INDEX:
1. Identification and contact details of the Data Controller.
2. General Information: Description of the information contained in the privacy policy.
3. Necessary and up-to-date information.
4. Exercise of your rights.
5. Detailed information on the treatments performed per service.
6. Security.
7. Confidentiality.
8. Minors.
9. Update to the privacy policy.
1. Identification and contact details of the Data Controller:
KAVAN HEALTH, S.L., a company registered at Avenida Comandante Franco, 23, 28016, Madrid, with CIF B-72537152, registered in the Madrid Mercantile Registry in volume 44079, folio 33, first entry, sheet M-777492 (hereinafter, “Kavan” or the “Company”) is responsible for the processing of personal data processed through the Kavan platform or website. This document provides information on the use that the Company will make of your personal data. In addition, this Privacy Policy is intended to provide information on the rights of both registered and unregistered Users under the General Data Protection Regulation (“GDPR”). If you have any questions regarding the processing of your personal data, please contact the Company at the following address: rgpd@kavanhealth.com.
2. General Information: Description of the information contained in the privacy policy:
In section five of this privacy policy, there is a table identifying each of the different services offered by the Company. These information tables inform you about:The purposes of the processing of your personal data, that is, the reason why the Company processes your personal data.The legal bases that allow the processing of data by the Company for each of the indicated purposes.The possible communication of your data to third parties, as well as the cause of such communication. For these purposes, we inform you that we do not transfer your personal data to third parties unless there is a legal obligation (Public Treasury, Judges and Courts, Security Forces and Bodies, OCU...) or we expressly indicate this in the table below. On the other hand, those responsible for the processing of the Company may have access to your personal data, that is, service providers who, for the performance of their functions, have access to your personal data. The table below will indicate those sectors in which the Company's service providers must access your personal data. We inform you that you can request more detailed information regarding the recipients of your data by sending an email to the address [rgpd@kavanhealth.com], indicating the specific treatment whose recipients you would like information about. The existence of potential international data transfers.The retention period of the data you provide us. For these purposes, we inform you that we keep your personal data for the entire duration of the contractual relationship or for a longer period if you have authorized us to do so. In addition, we inform you that your data will subsequently remain blocked for the attention of judicial, administrative or fiscal claims, for the periods legally determined by each applicable regulation.
3. Necessary and updated information:
All fields marked with an asterisk (*) in the forms provided to you must be completed, so that the omission of any of them could make it impossible for you to provide the requested services. You must provide true information, and the use of aliases or means to hide your identity is prohibited, with the exception of cases in which the same form expressly asks you to create a username, nickname or alias. It is essential that you keep at all times the reference numbers, passwords and access codes that you create or are provided with. You will be solely responsible for the use, authorized or not, of your personal account, and in this regard you undertake to make diligent use of such information, not to make it available to third parties, and to report its loss or theft. In order for the information provided to be always up to date and free of errors, you must inform the Company, as soon as possible, of any changes and corrections to your personal data that may occur through the following email [rgpd@kavanhealth.com]. You can also update your personal data through your private area. Also, by “clicking” on the “I Accept” button (or equivalent) incorporated in the above-mentioned forms, you declare that the information and data you have provided in them are accurate and true.
4. Exercise of your rights:
We inform you that you can exercise the following rights:
(i) right of access to your personal data to know which ones are being processed and the processing operations carried out with them;
(ii) right to rectify any inaccurate personal data;
(iii) right to delete your personal data, when this is possible;
(iv) right to request the limitation of the processing of your personal data when the accuracy, legality or need for the processing of the data is doubtful, in which case, we may keep the blocked data for the exercise or defense of claims;
(v) right to object to the processing of your personal data, when the legal basis that enables us to process those indicated in the table included in section 5 is legitimate interest. The Company will stop processing your data unless it has an overriding legitimate interest or for the formulation, exercise or defense of claims;
(vi) right to the portability of your data, when the legal basis that enables us to process those indicated in the table included in section 5 is the existence of a contractual relationship or your consent; and
(vii) right to revoke the consent granted to the Company for the processing of your data. You can exercise your rights at any time and free of charge by sending an email to [rgpd@kavanhealth.com] indicating the right you want to exercise and your identifying data. On the other hand, we inform you that you have the right to file a complaint with the Spanish Data Protection Agency if you consider that a violation of data protection legislation has been committed with respect to the processing of your personal data.
5. Detailed information on the treatments performed per service.
Management of the contractual relationship with you, including, but not limited to:
- Creation, management and modification of your customer account;
- Manage the technological platform and make it available both to duly registered psychology professionals and to users seeking psychological therapy;
- Make available to you in your private part; Provide you with the products or services you request;
- Process payment transactions.
The management, development and control of the contractual relationship derived from the use of the Platform service, including:
- Payment for services received through access to the Platform.
- The acceptance of this Privacy Policy, the General Conditions and Any other accepted general or particular conditions.
- Manage your registration as a User on the Platform, through any of the means enabled for this purpose, the web or the mobile application.
- The provision of Kavan's technical resources to allow their use by Users in accordance with the General Conditions.
- Verify, when necessary, the quality of the services provided to the User through the Platform.
- Respond to any requests, queries or suggestions that, if any, the User makes to Kavan.
- Control the computer security of the Platform.
- Management and control of promotions on the Platform.
- The sending by e-mail of information inherently related to the use of the Platform, as well as to the changes and updates that Kavan may make to them.
