Last updated: 13th September 2021
This privacy statement (the “Privacy Statement”) sets out the turn2me statement relating to the collection and use of your personal information on the turn2me Website.
It will not be shared with, bartered, or sold to ANY third party, except when we are required to do so by law or where you are at risk to yourself or another. Your personal information is important to us. turn2me recognises that your privacy is very important to you and that we are under a legal obligation to protect the integrity of your personal information.
When you register with turn2me you will be asked to enter your username and some demographic information about you. All registered members agree to be bound by the terms of this Privacy Statement.
By using this Website, you provide your explicit consent to us and to the organisations directly involved in delivering our service, to collect, use, store, disclose and otherwise process your personal data (including special category data such as mental health related information and data) in accordance with the terms set out in this Privacy Statement.
What kind of information do we collect from you?
We collect information from you for the purposes of providing you with the most supportive experience, so that our Clinical and Support Team can help you through suggesting services to you and by monitoring (see our Content Monitoring Policy) your Content Posted to the Website.
Personal information you provide
We collect personal information from you when you register to this Website and when you apply for one of the services which we offer, this may be via an online form, an online assessment, a chat or video Counselling session, a direct message on site, an email or other means. It is necessary for us to collect sensitive and special category data (such as clinical and medical information) relating to you so that our Clinical and Support team can make a clinical decision if the service is safe and suitable for you and to make appropriate referrals to other services or Professional Counselling Bodies.
We collect your email and mobile number so that our team can contact you if required and so that SMS notifications and reminders can be sent. We collect your next of kin details and GP and some medical details when you apply for our Counselling Service per our Counselling Policy.
You may choose to not supply any personal information to us; however, doing so will mean you cannot register to and access the members’ area on this website, such as discussions, online support groups, online counselling and the like. Members may not share, copy or transmit any information posted on turn2me (including their own information). All information posted and / or published on turn2me shall remain within this website at all times.
Your usage of this Website
Information is collected in statistical form about the most frequently visited pages on this website. This is intended to help us understand how visitors use the website. turn2me analyses the log files of this website to better understand the volume of traffic to particular areas of this website.
This information helps us to better understand and serve your information needs. Although we do track the Internet address of the domains from which people visit us, our log files do not correlate individual visitors with the pages visited. Therefore, the individual user remains anonymous in this website’s log files.
We collect information about how you use this website, such as the types of content you view or engage with; the Services you use; the Services bookings you make; the people or accounts you interact with; and the time, frequency and duration of your activities. This information is collected and recorded so that our Clinical and Support Team can provide the most supportive and safest online environment to you and so that every member of our Clinical and Support Team can support you if needed at any time.
Donations on this Website
If you use turn2me to make a donation or a payment (such as when you make a donation directly or towards a 1 to 1 Counselling session), we collect information about the donation or transaction. This includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing and contact details.
You can opt-in to receive further updates about turn2me and donor emails. Where you make a donation to turn2me, we will retain your donor information where you provide it, for as long as we are required to do for tax and accounting purposes. Once this is fulfilled, we will delete your information from our system.
Assessments and Surveys that you may complete
When you register for and enter the turn2me website you may be asked to complete a number of assessments and surveys and enter some information, which may be sensitive data, about yourself.
The website asks for this information in order to provide you with tailored, and specifically relevant information about mental health related issues and concerns. The information is stored in the turn2me database along with information about the date and time you complete each exercise or survey.
It is necessary for us to collect sensitive and special category data (such as medical and mental health related information) relating to you so that our Clinical and Support team can make a clinical decision if the services we offer are safe and suitable for you.
Content Posted and Usage
We collect the content, communications and other information you provide when you use this website including when you sign up for an account, create or share content on Thought Catcher or through your use of our services including Thought Catcher, Support Groups and Counselling (where applicable)
Use of Personal Information and your Data
We use the information you provide for the following purposes: To provide a mental health support service and provide support to you Our mission is to provide professional mental health services online, this means that the data you share or post on this website can be reviewed by our Clinical and Support Team so that services and support can be offered to you.
Content posted to the website is within the live chat, Thought Catcher and Support Groups. Content posted in these services including Private thoughts and Public comments may be monitored by the turn2me Clinical and Support Teams to:
- Provide the most supportive experience to you
- Ensure the wellbeing and welfare of all Website Users and
What actions can we take when monitoring content posted? Through Monitoring Content Posted, the turn2me Clinical and Support Teams may:
- Directly contact you by onsite direct message, email, SMS if provided or through push site notifications if any Content Posted by you is deemed to be a concern for your wellbeing
- Add support and service usage notes in our system about you in order to provide you with the most supportive and safest experience and so that our Clinical and Support Team can help and support you when needed.
- Make suggestions or invite you to our Services through your Thought Catcher Feed, direct message or Email
- Please note that Monitoring of your Content Posted does not amount to a mental health diagnosis.
We cannot guarantee that all Content posted will be monitored.
