Privacy Policy
We know that privacy and trust are essential and we are committed to keeping your personal data safe, secure and confidential, both online and offline.
This privacy notice (the "Notice") applies to the Alena mobile app (the "App") and sets out how we use and protect personal data we collect and process about you, our users when you use Alena. It also provides you with information about your rights in connection with your personal data.
We encourage you to read this Notice in full so that you understand how your personal data is processed through the App.
If you have any questions about this Notice or how your personal data is used you can contact us on contact@alena.com. Please see the "Your Rights" tab below for further details on your data subject rights.
This Notice was last updated 31 October 2023.
WHO WE ARE
We are AYA Technologies Limited, a company registered in England and Wales (company number 12333066), whose registered address is at 25 Wilton Rd, Pimlico, London SW1V 1LW ("Aya", "us", "we", "our").
We are a controller in connection with the processing of your personal data. This means that we determine the purposes and means of the processing of your personal data.
WHAT PERSONAL DATA WE COLLECT AND HOW WE PROCESS IT
Personal data is any information which can be used, directly or indirectly, to identify you as an individual.
When you use the Alena App you may choose to provide us with personal data such as: (i) your name; (ii) your email address(es); (iii) your contact telephone number(s); (iv) your location; (v) your address; (vi) your payment information; (vii) details of your mental health.
Here are the ways you may provide the information and the types of personal data you may submit. We also tell you how we may use that personal data. The list below explains those uses for which we have a legitimate business interest.
Signing up to the Alena app.
When you sign up to use the Alena app you are required to provide your name, and your email address. We require this information in order to provide you with our services in accordance with our Terms of Service.
Due to the nature of the services, the Alena app is also only available to those over the age of 18, therefore we may collect your date of birth to confirm that you are eligible to use the Alena app.
Using the Alena app
When you use and engage with the exercises on the Alena app you may be asked to provide certain information about your relationships with other individuals, information about your mood and information about your mental health. This information will be stored in The App in order to provide you with suggestions for coping mechanisms and ways to handle stress and anxiety which you may be experiencing.
In order to assess your current mental health state, Alena will provide assessments where you will need to perform choices and provide inputs that will help determine your cognitive tendencies and recommend appropriate courses of therapy.
Your safety and security are extremely important for us. Your data is end-to-end encrypted and saved in the cloud . Your personal information is not linked to your app reflections and inputs. Your personal and app data is not and will not be shared with any advertisers.
Your use of the Alena app is voluntary, and when you provide your personal data you acknowledge that Alena will use this information in order to provide the services as set out in our Terms and Conditions.
The Alena app may request certain information about your mental wellbeing and health; this information is considered a special category of information. Alena is only able to process this type of personal data if you consent to Alena’s processing for the purposes identified. We will explain the way your personal data will be used before you submit it.
If you do not wish to provide this information, the Alena app may not be able to accurately assess your current mental state and provide you with accurate suggestions or coping mechanisms. Providing false or incorrect information will impact the results provided to you. If you do consent to provide this information you can choose to withdraw your consent to Alena’s processing of this personal data at any time by contacting us at contact@alena.com. For further information about withdrawing your consent, please see the Your Rights section below.
Please note it is your responsibility to ensure that you are responding to questions in full, honestly and accurately. Any suggestions made are directly related to the information you provide. If the information which you have provided is not correct, incomplete or has changed, you are responsible for updating Alena. Please see Your Rights below for further information about how to update your information within the Alena app.
Paying for use of the Alena app and additional services
Some of our services are subscription based and require payment. If you opt in to our subscription based services you will be required to provide payment details such as your name, your address, contact number and card payment details including name on the card, card number, and expiry date.
This information is required in order for us to process your payments and provide you with the subscription service you have signed up for.
Marketing communications
The Alena app is constantly developing and our service and product offerings may change with time. When you register with the Alena app we will add you to our marketing list to keep you up to date with any new service or product offerings.
We will send you marketing communications via email using the address you provide when you sign up. We do this based on both our and your legitimate interest as we think these communications will be useful to you.
You can always choose to unsubscribe from receiving these communications by clicking the link provided at the bottom of our emails.
Compliance with laws and regulations and to establish a legal defense
In some circumstances, where we are required under applicable law or to establish a legal defense in accordance with our legitimate interest, we may retain and process your personal data for a period after you stop using our services.
Processing of anonymized information
We process anonymized information to help improve our services and products. When we anonymize the information you provide it means that you are no longer identifiable from that information or data set and it cannot be traced back to you.
We have a legitimate interest in improving the functionality of the Aya App, in order to provide you and our other customers with a better service.
AUTOMATED DECISION MAKING, INCLUDING PROFILING
In order to provide you with the services, your personal data is automatically processed through Aya’s proprietary technology, without human intervention. We match and score your responses against our database to evaluate certain personal aspects about you. We may use such automated processing to create an abstract representation of your preferences and your mental state.
