Who we are
The Personal Data we process about you
How we collect your personal data
How we use your Personal Data
How long we keep your Personal Data
Disclosures of your Personal Data
How we protect your Personal Data
Third-party links
Your rights in relation to your Personal Data
Glossary
WHO WE ARE
1.1 This Privacy Policy
This Privacy Policy covers how Meela AB (“MEELA”, “we”, “us”, or “our”) collects and processes your Personal Data (defined in section 2) obtained by us through your use of the Services or otherwise shared by you. It is important that you read it together with any other privacy notice that we may provide when we are collecting your Personal Data so that you are fully aware of how and why we are using it.
We keep our Privacy Policy under regular review and may make changes to it. Any changes will be posted on our website (the “Website”) and, where appropriate, notified to you.
All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refers to the Swedish Personal Data Act (1998:204), which implements the EU directive 95/46/EC, and the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.
1.2 The Services
Delivered in the form of a web application (the “Web app”), MEELA is a digital matching service between private practicing psychologists and psychotherapists and patients looking to start therapy.
1.3 Controller
MEELA is a controller and is responsible for the processing of your Personal Data. We care deeply about the confidentiality and integrity of the information that is shared with us, and will only process your Personal Data in accordance with this Privacy Policy and applicable laws and regulations.
If you have any questions or comments about this Privacy Policy or our processing of your Personal Data, please contact us at hello@meelahealth.com
Contact details
Meela AB
Reg. no 559160-0944
Vera Sandbergs Allé 5B
411 33 Gothenburg, Sweden
The Personal Data we process about you
MEELA may process the following kinds of personal data about you (collectively referred to as “Personal Data”):
Account Data includes registration date and whether you have an active account or not.
Contact Data includes email address.
Device Data includes device identifier, your mobile operating system, the type of mobile browser you use and time zone setting.
IP Data includes your approximate position based on your IP address.
Identity Data includes first name, last name and e-mail address.
Marketing Data includes your preferences in receiving marketing from us.
Profile Data includes your feedback and survey responses.
Sensitive Data includes health data and referred to as special categories of Personal Data as defined in article 9 of the European Union’s General Data Protection Regulation (“GDPR”), such as information on whether you are using the App to follow a pregnancy or post pregnancy as well as your physical and mental history, current moods and physical symptoms and personal notes.
Usage Data includes details of your use of the Services, such as traffic data and the features that you access.
User Data includes data provided by you when setting up an account with MEELA and using the Web app, such as Contact, Identity, Marketing and Sensitive Data as well as other Personal Data that you may provide in connection with such use.
We also use cookies and HTML local storage to distinguish you from other Users of the Services and to remember your preferences. This helps us provide you with a good experience when you use the Services and allows us to improve them. For more information on cookies, please see our Cookie Policy.
HOW WE COLLECT YOUR PERSONAL DATA
3.1 Information you give us
MEELA processes Personal Data provided by you when registering for an account and using the Web app, using our social media platforms, answering surveys, contacting our customer support, or otherwise corresponding or interacting with us and our Services.
When signing up for the Web app, you will be requested to consent to our use of your Sensitive Data (please note that you will need to consent in order for the Web app to work). You have the right to withdraw your consent at any time by changing the setting in the App, or by contacting us at hello@meelahealth.com. If you provide sensitive data to us by other means than the app – for example via support – this is described in greater detail in section 4.1.
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 our relationship with you.
3.2 Information we automatically collect about you and your device
When you are using our Services, we will automatically collect Device, IT and Usage Data. Some Usage Data is collected by using cookies. Please see our Cookie Policy for further details.
3.3 Information we receive from suppliers
We receive Device and Usage Data about you from analytics providers such as Google Analytics.
HOW WE USE YOUR PERSONAL DATA
4.1 – To enable and provide the Services
4.1.1 – General
It follows from the nature of our Services that we must process such Personal Data that you add to the Services to enable and provide them. This includes administering the Services and our relationship with you, giving you personalized information, to secure the quality and develop the Services and to communicate and provide customer support, as further explained below. Consent for processing sensitive personal data must be obtained in order for the Web app to work.
4.1.2 – To administer the Services and our relationship with you
We use your User and IT Data to administer the Services and our relationship with you. This includes setting up your account for the Web app, troubleshooting, system testing as well as notifying you of changes to the Services or technical issues and reaching out to you via in-app messages to ensure your correct and optimal use of the App.
Lawful Basis: Contract, Consent, Legitimate interest in running the business, provide and ensure the proper function and use of the Services.
4.1.3 – To give you personalized information
MEELA provides you with personalized information and we do this by analyzing the User Data that is added to the Web app. Hence, MEELA uses automated methods for processing of User Data to provide you with an adequate App.
