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PRIVACY POLICY

  1. "Rapport" platform together with its partners ("Rapport", "we” or “us”) manages this website (hereinafter – “Platform", "Rapport platform” or “website"). We understand and respect the importance of your privacy and are committed to protecting your personal information. In this Privacy Policy (“Policy“) we describe our practices regarding the collection, use, disclosure and protection of your personal information on our Platform.We encourage you to read this Policy in its entirety to understand our data processing practices before using the Platform. If you have any questions or concerns about this Policy or our practices, please contact us at info@rapport.com.ua. GENERAL INFORMATIONBy using the Platform and interacting with Rapport in any other way, you consent to the collection and use of your information in accordance with this Policy, which explains:
    • what personal data we collect;
    • how we use, store and process your personal data;
    • the conditions under which we may disclose your personal data to others;
    • how we ensure the security of your personal data; and
    • the rights available to you in relation to your personal data.

    Rapport ensures compliance of this Policy with the following laws:

    • Ukraine: Law of Ukraine No. 2997-VI dated June 1, 2010 "On Personal Data Protection"; 
    • EU: Regulation of the European Parliament and the Council (EU) 2016/679 dated 04/27/2016; 
    • USA: Privacy Act of 1974, Virginia Consumer Protection Act (VCPDA), California Consumer Privacy Act (CCPA) (as amended by California Privacy Rights Act (CPRA)), Colorado Privacy Act (CPA), Utah Consumer Privacy Act (UCPA), Connecticut Data Privacy Act (CTDPA) and other state data privacy laws.

    Despite the fact that our main activity is carried out in Ukraine, our privacy practices are designed with international legal standards in mind.In addition, we acknowledge that we may inadvertently receive through the Platform, store, process and transfer personal data of individuals located in countries or regions not mentioned in this Policy. However, we assure that for these persons the level of protection and security of personal data will not be lower than the requirements established by the legislation of the mentioned countries.We are not health care providers, licensed physicians, or medical consultants. Rapport is an independent digital service provider that provides technical capabilities to optimize the communication of mental well-being professionals with users. We are not authorized to provide medical advice, make diagnoses or make any health care decisions. Nothing in this Policy or on the Platform should be construed as establishing a relationship regarding the provision of medical services by us.DEFINITION"Personal data” is any information that identifies, or can be used to identify, an individual who interacts with us (“data subject(s).” or “you"); an identifiable natural person is a person who can be identified directly or indirectly, in particular by reference to their data, such as first and last name, identification number, location data, online identifier or to one or more factors that characterize the physical , physiological, genetic, mental, economic, cultural or social identity of that person.  The Platform may collect and process personal data relating to the following data subjects:

    • specialists who provide consulting services in the field of mental well-being ("specialists”) and use an account on the Platform for operational optimization of their activities;  
    • users who provided their personal data for the purpose of receiving specialist services on our Platform (“users”); and  
    • any other visitors to the Platform.

    "Processing” is any operation (use) performed with personal data, regardless of whether it is performed by automated means. Processing includes: collection, recording, organization, structuring, storage, adaptation or modification, extraction, disclosure by transmission, distribution or other means of providing access, matching or combining, restriction, deletion or destruction of personal data. "Data Controller" is a natural or legal person, state body, agency or other body that determines the purposes and means of personal data processing; the specialist in this sense is the Data Controller.PERSONAL DATA WE COLLECTBelow are the types of personal data we may collect and use:

    • Contact details: information we use to contact you, including physical address, email address, postal address, telephone number, user identifiers in messengers and telecommunications applications;
    • Identification and Demographic Data: information we use to identify you, including full name, age, gender, date of birth, country of temporary and/or permanent residence, etc.;
    • Financial data: information about a person's financial account, including bank account details, payment card details;
    • Professional data: information related to professional experience, such as data on education, certifications, licenses, professional experience and skills, qualifications, etc.;
    • Other information: such as interests and preferences, as well as any other personal data provided by data subjects on their own initiative.

