Last Updated: 2 August 2023
This Privacy Policy (“Policy”) outlines how Voda Technologies Limited, as the data controller, processes and protects personal data collected through our website (“Site”) and mobile device application (“App”).
By accessing our Site, downloading our App, or using any of the Services provided on the Site and the App, you signify your agreement to the terms of this Policy. Please note that this Policy pertains solely to information collected through the Site and the App and does not govern data collected through other channels or contexts.
We collect personal and other information from you directly when you provide it to us through the Site and the App.
We may also automatically collect certain information about you when you (i) use, access, or interact with our Site, including information about your computer, smartphone, or other device; and (ii) use our App, including the type of mobile device you use, your mobile device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the App.
The App does not request access to your phone’s contacts or other device data or applications, except when you choose to use services within the app that allow you to share photos or location information.
You can visit the Site without submitting any information that we can use to identify you personally. However, if you use certain features on the Site, such as the “Contact Us” feature, you will be required to provide personal information. Such information could include, for example, your name, email address, or phone number.
When you register with us and use the App, you may provide your name, email address, age, user name, password and other registration information, transaction-related information, and information you provide when you contact us via the App. We may also collect this information when you create an account by using a third-party social networking service such as Facebook (each, an “SNS Account”). If you use an SNS Account to create your Voda account, we will gather your name, email address, and other personal information that your privacy settings on the SNS Account allow us to access.
It is possible for you to submit your own content, such as answers to guided questions, journal entries, or other writings, in all cases submitted in the App. You own your own user content. Such content is encrypted and stored locally on your device or in the cloud.
Because of the nature of the Services, we will be collecting information about you that relates to your mental health and personal identity. Such information may include reflections on your mental health status, information about current mental state or mood, information on symptoms of mental health conditions, previous diagnoses, personal identity, relationships information, sexual orientation information, personal history, and additional personal information related to answers provided to guided journaling questions and on your user profile. These information is only collected when you provide it to us, and is not shared with third parties and only used to provide you with appropriate content.
The App does not collect or process credit or debit card data. Apple and Google Play collects credit or debit card data with respect to in-app purchases made through the App, including payments for an App subscription. If you purchase a membership subscription through the Site, Voda may receive your name, email address, and credit card details for the purpose of the transaction. We do not directly handle credit card information. If purchasing an App subscription on the Site or in the App, your payment and information will be processed by Stripe, Apple Pay, Google Play Billing.
When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognise your computer and gather information about its online activity.
The Site contain cookies. Cookies are small files that are stored on your computer by your web browser. A cookie allows a website to recognise whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.
Our Services may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your activity (such as Facebook SDK). In addition, some mobile devices come with a resettable advertising ID (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify your mobile device over time for advertising purposes.
We also may partner with certain third parties to collect, analyse, and use some of the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from us. This information may be used for a variety of purposes, including online website analytics.
From time to time, we may also collect aggregated or deidentified information about Site users for internal use to improve the product. Such aggregated or deidentified information will not identify you personally.
We use the information that we collect for a variety of purposes in the interest of consistently delivering the best and most personalised mental health services. These purposes include, for example:
• To provide the Services;
• To respond to your questions or requests concerning the Site, App, or other services offered by us;
• To fulfil the terms of any agreement you have with us;
• To fulfil your requests for our Services or otherwise complete a transaction that you initiate, including in-App and Site purchases;
• To send you information about our Services and other topics that are likely to be of interest to you, including through emails from which you may opt-out;
• To deliver confirmations, account information, notifications, and similar operational communications;
• To improve your user experience and the quality of our products and Services;
• To comply with legal and/or regulatory requirements; and
• To manage our business.
In addition to the purposes above, we use the information that we collect automatically through the Site and the App for such purposes as:
• Counting and recognising visitors to the Site and users of the App;
• Analysing how visitors use the Site and various Site features;
• Analysing how users of the App use the App and App features;
• Improving the Site and App and enhancing users’ experiences with the Site and the App;
• Creating new products and services or improving our existing products and Services;
• Enabling additional website analytics and research concerning the Site and the App;
• Engaging in interest-based advertising (as described below); and
• Managing our business.
We may link information gathered through the Site or the App with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.
In order to deliver the best personalised experience to you, we may share your personal data from time to time, including in encrypted form to provide our Services.
