Psyche Ethos Advisory

Privacy Policy

PRIVACY POLICY

  1. Introduction 

This Privacy Policy is between you and us, Psyche Ethos Consulting, Advisory and Transformations L.L.C-F.Z. and Psyche Ethos Advisory FZE (together, Psyche Ethos Advisory, we, our, or us) for use of our services including our     website accessible at Psycheethos.com (Website) and any related services we provide via the Website and our associated social media pages/platforms (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. 

Our collection, storage, use and sharing of your personal data is regulated by applicable data protection laws, including:

  • Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL),
  • The UK General Data Protection Regulation (UK GDPR), and
  • The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

(Hereinafter referred to as “Applicable Data Protection Laws”)

Depending on the Services you receive and the relevant contracting entity, either or both Psyche Ethos entities may be the controller of personal data obtained via the Services.

  1. What this policy applies to

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

If you are a user located in the United Arab Emirates, the UK, or California, please note that your personal data may be processed in accordance with the applicable laws of your jurisdiction, including the Applicable Data Protection Laws where relevant.

  1. Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

Category of dataIn more detail 
Identity and account data you input into the Services For individuals: Your name, Your date of birth, Your postal address, Your email address, Your contact number, Your account details, such as username and password Health and/or wellbeing information you choose to disclose in connection with our Services.
For organisations: Your organisation’s name, Your organisation’s postal address, Your organisation’s contact person, Your contact person’s designation, Your contact person’s email address, Your contact person’s contact number
Data collected when you use specific functions in the ServicesData you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this Privacy Policy as if it were)
Other data the Services collects automatically when you use itYour activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use 
Data collected when you make an enquiry with usYour full name, email address, telephone number and message

If you do not provide personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

We may also collect information defined as “sensitive personal data” under applicable laws (see Section 4 below).

In accordance with the California Consumer Privacy Act (CCPA/CPRA), we may collect the following categories of personal information: identifiers; characteristics of protected classifications under California or federal law; commercial information; Internet or other electronic network activity information; geolocation data; and inferences drawn from such information.

  1. Sensitive Data

Sensitive personal data (also known as special category data or sensitive personal information) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

In the course of providing our Services, you may choose to disclose certain health or wellbeing information to us.

This information is classified as a special category of personal data under applicable data protection laws, including Applicable Data Protection Laws. 

We collect and process your health information based on the following lawful bases:

  1. Explicit Consent: We will ask for your explicit consent to collect and use your health information. By providing this information, you agree to its use for the purposes described in this Privacy Policy, such as personalising our services and ensuring they meet your specific health needs.
  2. Provision of Services: The collection of health information is necessary for us to deliver our Services effectively and safely. We use this information to customise programs, assess your suitability for certain activities, and provide you with the best possible experience.
  3. California Consumers: Under the California Privacy Rights Act (CPRA), health information may be treated as sensitive personal information. We will not use or disclose this information beyond what is necessary to provide our Services unless we obtain your consent or provide a clear right to limit such use, in line with California regulations.

You have the right to withdraw your consent at any time by contacting us at contact@psycheethos.com. However, please note that if you withdraw consent, we may be unable to continue providing certain Services that rely on the use of your health information.

All health information provided will be treated with the utmost confidentiality and will only be shared with authorised personnel or trusted third parties as necessary to provide our Services and as outlined in this Privacy Policy. 

  1. How your personal data is collected

We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media platforms, for instance, LinkedIn, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services. 

We use cookies and similar technologies which may collect personal information about you, provided you have consented to our use of such cookies subject to your consent, as required under the Applicable Data Protection Laws. You can find out about the cookies we use on our Website in our cookies policy or contact us for the cookie policy. You can consent to or reject cookies, and update your consents, at any time via our Website.

  1. How and why we use your personal data

Under Applicable Data Protection Laws, we can only use your personal data if we have a proper reason, e.g.:

  1. where you have given consent
  2. to comply with our legal and regulatory obligations
  3. for the performance of a contract with you or to take steps at your request before entering into a contract, or
  4. 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 information, 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  
Create and manage your account with us To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Services to you To perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions which apply to the Services) 
To enforce legal rights or defend or undertake legal proceedings  Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important noticesDepending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data  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 or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to youFor our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Updating and enhancing user recordsDepending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions which apply to the Services)to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To share your personal data with members of our group and third parties 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.In such cases information will be anonymised where possible and only shared where necessaryDepending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

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.

  1. Marketing

We do not intend to send you email marketing to inform you of our services such as promotions. 

We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

  • contacting us at contact@psycheethos.com
  • using the ‘unsubscribe’ link included in all marketing emails you may receive from us

We will always treat your personal data with the utmost respect and never sell or 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.

  1. Who we share your personal data with

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including instructors, developers, payment providers and session booking providers and Google, Inc. for Google Drive functionality. We exert no control over Google’s Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protects personal data – https://policies.google.com/privacy?hl=en-US. 

We may use payment service providers, including Wise and Stripe, to process payments in connection with our Services.  Where used, these providers will collect and process your personal data in accordance with their respective privacy policies.  

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you. 

We or the third parties mentioned above may occasionally also need to share your personal data with:

  • external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
  • professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
  • other parties 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, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

  1. How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to 7 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.

Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

  1. Transferring your personal data out of the UAE
    • You acknowledge and agree that personal data provided in connection with these Services may be transferred to, stored, and processed in jurisdictions outside of the UAE, e.g. Switzerland. Such transfers will be conducted in accordance with applicable data protection laws of both the sending and receiving jurisdictions. We commit to handling Your personal data respectfully and in compliance with all relevant data protection regulations applicable to the location of the Client.
  2. Your rights

Depending on your location and the applicable data protection laws, you may have the following rights regarding your personal data. These rights may differ slightly depending on whether you are located in the UAE, the UK, or the state of California, United States.

Access to a copy of your personal dataThe 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 useThe 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:at any time to your personal data being used for direct marketing (including profiling)in certain other situations to our continued use of your personal data, e.g. where we use yourpersonal data for our legitimate interests. 
Not to be subject to decisions without human involvement The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
 We do not make any such decisions based on data collected by the Services.

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). 

If you would like to exercise any of those rights, please complete email, call 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 and username) and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you would like to exercise and the information to which your request relates
  1. 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 business 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 (such as the UAE Data Office, UK Information Commissioner’s Office (ICO), or the California Privacy Protection Agency (CPPA)) and California Attorney General of a suspected data security breach where we are legally required to do so.

  1. How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with the relevant data protection or privacy regulator in your jurisdiction. 

  1. 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 via the Services or by other means, such as email.

  1. How to contact us

You can contact us by post, email or telephone 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: