PRIVACY POLICY

Rapport Platform, together with its partners (“Rapport", "we” or “us”) operates this website (the “Platform", "Rapport Platform” or “website”). We understand and respect the importance of your privacy and are committed to safeguarding your personal information. In this Privacy Policy (“Policy“), we describe our practices in relation to the collection, use, disclosure, and protection of your personal information within our Platform. 

We encourage you to read this Policy in full to understand our data-handling practices before using our Platform. If you have any questions or concerns about this Policy or our practices, please feel free to contact us at info@rapport.com.ua.

GENERAL INFORMATION

By using the Platform as well as engaging with Rapport in any way, you agree to the collection and use of your information in accordance with this Policy that explains:

Rapport ensures that this Policy is in compliance with the following Laws:

Despite our primary operations being conducted in Ukraine, our privacy practices are designed in accordance with international legal standards.

Additionally, we assume that we may unintentionally receive through the Platform, store, process, and transfer the personal data of individuals located in countries or regions not specifically mentioned in this Policy. Nevertheless, we assure that for these individuals, the level of personal data protection and security will be no lower than that required by the legislation of those countries.

We do not act as providers of medical services, licensed doctors, or medical consultants. Rapport is an independent provider of digital services that offers technical capabilities to optimize communication between mental well-being specialists and users. We do not have the right to provide medical consultations, make diagnoses, or make any decisions in the field of healthcare. Nothing in this Policy or on the Platform should be construed as establishing a relationship for the provision of medical services by us.

DEFINITIONS

 

We may collect and process personal data related to the following data subjects:  

 

PERSONAL DATA THAT WE COLLECT

Below is a list of types of personal data that we may collect and use about you:

Please note that the specific range of personal data we collect varies on a case-by-case basis, and, among other things, depends on how you interact with us through the Platform.

Moreover, we can collect some amount of information about you (such as your language preferences, operating system, device settings, etc.) using the cookies and other similar technologies on the Platform (please see detail in Section “Use of Cookies").

HOW WE COLLECT THE PERSONAL DATA

We receive personal data directly from you when you interact with us, especially when:

In general, you are not obliged to provide your personal data to us. However, most probably we will not manage to fulfill your requests or provide you with the access to the Platform unless you do so. 

Please note that we may combine personal data about you collected from different sources. 

SPECIAL RULES WHEN PERSONAL DATA IS NOT COLLECTED DIRECTLY BY RAPPORT

We may get your personal data indirectly (for example, when a Specialist adds information about you as a User while completing their account on the platform). In such cases, Specialists are required to independently obtain Users’ consent to transfer their personal data to the Platform. We process such data, presuming that Specialists have obtained the necessary consent from Users. The Specialist who provided us with the User’s data is responsible for obtaining that User’s consent for transferring their data to the Platform.

NOTE: If you are a Specialist, please, make sure to get the User’s consent before sharing his/her/their personal data with us. The User’s consent should be explicit, freely given, specific, informed, and unambiguous and cover transferring of the User’s personal data to us and the processing of the User’s personal data by us according to this Policy. In case of any requests regarding the compliance of processing the Users’ personal data, you should be able to demonstrate appropriate evidence of the Users’ consent upon request.

HOW WE USE THE PERSONAL DATA 

Rapport may use your personal data to operate, provide, develop, and improve the Platform. These purposes include:

LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA

The legal basis upon which we collect, use, store, and otherwise process your personal data will depend on the personal data concerned and the specific purpose for which it is needed.

In general, we rely on one of the following grounds:

You may be assured that we use your personal data in ways that you would reasonably expect, and our legitimate interest serves as a legal basis for collection and processing your personal data only if, and to the extent it does not interfere with your rights and freedoms.

You have the right to object to these grounds of processing your personal data by contacting us (please see details in Section “Contacts”), upon which we will delete your personal data without further delay (unless we have a separate legitimate ground for further processing).

NOTE: you are free to withdraw your consent at any time by contacting us (please see details in Section “Contacts”), upon which we will delete your personal data without further delay (unless we have a separate legitimate ground for further processing). If you withdraw your consent, it will not affect the lawfulness of prior processing your personal data based on your consent before you withdrew it.  

Please be assured we will handle your personal data only in line with the purpose for which it was collected. If at any moment we intend to process your personal data for any other purpose, we will not do this without sending you respective notification / your prior explicit consent (subject to the exclusions and limitations which may be provided in the provisions of domestic and/or international law).

