Meela’s Privacy Policy

Who we are

1.1 This Privacy Policy

This Privacy Policy covers how Meela AB (“MEELA”, “we”, “us”, or “our”) collects processes and shares your Personal Data (defined in section 1.4) which is obtained by us through your use of our services or shared by you. It also sets out the rights you have in connection to the information we use. 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. Our Privacy Policy was last updated 2024-07-24.

1.2 The Services

MEELA is a digital matching service between private practicing psychologists and psychotherapists and patients looking to start therapy. Our services are delivered in the form of a web application (the “Web app”), These services are referred to as “Services” throughout this Privacy Policy.

1.3 Controller

For the purposes of European data protection law, 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 we process 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 support@meelahealth.com

Contact details

Viktor Rydbergsgatan 33

412 57, Gothenburg Sweden

The data we process

1.4 The Personal Data we process about you

Personal Data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different types of Personal Data about you which we have categorised as follows:

Account Data includes registration date and whether you have an active account or not.

Contact Data includes your 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, e-mail address, telephone number age range, and gender.

Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Profile Data includes your feedback and survey responses.

Sensitive Data includes information on your health, whether you are using the Web app to follow a pregnancy or post pregnancy, your physical and mental history, current moods and physical symptoms and personal notes. This also includes information that you disclose to us revealing religious or philosophical beliefs, racial or ethnic origin and data concerning your sex life or sexual orientation.

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 or when you correspond with us in any way and when 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 for a number of different purposes, including to remember your preferences and for analytics purposes. Our use of cookies 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 below.

How we collect your personal data

3.1 Information you give us

MEELA collects Account Data, Contact Data, Identity Data, Profile Data, Sensitive Data and any other Personal Data you choose to provide to us when you:

register for an account/create a profile with us,

use or otherwise interact with our Web app or Website,

use or otherwise interact with our social media platforms,

answer our surveys,

contact our customer support, or

correspond or interact with us and our Services.

When signing up for the Web app, we will also ask for your consent to collect the required Sensitive Data to help match you with a therapist (please note that you will need to consent 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 support@meelahealth.com. Please not that where you withdraw your consent we will delete the Sensitive Data you have provided to us which in turn may affect your ability to use the Service.

When you interact with us publicly on our social media channels, please 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.

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 interact with our Website or otherwise using our Services, we will automatically collect Device, IT and Usage Data. Some Usage Data is collected through our use of cookies. Please see our Cookie Policy for further details.

3.3 Information we receive from other sources

We receive Personal Data about you from third party data processors as set out below:

Google Analytics: Device and Usage Data; and

Meta Analytics: Device and Usage Data.

How we use your personal data

4.1 – Where it is required to perform or, at your request, take steps to enter into, a CONTRACT

The use of your Personal Data may be necessary to perform a contract that you have with us or perform steps you request to enter into a contract. For example, when you register with us to provide the Services, the provision of the Services to you and to enable you to use some parts of the Website.

If you fail to provide certain information when requested (including Sensitive Data), we may not be able to provide the Services to you.

4.2 – Where you have provided CONSENT

4.2.1 – Marketing

Where you have provided your consent, we send electronic marketing communications including by email and SMS.

You always have the right to opt out of receiving marketing communication by unsubscribing, by adjusting your settings in the Web app or by contacting us at support@meelahealth.com.

4.2.3 – Surveys and Interviews

You may also be contacted by us to provide your consent to complete surveys or take part in interviews. We may use Personal Data collected via surveys and interviews in our internal business operations and strategy or marketing material or other promotional purposes (with your express consent).

4.2.3 – To conduct research

Mental health is important to MEELA and we will invest in scientific research in mental health in order to advance knowledge and research around mental health

All our published research is subjected to independent peer review and has ethical approval from the relevant professional bodies where required.

Where you have provided your express consent, we will use your User Data and other Personal Data that you may provide, in pseudonymized or anonymized form, for scientific studies, scientific articles and other research purposes. Your Personal Data is anonymized and aggregated (so that you cannot be identified) 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. Such participation requires your express consent.

You may withdraw your consent at any time. Please see the Your Rights section below for further details.

MEELA also contributes to research carried out by selected universities, institutions and other parties by sharing anonymized statistical, aggregated data with them. For the avoidance of doubt, we do not share any Personal Data or anything that would enable you to be identified with such external parties.