Research and Development
To improve our service and help us make better decisions, we analyse personal data to find improvements and make clinicians aware of risks. We may from time to time engage in and publish anonymised research on aggregate data (you will never be identifiable as we will remove all identity information). As part of our commitment to continuously develop and improve the services we provide to you turn2me may invite you to participate in research which is entirely optional. Research conducted by turn2me is fully complaint with ethical standards and best practice.
Communication with you to provide services: We use the email you provide to send you Service Notifications (Set out Below) or if you have elected to provide email-based counselling. We use two-step verification for all our email accounts for added security.
Service Notifications by booking services on this Website we will contact you by email or SMS to send you service booking reminders. These act as important reminders so that you can avail of the services that you have booked on this Website. As places are limited to all of our services, we require you to receive these reminders.
Marketing Purposes turn2me maintains several e-mail lists to keep interested persons informed about events and other items of interest. Individuals can sign up to join our mailing lists in several ways, for example; in response to an e-mail message or by using a form on this Website. We do not sell, trade, lease, rent, loan or otherwise disclose the addresses on our lists to any third party.You have the option to opt-out of such communications if you wish. If you would like to opt out please visit here We will only ever use your personal information to send you an email for Marketing Purposes if you have explicitly opted in to receive these, and we will never give any of your personal information, your username or your browser details to any advertisers.
How long do we hold your data? Retention of Information
We will retain your Personal Data whilst your account is active, we recognise that some of our users use our Website less frequently than others.
We deem accounts to be inactive when no login or Website activity has happened for a period of 12 months. Unless already requested to do so by you we will delete your account and your non Clinical Data (where appropriate, see below) after this 12 month period, automatically.
Clinical Data Retention
We define Clinical Data as all data, notes and Clinical inputs by our Clinical and Support Team stored securely in our system from Thought Catcher, the Counselling service and Online Group Support Service including:
- Chat transcripts
- Emails that are Clinical in nature
- Files that are Clinical in nature
- Clinical notes including a record of supports offered to you
- Risk flags
If you engage in our 1:1 Counselling service or Online Group Support Service, the following will apply to data retention: The following are the Recommended minimum retention periods from the Medical Protection Society which turn2me applies:
- Healthcare records of an adult: eight years after last treatment or death.
- Children and young people: until the patient’s 25th birthday, or 26th if the young person was 17 at the conclusion of treatment, or eight years after the patient’s death.
This means that by engaging in Counselling on this Website, your Clinical Records and notes will be retained as set out above even after your account is deleted.
Data Disclosure Policy
turn2me will not use or disclose any information about you without your consent or unless we are required to do so by law or there is a significant imminent risk to you or others where non intervention could result in serious risk, harm or death or criminal activity. In such cases, we reserve the right to contact a third party including emergency services and the police.
Legitimate Interests You are entitled to object to the use of your personal data, in the event of turn2me using it for legitimate purposes, as explained in the previous paragraph. If you object, turn2me will cease to use and process your personal data for that purpose unless we can show there are compelling legitimate reasons for us to continue or we need to use the personal data for the purposes of legal claims. If you do not agree to this, you cannot continue to use this Website so please follow the Account Deletion process below.
Third Party Services
We require a number of third parties to deliver our service. Without these, we cannot provide you with a service.
These include all the companies and services listed:Name | Service | Data Controller/Data Processor | Description | Privacy URL | Circulator | Email marketing | Data Processor | Email marketing, site news and offers | https://www.circulator.com/privacy/ | Google | Google Analytics | Data Processor | User analytics tracking | https://policies.google.com/privacy | Twilio | SMS | Data Processor | SMS services | https://www.twilio.com/legal/privacy | Google | G Suite | Data Processor | Productivity and collaborations tools | https://policies.google.com/privacy | Tokbox | Tokbox | Data Processor | Cloud based service provider for video | https://tokbox.com/support/privacy-policy | Stripe | Stripe | Data Controller and Processor | Online payment processing | https://stripe.com/ie/privacy | Mandrill | Transactional SMTP | Data Processor | Relays emails through SMTP service, | https://mailchimp.com/legal/privacy/Storage and security of your personal informationWe take reasonable measures to protect the information you share with us from unauthorised access or disclosure.
All the information gathered is stored on turn2Me servers and is subject to reasonable ongoing security measures. turn2me will endeavour to take all reasonable steps to keep all information about you secure. Your information is held on a secure server that is in controlled facilities. In addition, all the staff on turn2me team as well as all employees, contractors and agents that provide services related to our information systems, are obliged by law to respect the confidentiality of any personal information and/or research information held by turn2me. You can also play an important role in keeping your personal information secure using a pseudo username and by keeping your password secure.
Who has access to the information we collect?
Our Clinical and Support Team, who are all bound by strict confidentiality agreements. They only access the information that they need to do their jobs, and no more.
Your rights in relation to your personal data Subject Access Request (SAR) You may at any time request a copy of your personal data from turn2me. This right can be exercised by writing to turn2me at firstname.lastname@example.org. Requests will be processed within 1 month from the date of the receipt of the subject access request. Subject access requests must be made in writing and include a copy of identification (such as driver licence or passport, this is to make sure that your personal information is not given to the wrong person) and must be addressed to the Data Protection Officer (see below).
How you can update your information?
