Privacy Policy

1. Important Information and Who We Are

This privacy policy gives you information about how CDRA Ltd collects and uses your personal data through your use of this website and our app, including any data you may provide when you register with us or purchase a membership.

The CDRA website and app are not intended for children and we do not knowingly collect data relating to children.

Controller

CDRA Ltd, a company registered in England and Wales with company number 17310956, whose registered office is at 11-12 Hallmark Trading Centre, Firth Way, Wembley, HA9 0LS, is the controller and responsible for your personal data (collectively referred to as “CDRA”, “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

2. The Types of Personal Data We Collect 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 kinds of personal data about you which we have grouped together as follows:

• Identity Data includes full name (encrypted at rest), professional registration body and membership number (encrypted at rest), proof of enrolment onto an accredited training programme for student/trainee mental health professionals, clinical calibration information (therapeutic modality, population, setting, years qualified and clinical voice preferences).
• Contact Data includes email address and telephone numbers.
• Technical Data includes login timestamps and session metadata, and app usage activity.
• Profile Data includes your username and password, subscription status and clinical calibration preferences.
• Usage Data includes login activity and app usage patterns.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website or app feature in order to analyse general trends in how users are interacting with our website and app to help improve the website and app and our service offering.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our services;
• create an account on our app or website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our app or website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

We do not collect or process payment or card information. Where you choose to make a payment for our services, you will be redirected to Stripe, which collects your payment information directly from you. Stripe acts as an independent data controller and processes your personal data in accordance with its own privacy policy. CDRA does not receive, store, or otherwise process your payment details.

4. How We Use Your Personal Data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

For more information about the cookies we use, please see our Cookie Policy.

5. Disclosures of Your Personal Data

We may share your personal data where necessary with the parties set out below for the purposes set out in section 4 above.

• We use Vercel as our hosting provider. Vercel may process limited technical data, such as standard server logs. Vercel processes such data strictly in accordance with our instructions and in accordance with their Data Processing Addendum.
• We use Supabase as our database and backup host. Supabase stores and manages certain data on our behalf as part of providing the CDRA App/services. Supabase processes such data strictly in accordance with our instructions and their Data Processing Addendum.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We shall not process, transfer or otherwise disclose any Personal Data outside the United Kingdom without your prior written consent, except where such transfer is carried out in accordance with applicable Data Protection Laws and supported by appropriate safeguards. You acknowledge that Personal Data may be transferred outside of the United Kingdom via our sub-processors (Vercel and Supabase).

7. Data Security

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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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 processing of your personal data where we are relying on a legitimate interest as the legal basis for that particular use of your data.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
• Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
• Request restriction of processing of your personal data in certain circumstances.

If you wish to exercise any of the rights set out above, please contact us using the contact details in paragraph 10.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We will respond to all legitimate requests without undue delay, but in any event no later than one calendar month from the date you made the request.

10. Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us:

• Email: d@davidwatermanpsychotherapist.co.uk
• Post: 11-12 Hallmark Trading Centre, Firth Way, Wembley, HA9 0LS

11. Complaints

You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification. You can make a complaint to CDRA by emailing: d@davidwatermanpsychotherapist.co.uk.

12. Changes to the Privacy Policy

We keep our privacy policy under regular review.

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 your relationship with us, for example a new address or email address.

13. Voice Input and Dictation

CDRA never records, receives, or stores your voice. We only ever receive the text you choose to submit.

If you choose to dictate your notes using your device's microphone, that speech-to-text processing is handled entirely by your phone or computer — not by CDRA. The microphone icon on your device keyboard connects to your phone's built-in dictation feature, which converts your speech to text before anything is sent to CDRA.

Whether that dictation is processed locally on your device or sent to your phone manufacturer's servers depends on your device, language, and settings. Apple states that dictation is processed on-device for many supported devices and languages, but this is not guaranteed for all devices or situations.

To check whether your iPhone processes dictation on-device: go to Settings > General > Keyboard > Dictation. If your device supports on-device processing, iOS will indicate that your audio and transcripts are processed on your device and not sent to Apple servers. If on-device processing is not available for your device or language, speech may be processed by Apple's servers. Apple states that audio processed this way is not stored, unless you have opted into “Improve Siri & Dictation” in your settings.

• Android devices may send audio to Google servers for processing. This is governed by Google's own privacy policy, not ours.

If you are recording confidential clinical material, we recommend checking your own device settings before relying on dictation. If in any doubt, typing your notes directly is always the safest option. CDRA works equally well with typed input.

14. Third-party Links

Our website or app may include links to third-party 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 statements. When you leave our website or app, we encourage you to read the privacy policy of every website or app you visit.