4.2 – Where there is a LEGAL REQUIREMENT

We will use your personal information to comply with our legal obligations including for the following purposes:

to comply with and (where relevant) keep a record relating to the exercise of any of your rights as a data subject;

to comply with court orders or other notices where failure to do so would result in us breaking the law; or

to handle and resolve any complaints we receive relating to our processing of your personal information as described in this Privacy Policy.

4.3 – Where there is a LEGITIMATE INTEREST

We may use and process your Personal Data where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

4.3.1 – For our legitimate interest in operating the administrative and technical aspects of our business:

to administer the Services and our relationship with you,

to administer the Website, Web-app and our social media pages,

troubleshooting, system testing, statistical purposes as well as notifying you of changes to the Services or technical issues,

for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access,

reaching out to you via in-app messages to ensure your correct and optimal use of the Web app,

to correspond or communicate with you in relation to administrative, legal and business matters,

for the purposes of corporate restructure or reorganisation or sale of our business or assets,

for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you,

to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings,

to inform you of updates to our terms and conditions and policies, and

for our internal purposes, such as quality control, Web app performance, system administration and to evaluate use of the Web app, so that we can provide you with enhanced services.

4.3.2 – For your and our legitimate interest in supporting individuals and users with their enquiries

We will process your Personal Data, including any Personal Data that you choose to provide in managing inquiries, complaints or claims received via our customer support, on our social media channels, or through contact forms provided by us at congresses and events.

4.3.3 – For our legitimate interest to improve our website, products/services, customer relationships and experiences and develop our business

We process your User, Usage and Account Data to 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 also use the results from any surveys you may undertake, including Profile Data from these surveys to better understand how we can improve your user experience and assess the effectiveness our marketing activities.

4.3.4 – For our legitimate interests in social media marketing, custom audiences, lookalike audiences and advertising

We use aggregated data for analysis and insight to help inform our marketing, business strategy and to enhance your user experience. This includes to identify and record when individuals have received, opened or engaged with the Web app or our electronic communications (please see our Cookies Policy for more information).

We use tools that help us identify and reach out to potential new customers, by matching cookies and device identifiers 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).

You always have the right to opt out Custom and Lookalike Audiences from us by opting out, by adjusting your settings in the App or by contacting us at support@meelahealth.com.

4.3.5 – For our legitimate interests in establishing, bringing or defending legal claims

It is in our legitimate interests to protect our business and our rights by establishing, bringing or defending legal claims where these relate to reports of adverse reactions or incidents that we receive.

Accordingly, we may process Personal Data, including Sensitive Data relating to complaints, claims or incidents at our events and to our products to allow us to establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3.6 – For our and other’s legitimate interests in enhancing knowledge and understanding on women’s health issues

We may analyze Sensitive Data in order to publicly share insights learned from anonymized and aggregated data with the purpose of increasing the public knowledge and understanding of women’s health. This kind of publication however is always based on aggregated anonymized data and as such doesn’t contain any Personal Data.

How long we keep your personal data

5.1 The length of time for which we retain your Personal Data is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not your Personal Data in an identifiable form for longer than necessary to provide you the Services and achieve the purposes set out in this Privacy Policy. When you terminate your account with us, your Personal Data will be deleted.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will retain your personal information for up to 180 days after the date it is no longer needed by us for the purposes listed in this Privacy Notice. The only exceptions to this are where:

the law requires us to hold your personal information for a longer period, or delete it sooner;

you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see paragraph 11 (Your data protection rights) below); or

you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see paragraph 11 (Your data protection rights) below).

Disclosure of your personal data

6.1 MEELA never sells your Personal Data and we conduct extensive assessments before engaging any company that will process that data on our behalf 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. We do not allow our third-party service providers to use your Personal Data for their own purposes.

6.2 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. Our suppliers include media providers (advertising and PR), IT service providers (cloud services, hosting, data management, data analytics and software development providers), analytics providers, market research providers, marketing communications providers, payment facilitation providers and professional services providers (legal and accounting),

with our affiliates, 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 (including third parties) with whom you ask us to share your Personal Data, including your therapist(s) with whom you have been matched using our Service,

publicly where you provide your consent for us to share testimonials and feedback on our Services and/or therapists, and

if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, tribunals, regulators, the government or related agencies, and/or to protect and defend MEELA, our affiliates, our business partners or our users’ rights and interests.