Any data that is collected by Kavan under no circumstances will be transferred to third companies under any circumstances, with the exception of the following exceptions:
- Make a prior request by the portal to the interested party and the interested party expresses their agreement, whether such request is individual or generic. In any case, Kavan will never transfer any data for advertising purposes.
- When they refer to the exceptions contemplated by the applicable regulations.
- Through contracting with third party companies and/or Kavan, for analysis services, for statistical purposes only and for improving the Service and never advertising.
- To the Professionals registered on the platform for the purpose of arranging and carrying out the Service. For these purposes, Professionals who access Patient data on the Platform assume, where appropriate, the obligations determined by the applicable data protection regulations, who assume all responsibility in the event of non-compliance with this regulation.
International transfers will not be made.
The personal data of Users will be processed by Kavan during the User's use of the Kavan Platform and, thereafter, for a period of five years unless, exceptionally, a limitation period for any longer legal or contractual actions during the contractual relationship applies to Kavan.
Sending commercial and promotional communications.
Data Management and Privacy: Use of Google Services:
- We do not transfer, share or disclose user information to third parties under any circumstances. - The data collected includes Google Meet, Google Calendar, email and profile information, only to provide the contracted services.
- Data is only stored as long as it is necessary to provide our services. Users can request their complete removal by contacting us at rpgd@kavanhealth.com
- We only access Google Meet and Calendar events that we create ourselves as part of our services, and access is restricted to authorized Kavan personnel for specific operational purposes.
Data Management and Privacy: Use of Google Services:
- We do not transfer, share or disclose user information to third parties under any circumstances. - The data collected includes Google Meet, Google Calendar, email and profile information, only to provide the contracted services.
- Data is only stored as long as it is necessary to provide our services. Users can request their complete removal by contacting us at rpgd@kavanhealth.com
- We only access Google Meet and Calendar events that we create ourselves as part of our services, and access is restricted to authorized Kavan personnel for specific operational purposes.
Your consent.
Access will be provided to service providers other than those indicated in the previous section, who are service providers of Mailing and digital marketing.
Access will be provided to service providers other than those indicated in the previous sections that are Google service providers.
The personal data of Users will be processed by Kavan during the User's use of the Kavan Platform and, thereafter, for a period of five years unless, exceptionally, a limitation period for any longer legal or contractual actions during the contractual relationship applies to Kavan.
Complaints and inquiries through user support and the contact form.
Your consent.
Access will be provided to service providers other than those indicated in the previous sections who are service providers of Contact Center.
Until the resolution of the query or complaint raised.
The personal data that the User voluntarily provides to Kavan, through the available means of contact -including the ChatBot-, to make any query or to contract a service from Professionals by registering on the Platform (such as, for example, name, surname, email and other identifying data or credit card data for the collection of services), or those generated later will be subject to processing and Kavan will be responsible for such treatment. The Patient is informed that, once the provision of psychology services begins, the Professional, in his capacity as independent healthcare professional, will be solely responsible for the Patient's data collected and generated during the provision of the service. Consequently, your personal data will be treated in accordance with the Professional's Privacy Policy (shared by the Professional once the provision of services has begun). At that time, Kavan will only act as a communication platform used by the Professional to communicate with the Patient and, therefore, will have the unique status of a provider of data hosting services.
Sensitive data. Health data and medical records, as well as all forms submitted by name and on behalf of the Professional, will be the sole responsibility of the Professional. Kavan will not use such data for any other purpose. Exceptionally, Kavan may collect some health data from the Patient always subject to their free and express consent (e.g., by voluntarily completing satisfaction and quality of service surveys) or if such treatment is necessary for the provision of the service (e.g., when completing certain questions that may be asked in order to identify the most appropriate Professional for the Patient) for the purpose of a possible analysis for statistical purposes.
6. Security
The Company has implemented and maintains the security levels required by the GDPR to protect the personal data of users against accidental loss and unauthorized access, processing or disclosure, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed. However, the transmission of information over the Internet is not completely secure; therefore, and despite the fact that the Company makes its best efforts to protect user data, it cannot guarantee their security during transit to the Website/App. Therefore, all the information you provide will be sent at your own risk. Once your data is received, the Company will use rigorous procedures and security functions to prevent any unauthorized access.
7. confidentiality
The personal data that we may collect through the Website/App or through the various communications that we hold with you will be treated with confidentiality, and we undertake to keep them secret in accordance with the provisions of applicable legislation.
8. Minors
Children under 18 years of age may not use the services available through the Website/the App without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all acts performed through the Website/App by the minors in their care, including the completion of forms with the personal data of said minors and the marking, if appropriate, of the boxes that accompany them. In this regard, and to the extent that the Company does not have the capacity to control whether users are minors or not, it is noted that parents and guardians must enable the necessary mechanisms to prevent minors from accessing the Website/App and/or providing personal data without their supervision, and the Company does not admit any responsibility in this regard.
9. Update to the privacy policy
This Privacy Policy may need to be updated; therefore, it is necessary that you review this policy periodically and if possible each time you access the Website/App in order to be adequately informed about the type of information collected and its treatment. You can find the Privacy Policy in the footer of the Website/ in the settings tab of the App. Notwithstanding the foregoing, we will notify you of any changes to this privacy policy affecting the processing of your personal data. The Privacy Policy comes into effect on 28/04/2023.