Lawful Basis: Consent, Contract.
4.1.4 – To secure the quality and develop the Services
We process your User, Usage and Account Data to monitor and analyze how our customers engage and interact with the Services so that we can secure the quality and develop the Services to better align them with your usage patterns and preferences. While we have access to Personal Data for analytics, the results are aggregated and stripped of any Personal Data.
We may also contact and enable you to complete surveys. We use the Profile Data from these surveys to better understand how we can improve your user experience.
Lawful Basis: Contract, Consent, Legitimate interest to analyze how our customers use the Services and to develop and improve them.
4.1.5 – To communicate with you and provide customer support
We will process Personal Data that you provide in inquiries to our customer support, on our social media channels or through contact forms provided by us at congresses and events, for the purpose of communicating with you and acting on complaints. What type of Personal Data we collect for this purpose depends on the nature of your inquiry. If you are a User, our support agents may request access to your User Data if necessary to appropriately respond to your inquiry. Such access is subject to strict access controls and security measures to protect your integrity.
When you interact with us publicly on our social media channels, ensure that you do not submit any Personal Data that you do not want to be seen by other people. We recommend that you also read through the privacy policies of such platforms.
Lawful Basis: Contract, Consent, Legitimate interest to respond to your inquiries, as far as Personal Data is processed to communicate with you on matters that are not related to your agreement with us
4.2 – To conduct research
Women’s health is important to MEELA and we invest in scientific research in mental health and female health in order to advance women’s health.
All our published research is subjected to independent peer review and has ethical approval from the relevant professional bodies where required.
If we have your consent, we will use your User Data and other Personal Data that you may provide, in pseudonymized or anonymized form (see the Glossary for more information on pseudonymization), for scientific studies, scientific articles and other research purposes as may be disclosed when your Personal Data is collected. However, Personal Data is anonymized and aggregated before any such publications are shared outside of MEELA. We may also contact you with requests to participate in specific research projects run by us or our business partners.
MEELA also contributes to research carried out by selected universities, institutions and other parties by sharing anonymized and minimized data with them. For the avoidance of doubt, we do not share any Personal Data with such external parties.
Finally, we may analyze sensitive data in order to publicly share insights learned from aggregated data with the purpose of increasing the public knowledge and understanding of women's health. This kind of publication is always based on aggregated anonymized data and as such doesn’t contain any personal information.
Lawful Basis: Consent
4.3 – Marketing
4.3.1 – Marketing Communication
We use Identity, Contact, Device and Marketing Data of our users of the App to send you newsletters and other marketing communications e.g. push notifications regarding MEELA and our Services, including campaigns and offers. We also process Account, Contact and Usage data to conduct internal usage analysis for the purpose of creating and sending relevant messages about our Services. Some Marketing Data is collected by using cookies. These cookies include third party services that may collect information about your visits to our site for analytics, retargeting and conversion tracking purposes. Please see our Cookie Policy for further details.
Lawful basis: Legitimate interest to market ourselves and our Services
4.3.2 – Social media marketing – custom audiences, lookalike audiences and advertising
We use tools that help us identify and reach out to existing and new customers, by matching cookies, device identifiers and hashed (a pseudonymisation technique) email addresses of people who have been using our Services with people on social media platforms to create so called “Custom Audiences” (this enables us to send targeted ads to people who have been using our Services), and “Lookalike Audiences” (this enables us to send targeted ads to people who have similar traits to our Custom Audience). The social media platforms will not share the hashed email address with third parties or other advertisers and will delete it promptly after the match process is complete. Please note that we do not share any Sensitive Data or group users based on sensitive data for the purpose of Custom and Lookalike Audiences.
Lawful Basis: Legitimate interest to market ourselves and our Services
4.3.3 – Surveys and interviews
You may also be contacted and enabled to complete surveys or take part in interviews for marketing purposes. We will process the Profile Data that you provide in such surveys and interviews to analyze user preferences, improve and assess the effectiveness of marketing activities, use as marketing material or other promotional purposes as disclosed when your Personal Data is collected.
Lawful Basis: Consent
4.3.4 – Marketing opt-out
You always have the right to opt out of receiving marketing communication or having your data being processed to identify Custom and Lookalike Audiences from us by opting out, by adjusting your settings in the App or by contacting us at hello@meelahealth.com.
HOW LONG WE KEEP YOUR PERSONAL DATA
5.1 Retainment
We retain your Personal Data for as long as necessary to achieve the purposes set out in this Privacy Policy. In some cases, we may be required to continue to process your Personal Data for a longer period of time to comply with legal obligations (e.g. accounting or audit obligations) or for the establishment, exercise or defense of legal claims. If you terminate your account with us, all your data will be deleted.