6.3 If you choose to share your Personal Data with any third party (e.g. a partner or therapist), you accept that you have done so at your own risk, please see section 9 for more details.

International transfers

7.1 MEELA is registered in Sweden and your Personal Data will be collected by MEELA. We may also transfer your Personal Data outside of the UK and EEA to service providers that carry out certain functions on our behalf. In accordance with applicable law, we implement measures, such as standard contractual clauses or declarations by regulators or governments (e.g. adequacy decisions) to ensure that any transferred Personal Information remains protected and secure.

7.2 Please contact us using the details at the end of this Privacy Policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

How we protect your personal data

8.1 We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For example, 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 and websites

9.1 The Website or Web app may contain links to other websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices.

9.2 Please note that we do not accept any responsibility or liability for personal data that may be collected through these third-party websites or services. We recommend that you read the privacy policy of every website you visit before you submit any personal data to them or use their services. This includes where you are directed to a therapist or similar professional via use of our Services.

10.1 Automated Decision Making

We use an automated, rule based algorithm for matching users to therapists. We always ensure that a proportion of matches are additionally reviewed and verified by a human to ensure that you are getting the best matches possible, and to maintain the quality and accuracy of our Service. Where you are unhappy with the matches provided to you, you are able to request re-matching, which will be undertaken by an individual.

Your rights in relation to your personal data

11.1 Your data protection rights

You have the right to:

request access to and information about your Personal Data that is being processed by us (commonly known as a “subject access request”),

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 in certain circumstances where there is no good reason for us to continue to process it.

delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request,

object to our processing of your Personal Data (i) if the processing is based on our legitimate interest (or that of a third-party), or (ii) for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object,

request that we restrict the processing of all or some of your Personal Data in certain situations,

request a copy of certain Personal Data in a structured, commonly used and machine-readable format and that we transfer your personal data to another controller, and

withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain the Services to you. We will advise you if this is the case at the time you withdraw your consent.

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) where you are located in Sweden or the Information Commissioner’s Office (ICO) where you are located in the UK, or your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority (such as the Swedish Data Protection Authority or the ICO) so please contact us in the first instance.

11.2 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.

Cookie policy

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. This policy was last updated on 2024-07-24.

You are encouraged to periodically review this Cookie Policy to stay informed of updates.

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.

We use a number of cookies on our website. Please see the cookie preference centre for more information on the types of cookies that we use. You may also amend your cookie preferences where required.

Types of cookies

Some of the cookies placed on your device are ‘First-party cookies’ as they are placed from the domain name of the Site when you visit the Site. Others are ‘Third-party cookies’, which may be placed on your device when you visit the Site from a domain name other than the Site’s by companies that run certain services for us. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

Cookies may be used for the period of your browsing session (‘session cookies’) whist others may be used for longer periods (‘persistent cookies’).

The cookies that may be used when you visit the Site are set out in detail in our cookie preference centre and can be categorised as follows:

Marketing 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.

Statistics 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.

Necessary Cookies

Some of our cookies are necessary to make the Site work 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 this may affect the functionality of the Site.

These cookies include security cookies, which help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties. They also include Site management cookies, which 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.

Preference Cookies

Preference 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

Control of cookies

You can amend your cookie preferences and consent or reject cookies by visiting the cookie preference centre at the top-right of your screen

Most browsers are set to accept cookies by default. However, you can also 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:

Apple Safari

Google Chrome

Microsoft Edge

Microsoft Internet Explorer

Mozilla Firefox

Opera

Android (Chrome)

Blackberry

iPhone or iPad (Chrome)

iPhone or iPad (Safari)

In addition, you may opt-out of some third-party cookies through (i) the Network Advertising Initiative’s Opt-Out Tool (ii) the Digital Advertising Alliance (iii) the European Interactive Digital Advertising Alliance.

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 by visiting the cookie preference centre.

Contact us

If you have questions or comments about the Privacy Policy and Cookie Policy, please contact us at:

Viktor Rydbergsgatan 33

412 57 Gothenburg, Sweden

support@meelahealth.com