We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyse certain information for the purposes discussed above. The App uses Google Analytics, RevenueCat and SendInBlue.
To provide the best experience to you, our user, Voda uses third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above. We may share your information with other third parties when necessary to fulfill your requests for Services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
To comply with applicable law or a court order, subpoena, or other legal process;
To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
To establish, protect, or exercise our legal rights or defend against legal claims; or
To facilitate the financing, securitisation, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
You will be notified via email or a notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information. We never sell your information. The App allows you to share collected data with your social media accounts, like Facebook, but only with your permission.
If you want to learn more about the personal information that Voda has about you, or you would like to update, change, or delete that information, please contact us by email at support@voda.co.
You may also opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at support@voda.co.
You may stop all collection of information by the App by uninstalling the App. You may use the standard uninstall process as may be available as part of your mobile device or via the mobile application marketplace or network. While using the App, the App allows you to access your data, edit your data, share your data and delete your data. You may do this in the Settings section of the Voda app, which can be found in your profile.
This Site may contain links to third-party websites. If you use these links, you will leave the Site. The App allows you to share collected data with to social media accounts, like Facebook or Instagram. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. Your user content is deidentified and it is not read or reviewed by Voda or any third parties. However, no website or App is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Site, to the App, or to us, and you transmit such information at your own risk.
As a data subject under the UK GDPR, you have the right to access, rectify, erase, restrict, and port your personal data. To exercise these rights or for any data-related inquiries, please contact us at support@voda.co. You can also delete your data through the account deletion process on the App.
We retain personal information about you necessary to fulfil the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it, which includes the time period during which you are using the App and a reasonable time thereafter. We will retain automatically-collected information for up to 24 months and thereafter may store it in the aggregate as anonymised data. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.
Voda Technologies may retain therapy and analytics data in an anonymised form for research and development purposes. Anonymisation involves the removal of personal identifiers, such as names and email addresses, to ensure that the data cannot be linked back to individual users. The anonymised therapy data may be used for research and analysis to improve the effectiveness of our mental health services and enhance the overall user experience. This data allows us to gain valuable insights into mental health trends, user behaviours, and preferences, enabling us to develop more personalised and impactful content and features.
If you would like to delete the personal data that you have provided via the Site or the App, please contact us at support@voda.co and we will respond in a reasonable time. Please note that some or all of your personal data may be required in order for the Site or the App to function properly.
The information that we collect through or in connection with the Site and the App is processed in the United Kingdom for the purposes described above. We also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United Kingdom or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or other information to us, you expressly consent to such transfer and processing.
If you are a user in the European Economic Area, we process your personal data in the United States as data controller and in compliance with the European General Data Protection Regulation (“GDPR”). In addition to the data categories outlined above, we collect “data concerning health” as defined in the GDPR. Data concerning health means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.
We process your personal data based on one or more of the following legal grounds:
• your explicit consent,
• the performance of a contract with you or to take steps at your request before entering into a contract,
• our legitimate interests in providing personalised mental health services and improving our products and services, and
• compliance with applicable legal obligations.
You have the right to:
• access personal data we hold about you;
• request rectification or erasure of your personal data;
• request the restriction the of processing of your personal data;
• object to the processing of your personal data; and
• data portability.
If we rely on your consent for processing your personal data, you may withdraw that consent at any time. To exercise any of your data subject rights or to withdraw your consent, please contact us at support@voda.co.
You have the right to lodge a complaint with a supervisory authority if you believe that our data processing activities infringe on your rights. The EU Commission provides a list of supervisory authorities, which you can find here.
Voda may share your personal data with service providers or third parties as described above, and some of these recipients may be located outside the European Economic Area. In such cases, Voda will ensure that these entities adhere to applicable legislation and implement necessary organisational and technical measures to safeguard your personal data adequately.
We may update this Privacy Policy from time to time to reflect changes in our data practices or legal requirements. Any revisions to the Privacy Policy will be posted on our website [www.voda.co/privacy-policy] and will be effective immediately upon posting. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your privacy and handle your personal information.
For any questions or concerns about this Policy, you can reach out to our Data Protection Officer (DPO) at support@voda.co. We are committed to addressing your inquiries promptly and ensuring the protection of your personal information.