If you have any questions or need more information concerning the legal basis on which we collect your personal data, please contact us to clarify further details (please see details in Section “Contacts").

HOW LONG WE KEEP YOUR PERSONAL DATA

To determine the appropriate retention period for your personal data, we consider (1) the amount, nature, and sensitivity of the personal data in question; (2) the potential risk of harm from unauthorized use or disclosure of your personal data; (3) the purposes for which we process your personal data; (4) whether we can achieve those purposes through any other means; and (5) the applicable legal requirements.

We do not keep your personal data for any longer than is necessary (a) to fulfill the purpose for which we collected it (you may find more details in Section “How we use the personal data”); (b) to comply with domestic and/or international law, or other regulatory obligations (for instance, accounting or reporting requirements) that apply to our business and services we provide; or (c) to assert and/or defend against legal claims.

For example,we will keep your personal data:

YOUR RIGHTS WITH RESPECT TO PERSONAL DATA

As a data subject, you have certain rights under domestic and/or international law in relation to the personal data we hold about you. The processing of your personal data may be subject to:

Where the processing of your personal data is subject to the mentioned data protection Laws, at a minimum you have the set of data subject rights provided below.

NOTE: If you are located in countries or regions with legislation that is not mentioned above, we guarantee you a level of personal data protection and security no lower than that required by the legislation of the aforementioned countries.

Right of access

If you ask us, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of such personal data (along with other details). There are some limitations and exceptions concerning this right: for example, where information is legally privileged, or if providing you with the information would reveal any personal data of another person.

Right to data portability

In certain circumstances, you have the right to receive your personal data provided by you to us and reuse it elsewhere, or send such data to another organization (or ask us to do so if technically feasible); this is regarding where (1) our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you, and (2) the processing is carried out by automated means.

Right to rectification

You may require us to update or correct any inaccurate personal data or complete any incomplete personal data concerning you. If you do, we will take reasonable steps to check the accuracy and correct your personal data. Please let us know if any of your personal data changes so that we can keep it accurate and up-to-date. If you are entitled to rectification and if we have shared your personal data with others, we will let them know about the rectification where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly. 

Also note that Rapport is not required to notify third parties to whom your personal data has been disclosed of any rectification when such notification involves an unreasonable burden or disproportionate effort.

You also have the right to request the correction of your data directly by contacting us using the details provided in this Policy.

Withdrawal of consent (right to opt-out)

If we rely on your explicit consent as our legal basis or any other legal basis mentioned in this Policy for processing your personal data, you have the right to withdraw that consent or to opt out of data processing (unless we have a separate legitimate ground for further processing) at any time by contacting us (please see details in Section “Contacts” herein below). It will not affect the lawfulness of processing before you decide to opt-out or withdraw your consent.

Right to object

You can ask us to stop processing your personal data and we will abide so, if we are:

Right to erasure

You can ask us to delete your personal data in some circumstances, for instance if you withdraw your consent (where applicable). For situations where, in accordance with the provisions of domestic and/or international law, we fulfill your request, Rapport will delete your personal data without undue delay. If you are entitled to erasure and if we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly. Also note that Rapport is not required to notify third parties to whom your personal data has been disclosed of any deletion when such notification involves a disproportionate effort or unreasonable burden.

You can request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent and there is no other legal basis for processing. In such cases, we will erase your personal data without undue delay, unless legal obligations require us to retain it.

Right to restriction of processing

You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances (such as where you contest the accuracy of that data or you object to us), so that we no longer process that personal data until that restriction is lifted. If you are entitled to restriction and if we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly.

Right to file a complaint

If you have a concern with respect to the way we process your personal data, you can report it to the relevant supervisory authority (please see details in Section “Complaints” herein below).

Please note that these rights are not absolute and in certain cases are subject to conditions as specified in the provisions of domestic and/or international law. For instance, it may happen if we have an overriding interest or legal obligation to continue to process your personal data.

You can exercise the above rights, where applicable, by contacting us directly (please see details in Section “Contacts”). We will respond to your request within the statutory period and typically seek to resolve the matter within one month. We will require you to provide satisfactory proof of your identity in order to ensure that your personal data is disclosed only to you.

While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests, or to impose restrictions or requirements upon such requests if required or permitted by provisions of domestic and/or international law but will explain “why” if we do so.