    Please note that the specific amount of personal data we collect varies on a case-by-case basis and depends, among other things, on how you interact with us through the Platform.In addition, we may collect certain technical information about you (such as your language preferences, operating system data, device settings, etc.) using cookies and other similar technologies on the Platform (for details, see “Use of cookies").HOW WE COLLECT PERSONAL DATAWe receive personal data directly from you when you interact with us, including when:

    • you create an account on the Platform;
    • you use the platform as a Specialist or User and provide your personal data in this context (for example, your contact details);
    • you visit the Platform, participate in its interactive features (including but not limited to the use of cookies and other similar technologies, as explained in our section “Use of cookies”);
    • you contact us directly by any means (for example, via email);
    • you provide feedback about the Platform;
    • you ask us to provide any other information.

    In general, you are not obliged to provide us with your personal data. However, if you do not do so, we will most likely not be able to provide you with access to the Platform. Please note that we may combine personal data about you collected from different sources.SPECIAL RULES WHEN PERSONAL DATA IS NOT COLLECTED DIRECTLYWe may receive your personal data indirectly (for example, when the Specialist adds information about you as a User when using his account on the Platform). In this case, the Specialists are obliged to independently obtain the consent of the Users to transfer their personal data to the Platform. We process such data assuming that the Specialists have obtained the appropriate consent from the Users. The specialist who provided us with the User's data is responsible for obtaining consent from such User to transfer his data to the Platform.NOTE: If you are a Specialist, please ensure that you obtain the User's consent before sharing their personal data with us. The User's consent must be explicit, voluntary, specific, informed and unambiguous, and cover the transfer of the User's personal data to us and the processing of the User's personal data by us in accordance with this Policy. In case of any requests regarding compliance with the requirements for the processing of Users' personal data, you must be able to provide relevant evidence of the Users' consent at our request.HOW WE USE PERSONAL DATARapport may use your personal data to operate, provide, develop and improve the Platform. These goals include: 

    • fulfilling our contractual obligations; 
    • management of the Platform, namely: 
      • enabling you to visit and search the Platform;
      • providing you with the opportunity to participate in the interactive functions of the Platform (at your request); 
      • improving the operation of the Platform and improving the user experience;
      • creating, publishing and improving the content most relevant to you;
      • finding, investigating and correcting errors related to the Platform. 
    • fulfillment of requirements established by national and/or international legislation (for example: laws on taxation, accounting, reporting, anti-money laundering, etc.), fulfillment of court decisions and other legal requests of authorized regulatory bodies; 
    • protecting the rights, property and safety of Rapport and third parties (for example, preventing fraud and other prohibited or illegal activities);
    • for the efficient and proper conduct of our business, including managing our finances, planning and testing systems and processes, managing communications, corporate governance and auditing. 
    • other purposes that are not explicitly defined by this Policy, but their content may result from data processing.

    LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATAThe legal basis on which we collect, use, store and otherwise process your personal data will depend on the specific personal data and the purpose for which it is required.In general, we rely on one of the following grounds: 

    • Our legitimate interest, which consists of: 
      • keeping our records up to date;
      • improving the Platform and informing you about it;
      • effective performance of our legal and contractual obligations;
      • compliance with the rules and instructions of the controlling authorities. 

    You can be sure that we use your personal data as you could reasonably expect, and our legitimate interests are the legal basis for collecting and processing your personal data only to the extent that it does not infringe your rights and freedoms. You have the right to object to these grounds for the processing of your personal data by sending us a corresponding request (for details, see the section “Contacts”), after which we will delete your personal data without delay (unless we have a separate legal basis for further processing). 

    • Yours is obvious consent: in other words, when you allow us to process your personal data for a specific purpose. 

    NOTE: you can withdraw your consent at any time by sending us an appropriate request (for details, see the section “Contacts”), after which we will delete your personal data without delay (unless we have a separate legal basis for further processing). If you withdraw your consent, this will not affect the lawfulness of the previous processing of your personal data based on your consent before its withdrawal.