The app includes cognitive assessments which use data you have input, which may include personal data, to generate scores for you relating to different cognitive functions. These scores are generated by automated processing and will affect the therapy components you have access to and/or are recommended to you in the app. Automated processing is therefore necessary for the provision of Alena’s products and services.
We understand that this is likely to be considered to be profiling for the purposes of applicable data protection laws, including the GDPR and the UK DPA 2018. We have considered the relevant issues and have determined that there are no legal implications that would occur as a result of the outputs produced by these processing activities, and that we have adequate safeguards and procedures in place to ensure that risk of errors is minimized and that decisions are accurate
In consenting to the privacy policy, and/or by using the app, you are consenting to automated decision making with respect to your personal data for the purpose of Alena providing its products and services to you.
WHO WE SHARE YOU PERSONAL DATA WITH
We may store your personal data on the servers of our cloud service provider Google Cloud Platform, which for the purposes of the General Data Protection Regulation 2016/679 (GDPR) and the UK Data Protection Act 2018 (UK DPA 2018) is considered to be sharing.
We may use TypeForm to display exercises and assessments in the Alena app and store your responses. None of your personally identifiable information from the app will be shared with TypeForm. If you would like your exercise or assessment data to be deleted please contact us at contact@alena.com.
We may use external artificial intelligence services such as those provided by OpenAI to create content for you, such as personalized exercise summaries, emails, goal suggestions, exposure ideas and similar features that Alena develops in the future. Alena may share with such external services data that will not directly personally identify you, such as your goals, situations, beliefs and thoughts, and other information you enter into the app, for the purpose of delivering personalized content to you. Alena will not share your personally identifiable information such as your name or email address with these services.
Outside of the foregoing, we will never share or sell your personal data unless you explicitly request us to do so.
INTERNATIONAL TRANSFERS
We will only process your personal data in the United Kingdom or in the European Union and will not transfer your personal data to parties outside of these jurisdictions other than in cases where it’s required for the delivery of our service.
HOW WE PROTECT YOUR PERSONAL DATA
The security of your personal data is important to us. As noted in the "Who We Share Your Personal Data With" section, we store your personal data on the servers of our cloud service provider Google Cloud Platform, who have industry standard security measures in place to protect the personal data which it stores for us.
YOUR RIGHTS
Under applicable data protection laws, including the GDPR and the UK DPA 2018, you have a number of rights, including:
Right of access – you have the right to obtain from us confirmation of whether or not we are processing your personal data and where we are, you are entitled to a copy of such personal data and certain other details about our processing of such personal data. You can make a request for access to any of your personal data we are processing free of charge by contacting us at contact@alena.com.
Right of rectification – we want to ensure the personal data we hold about you is accurate. You have the right to request that we rectify any inaccurate personal data or complete any incomplete personal data we store.
Right of erasure – in certain circumstances, you have the right to request that we erase any personal data of yours that we hold. We are only required to comply with such a request in certain circumstances – if you would like to make such a request, us at contact@alena.com to discuss whether we can comply.
Right to restrict processing – in certain circumstances, you have the right to restrict how we process your personal data. Again, we are only required to comply with such a request in certain circumstances-– if you would like to make such a request, please contact us at contact@alena.com to discuss whether we can comply.
Right to data portability – in certain circumstances you have a right to (i) receive from us any of your personal data we hold, in a structured, commonly used and machine-readable format; and (ii) transmit such personal data to another data controller without interference from us. As with the above, we are only required to comply with such a request in certain circumstances-– if you would like to make such a request, please contact us at contact@alena.com to discuss whether we can comply.
Right to object – in certain circumstances you can object to our processing of your personal data, such as where our processing is based on your consent or our legitimate interest. As with the above, we are only required to comply with such a request in certain circumstances-– if you would like to make such a request, please contact us at contact@alena.com to discuss whether we can comply.
Right to withdraw consent - where we process your personal data on the legal basis of consent, you may withdraw your consent at any time. Where you withdraw your consent, such withdrawal will not affect the lawfulness of our processing based on such consent prior to such withdrawal.
Right to complain – if you are unhappy about how we have processed or are processing your personal data, please contact us at contact@alena.com in the first instance and we will try our best to resolve the issue. If we have been unable to resolve the issue, or if you do not wish to raise the issue with us directly, you have the right to complain to the Information Commissioner's Office (ICO). You can do so by contacting the ICO at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or visit their website https://ico.org.uk.
RETENTION OF YOUR PERSONAL DATA
We keep your personal data for only as long as we need to for legal and business purposes – taking into account local laws, contractual obligations, and the needs of our users. When we no longer need personal data, we securely delete or destroy it. If you would like more information about our retention periods please contact us at contact@alena.com.
CHANGES TO OUR PRIVACY NOTICE
We may update this Notice from time to time. We will inform you of any changes by posting the updated Notice on the app, and may do so without other notice to you. You are advised to review this Notice periodically for any changes.