SHARING AND TRANSFERRING PERSONAL DATA

Please note that your personal data may be processed outside of the European Economic Area, US, particularly in Ukraine. Please be informed that Ukraine is not determined by some countries as a country that offers an adequate level of data protection, which entails certain risks of losing the protection provided under the applicable legislation, when your personal data is transferred outside of the US, or European Union/ European Economic Area. Moreover, we may transfer your personal data to other countries, for example, when a Specialist or User is located outside the specified areas. 

Rapport may exchange your personal data with its affiliates, associates, and partners. Moreover, we may share your personal data with our customers and third-party service providers (as described below) where and to the extent necessary in connection with the purposes described in this Policy. Anyway, you may be assured that we do not share personal data with third parties, except as (a) necessary for our legitimate professional and business needs; (b) necessary to carry out your requests; (c) necessary to provide our services to you; (d) pursuant to your explicit consent; (e) required or permitted by law; and/or (f) as otherwise described in this Policy. Rapport will only transfer personal data to such persons when they meet our strict standards on the processing of personal data and security and pass those same standards down to their sub-processors.

Where we believe that processing or other business activities on our behalf or in our interest are better performed by third parties (“third party service providers”), we may outsource respective operations to them and, consequently, transfer your personal data to those persons, such as our IT systems providers, website hosting providers, data analysis, data backup, security and cloud storage services, consultants and other providers. We only share personal data that they reasonably need to provide their services and will not transfer your personal data to any third parties for their own direct marketing purposes. We ensure that third party service providers are authorized to use your personal data only as necessary toprovide services on our behalf or in our interest. 

Please note that the storage of your personal data on servers and/or on software made available or hosted by third party service providers shall not be considered a disclosure of your personal data to third parties as far as third-party service providers do not have direct access to it. In all events, we shall ensure by contract that our third-party service providers protect your personal data that is shared with them. 

In an ongoing effort to better understandusers of our website, we may analyze anonymousand aggregateinformationin order tooperate, maintain, manage, and improve our websiteand/or services that we render. This aggregate information does not identify you personally. We may share this aggregate data with our customers, third party service providers and other persons. We may also disclose aggregated user statistics in order todescribe Rapport services or pursuing other lawful purposes. 

In certain situations, we may be required to disclose your personal data where we have a legal necessity or obligation to do so, including to meet the requirements set forth by domestic and/or international law. For instance, we may disclose your personal data to assert and/or defend against legal claims. 

In the event of a sale, merger, receivership, or transfer of all assets of Rapport, we reserve the right to assign or share your personal data with such third parties and their advisors. Please be assured that you will be sent notice of such an event should it occur with the ability to opt-out of such a transfer unless Rapport and/or such third parties have a separate legitimate ground for such transfer and further processing of your personal data.

PERSONAL DATA SECURITY

Rapport has security measures in place to protect information we process (including your personal data), which involve preventing, detecting, investigating, and resolving security threats, both during transmission and once we receive it.

We do our best to protect your personal data, whether in electronic or tangible form (e.g., hard copy), by sticking to appropriate internal policies and using state-of-the-art technical and organizational measures that follow the applicable requirements for the safe and lawful processing of personal data. 

Moreover, we restrict access to your personal data to authorized individuals among internal personnel, agents, or contractors of Rapport who need to access your personal data to perform specific tasks. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who are required to keep the information confidential.

Although we use industry-standard precautions to safeguard your personal data, the transmission of data over the Internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but 100% complete security does not presently exist anywhere online or offline. For this reason, you should take care in deciding what information you send to us, especially when your do so at your own initiative.

USE OF COOKIES

This Section explains how and why cookies and any other tracking technologies may be stored on and accessed from your device when you visit or use our Platform.

Please read this Section carefully before using our Platform.

What are “cookies”? Cookies (or similar technologies) are tiny text files containing small amounts of data about you and your interaction with our Platform. Cookies work by assigning users with unique reference codes (identifiers) that are placed on their devices when they access the website. Later (if they last longer than a web session) they are sent back to the originating website on each subsequent visit, or to another website that recognizes them. 

Please note that our Platform may also contain other tracking technologies such as “pixels” (or “web beacons”). These are typically small transparent images that provide us with website statistics. They are often used in conjunction with cookies, though they are not stored on your device in the same way. As a result, if you disable cookies, pixels may still load, but their functionality will be restricted. For simplicity, all such technologies are further collectively referred to as “cookies".