    • For performance of our contractual obligations pursuant to separate contractual arrangements with Specialists or to comply with our other legal obligations, including but not limited to:
      • meeting any requirement of national and/or international legislation (for example: accounting, reporting, anti-money laundering regulations, etc.);
      • execution of court decisions or other legal requests of authorized regulatory bodies; or
      • defending and/or defending against legal claims/demands of third parties.

    Please be assured that we will process your personal data only in accordance with the purpose for which it was collected. If at any time we plan to process your personal data for any other purpose, we will not do so without providing you with appropriate notice/your prior express consent (subject to exceptions and limitations that may be provided by national and/or international legislation). If you have any questions or need additional information about the legal basis on which we collect your personal data, please contact us (for details, see the section “Contacts").HOW LONG DO WE KEEP YOUR PERSONAL DATATo determine the appropriate retention period for your personal data, we consider: (1) the scope, nature and sensitivity of the relevant personal data; (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 these goals in another way; and (5) applicable legal requirements.We do not keep your personal data for longer than is necessary: (a) to fulfill the purpose for which we collected it (for details, see the section “How we use personal data”); (b) to comply with national and/or international laws or other obligations (such as accounting or reporting requirements) that apply to our business; or (c) to defend and/or defend against legal claims/demands from third parties.For example, we will store your personal data: 

    • collected on the basis of your consent - during the period for which you have given your consent;
    • collected and processed on the basis of contractual relations - during the validity period of such relations and some period after that, taking into account the conditions of specific contractual relations;
    • received in connection with your request, request and/or complaint – until the issue related to such request, request and/or complaint is resolved.

    YOUR RIGHTS REGARDING PERSONAL DATAAs a data subject, you have certain rights under national and/or international law in relation to your personal data that we process. The processing of your personal data may be subject to:

    • the legislation of Ukraine on data protection, in particular the Law of Ukraine No. 2997-VI dated June 1, 2010 "On the Protection of Personal Data";
    • European Union legislation on data protection, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 (for example, when you are physically located in one of the EU countries or the European Economic Area); or
    • US data protection laws, including the Privacy Act of 1974, the Virginia Consumer Protection Act (VCPDA), the California Consumer Privacy Act (CCPA) (as amended by the California Privacy Rights Act (CPRA)), Colorado State Law Privacy Act (CPA), Utah Consumer Privacy Act (UCPA), Connecticut Act on Data Privacy Act (CTDPA) and other state data privacy laws.

    If the processing of your personal data is subject to the above data protection laws, the minimum set of data subject rights includes the following rights. NOTE: If you are located in countries or regions with laws that are not listed above, we guarantee you a level of protection and security of personal data no lower than that required by the laws of the above countries.Right of access
    If you contact us, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of such personal data (together with other details). Certain limitations and exceptions may apply to this right, such as when the information is protected by legal privilege or when providing the information to you would reveal another person's personal data.The right to transfer data
    In certain cases, you have the right to obtain your personal data that you have provided to us for further use elsewhere or to transfer it to another organization (or ask us to do so if technically possible). This right applies when: (1) our legal basis for processing the data is your consent or the need to perform a contract with you, and (2) the processing is carried out by automated means.Right to rectificationYou may request that we update or correct any of your inaccurate personal data or supplement any incomplete personal data. In such event, we will take all reasonable steps to verify the accuracy and correct your personal data. Please let us know if your personal data changes so that we can keep it accurate and up to date. If you have a right to rectification and we have shared your personal data with others, we will notify them of the rectification if possible. If you send us an appropriate request, and if possible and legal, we will also tell you to whom we have transferred your personal data, so that you can contact such persons directly. Also, please note that Rapport is under no obligation to notify third parties to whom your personal data has been disclosed of corrections if such notification creates an excessive burden or is a disproportionate effort.You also have the right to request correction of your data by contacting us at the contact details provided in this Policy.Withdrawal of consent (right of refusal)If we rely on your consent as our legal basis or any other legal basis mentioned in this Policy to process your personal data, you have the right to withdraw such consent or refuse to process the data (unless we have a separate legal basis for further processing) at any time by contacting us (see Contact section below). These actions will not affect the lawfulness of the processing before you decide to refuse or withdraw your consent.Right to TerminationYou can ask us to stop processing your personal data and we will comply with this request if we:

    • rely on our legitimate interest in processing your personal data, unless we can demonstrate other compelling legal grounds for the processing; or
    • process your personal data for direct marketing purposes.