We realise that your personal information, including name and e-mail address, is subject to change over time. In the effort to keep your information current and accurate, please update your profile in the members area of the site to update your details.
Requesting erasure of your data and limiting use of your Personal Data You have the right to request erasure of your data, if you wish to have your non-Clinical data erased your account will be deleted and you will no longer be able to make use of the website. This right can be exercised by requesting the deletion of your account in the website. The Clinical Data Retention Policy where applicable (As above) applies to requests for data erasure. You also have the right to request restriction on the use, of your personal data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. This right can be exercised by writing to turn2me at email@example.com
Withdrawal of Consent
In any case where we are relying on your consent to process your personal data, you have the right to change your mind and withdraw your consent by requesting the deletion of your account. Withdrawal of consent will mean that you can no longer use the turn2me Website and your account will be deleted, the account deletion policy will apply in this case (See Above).
Data Extraction and Portability
You may also have the right to data portability in respect to your personal (non-Clinical) data, which means you can request that we provide it to you. If you would like to extract your data in a secure format for use on another third party service, please visit this link in the members area. Data that applies here:
- Personal data that you have provided to us – including profile data
- Your public and private thoughts and comments (Where applicable)
turn2me will provide no technical support with such data extractions. The Clinical Data Retention Policy where applicable (As above) applies to Data Extraction and Portability.
Changes to this Statement We may occasionally update this Privacy Statement. We encourage you to periodically review this Statement to stay informed about how we are helping to protect the personal information we collect. Your continued use of this service constitutes your agreement to this Privacy Statement and any updates.
How to contact turn2me with questions about your Personal Data
The data controller responsible for your information is Turn2me Ltd., which you can contact by email firstname.lastname@example.org (subject “FAO DPO”) or bypost at Data Protection Officer, Turn2me Ltd., WeWork Charlemont Exchange, Charlemont Street, Dublin 2 (D02VN88) , Ireland
You also have the right to lodge a complaint with the Data Protection Commissioner about the processing of your personal data.
What are Cookies?
A cookie is a small text file, which often includes a unique identifier that is sent to your computer browser from a website’s computer and is stored on your computer’s hard drive. Some cookies are only placed on your device for the time you are browsing the website. Others may be stored on your device and sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.Your browser only allows a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. You can find more information about cookies, at www.allaboutcookies.org This website uses transient or session cookies. Cookies by themselves do not identify you or any user but they do identify your browser. Because turn2me uses ‘transient’ cookies, your computer does not retain the information delivered in the cookie once you leave this Website. When you close your browser the transient cookie set up by turn2me is destroyed, and no personal information is retained which could identify you or your browser next time you log on to turn2me.
- Accept All
- Reject All
- Customise your acceptance options
If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. You can find out more about turning off cookies at the independent website www.allaboutcookies.org.
- Store details that help you to manage accounts and service activity online, such as user login details. Capture your geolocation so that certain services can be offered or restricted as the case may be.
- Find out how people use our sites, such as how often they visit, which pages they go to, and which links they click on, so that we can improve our sites.
- Help us to provide relevant information, such as details of services and other information that you may be interested in.
Cookies used by turn2me:
- Essential Services(Required) – To monitor site usage to allow us to provide a better user experience and to improve our services and geo locate our services. This is a required cookie by turn2me and you cannot opt out of it.
- Facebook Pixel – To enable us to recognise and count the number of visitors coming from Facebook advertising and measure conversions from these ads.
- Google Analytics – To enable us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our website works. These cookies collect information in an anonymous form
How do I change my cookie settings?
Once you have submitted your cookie preferences, the ‘Privacy Settings’ options will disappear from your screen.
The current mechanism is browser-based, so that you can choose different privacy settings for different devices/browsers. We retain your privacy preferences until either one of the following happens:
– Your browser cache is cleared- You use a different device or browser- You log out
You can change your settings at any time by choosing “Privacy Settings” in the website footer. You can completely remove cookies from your browser by following the instructions in this section of this policy. You can use your browser settings to choose whether you want to accept cookies or not, as well as to remove cookies that have been set on your device.You can find out how to manage cookies on popular browsers by using the links below:
- Google Chrome
- Microsoft Edge
- Mozilla Firefox
- Microsoft Internet Explorer
- Apple Safari
- Apple Safari Mobile
To find information relating to other browsers, visit the browser developer’s website.To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. It may also be possible to install extensions into your web browser that block cookies and online advertising. Please consult your browser developer’s website for more information on this technology.While you can still visit and browse our website if you block or remove cookies, the functionality and performance of the website may be impaired as a result, and you may be prevented from using certain services provided through the website.If you would like to change your preferences in relation to certain cookies used for online targeted advertising, you can also visit the self-regulatory program opt-out webpages listed below:
Please note that these sites are operated by third parties and not by turn2me. Please also note that any opt-out preference selected will only apply to the web browser on the particular device from which you access the opt-out options.
Changes to this Statement
We may occasionally update this Privacy Statement. We encourage you to periodically review this Statement to stay informed about how we are helping to protect the personal information we collect. Your continued use of this service constitutes your agreement to this Privacy Statement and any updates.