., a Delaware corporation, principal office 88 Colin P. Kelly Jr. Street, San Francisco, CA 94107, USA | Source code hosting and version control for the application's codebase, and issue tracking. May incidentally receive personal data if it appears in code, test fixtures, debug snippets or issue attachments. | Limited, only personal data that may incidentally appear in source code, configuration, test data or issue/PR content (e.g. developer email addresses, occasional support screenshots). No live customer database. |
Who we share your personal data with - further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. Please contact us if you would like further information.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK
Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
However, where it is necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45A of UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here,
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
a specific exception applies under relevant data protection law.
If we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Cookies and other tracking technologies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies and similar technologies on our website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.
We use Google Analytics 4 to understand how people find and use our website, and to measure whether our advertising works. This runs on our public website and on the sign-up pages of the app. It does not run inside the signed-in app.
Where you consent, Google Analytics collects: pages viewed, approximate location derived from IP address, device and browser type, how you arrived at the site (including whether you clicked one of our adverts), and whether you started or completed a sign-up.
We do not send Google any information about your clients. Client records, session notes, appointments and the identifiers that refer to them are never included in analytics data.
Our legal basis is your consent, which you give through the cookie banner and can withdraw at any time via the cookie settings link in the footer. Google acts as a data processor for this purpose and may process data outside the UK; these transfers are covered by the UK extension to the EU–US Data Privacy Framework and standard contractual clauses.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of your personal data | The right to be provided with a copy of your personal data |
Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data - in certain situations |
Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations |
To object to use | The right to object: |
Rights in respect of automated decision-making | Where significant decisions (those which produce a legal or similarly significant effect on you) are made using your personal data and based on solely automated processing with no meaningful human involvement, you have the right to have certain safeguards in place to protect your data subject rights, freedoms and legitimate interests. These safeguards include giving you information about the decision and enabling you to make representations, obtain human intervention, and contest the decision |
The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under UK GDPR.
If you would like to exercise any of those rights, please email, or write to us - see below: ‘How to contact us’. When contacting us please:
provide enough information to identify yourself (e.g. your full name, address and any project reference number) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). You have a statutory right to complain to us directly.
You also have the right to lodge a complaint with the Information Commissioner. They may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time - when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.
How to contact us
You can contact us by post, or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details |
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Post: The Data Manager, Theraflo Ltd, Unit A6 Chaucer Business Park, Dittons Road, Polegate, BN26 6QH |