Some cookies are critical for the proper functioning of our website (“Necessary Cookies“), whereas others help us personalize and improve your experience while using the website (such as “Analytics Cookies”, “Preference Cookies“, “Statistic Cookies“, and “Marketing Cookies“). A list of cookies employed by us and third parties through our website is described in the Subsection “What cookies are used on this Platforn” herein below.

Cookies can remain on your device for different periods of time. Some of them are “Session Cookies” – they are only stored on the device during your browser session. In other words, they are automatically erased when you close your browser. Other ones like “Persistent Cookies” will remain on your device even after your browser session has ended until you manually erase them, or as they expire. They are used, for example, to remember you when you return to the website.

Our website uses both ‘first’ and ‘third’ party cookies depending on the domain placing/providing them. First-Party Cookies are those set directly by this website, whereas Third-Party Cookies are placed or provided by other domains (please see the list of such third parties herein in Subsection “Third parties”). Please note that we have no (or limited) control over Third-Party Cookies.

If you are accessing our website from the United States, or other non- European Union/ European Economic Area countries, or the United Kingdom, you have the right to restrict us from of storing and accessing any cookies, pixels and other tracking technologies which do not refer to Necessary Cookies. 

If you are accessing our website from the European Union/ European Economic Area, or the United Kingdom you will see a cookie banner on your first visit.

By clicking ‘Accept’ on the cookie banner, you give us your consent to store and access cookies as described in this Section.

By clicking ‘Reject’ on the cookie banner, you do not allow us to store and access any cookies, pixels and other tracking technologies which do not refer to Necessary Cookies. 

However, it may disrupt the normal functioning of our website (and have an adverse impact on your user experience). 

Data collected. Our website uses cookies to record web-session information including:

We use the information that we gather in order to evaluate the website’s usage, content, navigability, and composition. This statistical analysis allows us to improve our website, make your user experience more enjoyable, and provide value-added services.

How we use cookies. We use cookies for a number of reasons, like ensuring the proper functioning of our website, improving your user experience, trend analysis, and measuring the effectiveness of this Platform. 

What we don’t do with cookies. We never share or sell any information about you (including your personal data) except as and to the extent expressly stated in our policies and/or communications with you. Please also be assured that cookies cannot be used to run programs or deliver viruses to your devices. 

Consent for cookies. In most cases, we will need your consent in order to use cookies on this website. The exception refers to Necessary Cookies that are needed to carry out the transmission of a communication over a network, or essential to the inherent functionality of the website – such cookies are used automatically, by default, once you access our Platform.

What cookies are used on this Platforn? You can find the details of cookies used on this website below:

Disabling cookies. Most internet browsers are initially set up to automatically accept cookies. You can manage cookies by adjusting the appropriate settings on your browser, although some of our website features may not function as a result.

You can follow the links provided below to manage the cookie settings on your device depending on the browser you use:

Moreover, you can find useful information about managing cookie preferences on the All About Cookies website – it is a free resource which explains:

LINKS TO OTHER WEBSITES

Our website (including this Policy) may contain links to other websites, and you should review the privacy policies on those sites. We have no responsibility for the policies and practices of those sites.

CHANGES TO THIS POLICY

We may from time to time, modify thisPolicy, upon which we will also update the ‘Last Revised’ date stated herein above. Even though we may inform you about any changes hereof (especially by sending you an electronic notice if you provided us with your e-mail address), you are still advised to visit this page regularlyfor the latest information on our privacy practices with regard to our privacy practices.

COMPLAINTS

If you consider that your personal data is processed in contradiction with the provisions of domestic and/or international law, we ask you to inform us about such a contradiction, and we will resolve it as soon as possible (please see details in Section “Contacts” herein below). Additionally, you also have the right to file a complaint directly with the respective personal data protection authority, namely:

NOTE: If you are located in countries or regions not mentioned above, you may contact us, and we will provide you with the contact details of the competent authority in your country or region to which you can file a complaint (please see details in Section “Contacts” herein below). 

CONTACTS

If you (a) have any questions or complaints regarding this Policy or the way your personal data is processed; (b) would like to report any suspicious activity, including automated messages or calls from parties you cannot identify; or (c) would like to exercise a legal right in relation to your personal data, please contact us via the email: info@rapport.com.ua