    Right to deletionYou can ask us to delete your personal data in certain cases, for example if you withdraw your consent (where applicable). In cases where, in accordance with the provisions of national and/or international law, we comply with your request, Rapport will delete your personal data without undue delay. If you have the right to erasure and we have shared your personal data with others, we will notify them of the erasure whenever possible. If you ask us, and if possible and legal, we will also tell you to whom we have shared your personal data so that you can contact the relevant persons directly. Please also note that Rapport is not required to notify third parties to whom your personal data has been disclosed of the deletion if such notification creates an undue burden or is a disproportionate effort. 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 lawful basis for processing. In such cases, we will delete your personal data without undue delay, unless legal requirements oblige us to retain it.The right to restriction of processingYou can ask us to "block" or suspend the processing of your personal data in certain cases (for example, if you dispute the accuracy of that data or object to its processing) so that we no longer process that personal data until the restriction is lifted. If you have the right to a restriction, and if we have shared your personal data with others, we will inform them of this restriction when possible. If you ask us, and if possible and legal, we will also tell you to whom we have shared your personal data so that you can contact the relevant persons directly.The right to file a complaintIf you have a concern about the way we process your personal data, you can raise this with the relevant supervisory authority (see details under “Complaints” below).Please note that these rights are not absolute and in certain cases are subject to the conditions specified in the provisions of national and/or international law. For example, this may apply where we have an overriding interest or legal obligation to continue processing your personal data.You can exercise the above rights whenever possible by contacting us directly (see details under “Contacts"). We will respond to your request within the statutory time limit and usually aim to resolve the issue within one month. We will require you to verify your identity to ensure that your personal data is only disclosed to you.Although we will make reasonable efforts to comply with your request, we reserve the right to refuse such requests or comply only in part if required by national and/or international law, but we will explain to you “why” if this is the case .TRANSFER OF PERSONAL DATAPlease note that your personal data may be processed outside the European Union/European Economic Area and the USA, in particular in Ukraine. We inform you that Ukraine is not considered by some countries to be a country with an adequate level of data protection, which carries certain risks when your personal data is transferred outside the USA or the European Union/European Economic Area. In addition, we may transfer your personal data to other countries, for example, when the Specialist or User is located outside the specified territories.Rapport may exchange or share your personal data with third party service providers (as described below) when necessary in connection with the purposes described in this Policy. In any case, you can be assured that we do not share personal data with third parties, except when it is (a) necessary for our legitimate needs; (b) necessary to fulfill your requests; (c) necessary to provide access to the Platform; (d) with your consent; (e) required or permitted by law; and/or (f) as otherwise described in this Policy. Rapport will only share personal data with such individuals if they meet our strict standards for the processing of personal data and security and share those same standards with their subcontractors.When we believe that processing or other business operations on our behalf or in our interests are better performed by third parties (“Third party service providers”), we may delegate such operations to them and, accordingly, transfer your personal data to these persons. These include, but are not limited to, our IT systems/service providers, Platform hosting providers, data analysis, data backup, security and cloud storage providers, consultants and other providers. We only share the personal data that they reasonably need to provide the services and will not share your personal data with any third parties for their own direct marketing purposes. We ensure that third party service providers have the right to use your personal data only to the extent necessary to provide services on our behalf or in our interests.Please note that storing your personal data on servers and/or software provided or hosted by third-party service providers does not constitute disclosure of your personal data to third parties, as such service providers do not have direct access to it. In any case, we enter into agreements with our service providers to protect your personal data transmitted to them.We may analyze anonymous and aggregated information in order to support, manage and improve the Platform. This aggregate information does not identify you personally. We may share this aggregated data with our partners, third party service providers and others. We may also disclose