Lawful basis: Consent
DISCLOSURE OF YOUR PERSONAL DATA
6.1 Recipients
MEELA never sells your Personal Data and we conduct extensive assessments before engaging any processor to ensure that they have appropriate technical and organizational measures in place that provide adequate protection of your Personal Data. Anyone who is processing Personal Data on our behalf is bound by contractual obligations to keep Personal Data confidential and secure, and to use it only for the purposes as instructed by us.
MEELA may share your Personal Data:
with our service providers that we use to support and provide our business, such as technical service or operation providers, to the extent needed to enable and provide the Services to you,
with our affiliates MEELA, related by common ownership or control, to the extent needed to carry out the processing of Personal Data as described in this Privacy Policy,
with our successors, if we are involved in e.g. a merger, acquisition or asset sale, giving you notice of this,
with others with whom you ask us to share your Personal Data, if we reasonably believe it is necessary to comply with a legal or regulatory obligation, and/or to protect and defend MEELA, our business partners’ or users’ rights and interests.
If you choose to share your Personal Data with any third person (e.g. a partner), you accept that you have done so at your own risk.
HOW WE PROTECT YOUR PERSONAL DATA
7.1 All information you provide to us is transferred using TLS encryption (HTTPS) and stored on secure servers. We use generally accepted industry standards, technologies, procedures and methods, such as firewalls, encrypted storage, pseudonymization, regular software updates, security scans, access control, audit logging and review of admin actions as well as external penetration tests to protect the integrity of your Personal Data and to prevent unauthorized access. We also have policies and other organizational measures in place, including recurrent employee training on data protection and strict procedures to deal with any suspected personal data breach.Third-party links
The Website may contain links to other websites. Please note that we do not accept any responsibility or liability for personal data that may be collected through these websites or services. We recommend that you read their privacy policies before you submit any personal data to them or use their services.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
8.1 Your rights
You have the right to:
request access to and information about your Personal Data that is being processed by us,
request correction of your personal data if it is inaccurate or incomplete, including to provide additional data if relevant information is missing,
request erasure of your Personal Data,
object to our processing of your Personal Data (i) if the processing is based on our legitimate interest, or (ii) for direct marketing purposes,
request that we restrict the processing of all or some of your Personal Data in certain situations and to ask us not to send you any direct marketing, and
request a copy of your Personal Data in a structured, commonly used and machine readable format and that we transfer your personal data to another controller.
If you have any concerns regarding our processing of your Personal Data, you have the right to file a complaint with the Swedish Data Protection Authority (Sw. Integritetsskyddsmyndigheten), or your local supervisory authority.
8.2 How to exercise your rights
You may contact us in writing at any time to exercise your rights, preferably using the email address that is associated with your user account. We may need to request specific information from you to help us confirm your identity.
We do our best to respond to your request within a few days, and at least within one (1) month. If the request is complicated or if we have received a large number of requests, we may need to prolong our response time with one (1) additional month.
You can exercise your rights at no cost to you. However, we may charge you a reasonable fee if your request is clearly unfounded, repetitive or excessive.
8.3 – Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
If you have any concerns regarding our processing of your Personal Data, you have the right to file a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen), or your local supervisory authority.
8.4 – Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. We will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Meela AB (“MEELA” or “we” or “us” or “our”) may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit our website www.meelahealth.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) to help customize the Site and improve your experience.
We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Site, and you waive the right to receive specific notice of each such change or modification.
You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the Site after the date such revised Cookie Policy is posted.
USE OF COOKIES
A “cookie” is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the Site. We use cookies on the Site to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Site, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Site is being used and improve your user experience.
TYPES OF COOKIES
The following types of cookies may be used when you visit the Site:
Advertising Cookies
Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.
Analytics Cookies
Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.
Our Cookies
Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.
Personalization Cookies
Personalization cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.
Security Cookies
Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.
Site Management Cookies
Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.
Third-Party Cookies
Third-party cookies may be place on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.
CONTROL OF COOKIES
Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site.
For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies, or visit the following links:
In addition, you may opt-out of some third-party cookies through the Network Advertising Initiative’s Opt-Out Tool.
OTHER TRACKING TECHNOLOGIES
In addition to cookies, we may use web beacons, pixel tags, and other tracking technologies on the Site to help customize the Site and improve your experience. A “web beacon” or “pixel tag” is tiny object or image embedded in a web page or email. They are used to track the number of users who have visited particular pages and viewed emails, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons and pixel tags cannot be declined. However, you can limit their use by controlling the cookies that interact with them.
CONTACT US
If you have questions or comments about the Privacy Policy and Cookie Policy, please contact us at:
Meela AB
Viktor Rydbergsgatan 33
412 57 Gothenburg, Sweden
hello@meelahealth.com
Last updated 2022-07-06