aggregate user statistics to describe Rapport's operations or to pursue other legitimate purposes.In certain situations, we may be legally required to disclose your personal data, including to comply with requirements established by national and/or international law. For example, we may disclose your personal data to defend and/or defend legal claims/requirements.In the event of a sale, merger, appointment of a liquidator, or transfer of all of Rapport's assets, we reserve the right to disclose your personal data to such third parties and their advisors. Please be assured that you will be notified of such an event, should it occur, with the option to opt out of such transfer unless Rapport and/or such third parties have a separate legal basis for such transfer and further processing of your personal data.SECURITY OF PERSONAL DATARapport takes security measures to protect the information we process (including your personal data), which includes preventing, detecting, investigating and remediating cyber threats both during data transmission and after it is received.We do our best to protect your personal data, regardless of its form, by following appropriate internal policies and using modern technical and organizational measures that comply with current requirements for the safe and lawful processing/transfer of personal data.In addition, we limit access to your personal data to authorized individuals among Rapport's internal staff, agents or contractors who need access to your personal data to perform specific tasks. Your personal data is stored in secure networks and is accessible only to a limited number of persons who are obliged to keep the information confidential.Although we use standard measures to protect your personal data, the transmission of data over the Internet (including email) is never completely secure. We are committed to protecting personal data, but 100% security currently does not exist in either online or offline environments. For this reason, you should be careful in deciding what information you send to us, especially if you do so on your own initiative.USE OF COOKIESThis section explains how and why cookies and other tracking technologies may be stored on your device and used when you visit or use the Platform.Please read this section carefully before using the Platform.What are "cookies"? Cookies (or similar technologies) are small text files that contain a small amount of data about you and your interaction with the Platform. Cookies work by setting users unique codes (identifiers) that are stored on their devices when accessing the website. Later (if they are stored longer than the duration of the web session) they are sent back to the original website on each subsequent visit or to another website that recognizes them.Please note that the Platform may also contain other tracking technologies such as “pixels” (or “web beacons”). These are usually small transparent images that provide us with website statistics. They are often used in conjunction with cookies, although they are not stored on your device in the same way. As a result, if you disable cookies, pixels may still be loaded, but their functionality will be limited. For the sake of generalization, all such technologies are hereinafter collectively called "cookie files".Some cookies are critical for the proper functioning of our website (“Cookies are required”), while others help us personalize and improve your experience while using the website (such as “Analytical cookies", "Preference cookies", "Statistical cookies" and "Marketing cookies"). A list of cookies used by us and third parties through our website is provided in the subsection “What cookies the Platform uses” below.Cookies can remain on your device for different periods of time. Some of them are "Session cookies” – they are stored on the device only during your browser session. In other words, they are automatically deleted when you close your browser. Others such as “Persistent cookies”, will remain on your device even after your browser session ends, until you manually delete them or until 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 which domain hosts/provides them. First-party cookies are those that are set directly by a website, while third-party cookies are placed or served by other domains. Please note that we have no (or limited) control over third-party cookies.If you access our website from the United States or other countries outside the European Union/European Economic Area or from the United Kingdom, you have the right to restrict us from storing and accessing any cookies other than Necessary Cookies.If you access our website from the European Union/European Economic Area or from the United Kingdom, you will see a cookie information banner on your first visit.By clicking "Accept" (or any other word that indicates actual consent to the use of cookies) on the cookie banner, you give us your consent to store and access cookies as described in this section.By clicking “Reject” (or any other word that indicates you actually do not agree to the use of cookies) on the cookie banner, you do not allow us to store and access any cookies other than Necessary cookies. Necessary cookies are always used because not using them may disrupt the normal functioning of our website (and negatively affect your user experience). Data collection. Our website uses cookies to record information about web sessions, including:

    • the date and duration of your visit to the website;
    • the web pages you viewed during your visit;
    • your IP address;
    • the type and version of the browser you used; and
    • your device's operating system and other settings.

    We use the information we collect to evaluate the use of the website, its content, navigation and composition. This statistical analysis allows us to improve our website, make your user experience more pleasant and provide our services with better quality.How we use cookies. We use cookies for various reasons, such as ensuring our website functions properly, improving your user experience, analyzing trends and measuring the effectiveness of the Platform.What we don't do with cookies. We never share or sell any information about you (including your personal data) except as expressly stated in our policies and/or communications with you. Please also be sure that cookies cannot be used to launch programs or download viruses to your devices.Consent to the use of cookies. In most cases, we need your consent to use cookies. An exception is Necessary cookies, which are required for the transmission of messages over the network or for the functioning of the website - such cookies are used automatically, by default, as soon as you enter the Platform.What cookies does the Platform use?

    • Cookies are required. These cookies are necessary for you to browse the website and use its features - they provide basic website functionality, such as network management, web page navigation and access to secure areas of the website. Necessary cookies cannot be disabled by us. However, you can disable them by changing your browser settings (as described in the “Disabling cookies” section below), but this may negatively affect the functionality of the website.
    • Analytical cookies. We use analytical cookies to understand how visitors interact with the website, including metrics such as the number of visitors, bounce rate and traffic sources. This information helps us improve the performance of the website, providing a more efficient and convenient user experience.
    • Preference cookies. We use preference cookies to remember choices you make while using the website, such as your preferred language. This information changes the behavior or appearance of the website and helps make visits more personalized and comfortable for you.
    • Statistical cookies. Statistical cookies collect anonymous information about how people use our website. We integrate these cookies to obtain statistical information that tells us how long users spend on the website, how they use its web pages, which of them are the most viewed, and whether any errors occur. Ultimately, this helps to improve the user experience when browsing our website. The data stored by these cookies is usually anonymized, meaning it does not contain any personal data that can identify you.
    • Marketing cookies. Marketing cookies are used to track user behavior on the website. These cookies collect information about your browsing habits to make our or third-party websites more relevant to your interests.

    Disabling cookies. Most internet browsers are initially configured to automatically accept cookies. You can manage cookies by adjusting the appropriate settings in your browser, although some features of our website may not work as a result.You can use the following links to adjust the cookie settings on your device, depending on the browser you are using:

    • If you are using Google Chrome, see the details below link.
    • If you are using Mozilla Firefox, see the details below link.
    • If you are using Internet Explorer, see the details below link.
    • If you are using Opera, see the details below link.
    • If you're using Microsoft Edge, see the details below link.
    • If you're using Safari (on iPhone, iPad, or iPod touch), see the details below link.
    • If you're using Safari (on a MacBook), see the details below link.
    • If you are using Samsung Internet (on your phone), see the details below link.

    In addition, you can find useful information about managing cookies on the website All About Cookies is a free resource that explains:

    • what are cookies and how are they used (available at link);
    • how to delete cookies from your browser (available at link).

    LINKS TO OTHER WEBSITES  Our website (including this Policy) may contain links to other websites, and you should review the privacy policies of those websites as well. We are not responsible for the policies and practices of third-party websites. CHANGES TO THIS POLICY  We may change this Policy from time to time, at which point we will also update the “Last Updated” date on page 1 of the Policy. We may notify you of any changes (by sending an email if you have provided us with your email address), but we also encourage you to visit this page regularly for the latest information about our privacy practices. COMPLAINTSIf you believe that your personal data is being processed in violation of the provisions of national and/or international law, please notify us of such violation and we will resolve the issue as soon as possible (see details in the section “Contacts” below). In addition, you have the right to file a complaint directly with the relevant personal data protection authority, namely:

    NOTE: If you are located in countries or regions not mentioned above, you can contact us and we will provide you with the contact details of the competent authority in your country or region to which you can submit a complaint (see details under “Contacts” below).CONTACTSIf you (a) have any questions or complaints about this Policy or the way we process your personal data; (b) want to report any suspicious activity, including automated messages or calls from individuals whom you cannot identify; or (c) wish to exercise your legal right regarding your personal data, please contact us at this email address: info@rapport.com.ua

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