Privacy policy - Specialist

At Consultly, we respect your right to privacy. Ensuring the protection of the personal data you and your Clients provide to us is our top priority.

Main definitions

Personal data is any information about you that, alone or in combination, allows the person collecting and processing such information (controller) to identify you as a natural person.

Processing of personal data means any operation performed on your personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

Consent of the data subject is any freely given, informed and unambiguous expression of the data subject’s wishes, signifying agreement to the processing of that person’s personal data.

Who is the controller of my personal data?

The controller of your personal data is Consultly Ltd with the address of its registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. If you have questions about our Privacy Policy or data protection on our Portal, please email us at contact@consultly.com.

Apart from the controller mentioned above, does any entity process my personal data in connection with my use of the Portal?

Consultly uses a payment processor – Stripe Payments Europe, Ltd. (hereinafter: “Stripe”) based in Ireland – to handle subscriptions and all payment processes (including data collection and processing). The data collected by Stripe may vary depending on the Specialist’s country of operations and its applicable regulations. You can get all up-to-date information about the types of data collected by Stripe, the legal bases, purposes, methods, duration and safeguards of their processing here: https://stripe.com/privacy.

Consultly may also make personal data available in order to fulfill statutory obligations (e.g., at the request of law enforcement agencies), to process claims, and to protect the rights, property (including intellectual property) and safety of individuals.

What data are processed when using the Portal and for what purpose?

Please remember that providing your personal data to Consultly is voluntary, which means that you are not obliged to provide it. However, the provision of personal data is necessary to create an account on the Portal and use the portal. If you do not provide your personal data to Consultly, you will not be able to use all features of the Portal.

At Consultly, we collect the following personal data:

  1. Information that you provide to us directly, collected during your use of the Service, i.e., your name, email address, account password, state/country of residence or business, category of services provided, profile picture, time zone, information about scheduled/conducted meetings (IP address, date and time of start and end of the meeting with the Client, date of meeting creation, meeting status), Client name, Client’s email address, meeting cost, meeting note. 

  2.  Data collected by Stripe, to which the controller has or in certain cases may have access, include: 

  • email address; 
  • country;
  • payment currency;
  • address of your website if provided/description of your business;
  • the amount of money accumulated in the Portal;
  • amount to be paid out;
  • transaction list;
  • list of pay-outs of accumulated funds;
  • the name of the bank in which you have a bank account for pay-outs;
  • the last four digits of your account number;
  • tax identification number;
  • address of residence;
  • date of subscription/registration start by the Specialist;
  • the last four digits of your payment card number;
  • Client’s details necessary for the financial transaction (amount, name of the payment cardholder, payment card number, CVC code, postal code in certain cases).

All of the above information is necessary for us to complete your registration with the Portal, to contact you in necessary cases, to process any complaints, to provide you with properly functioning services offered by the Portal, i.e., to make and manage appointments with Clients, to handle subscriptions and any processes regarding payment for appointments.

For more information about Stripe’s financial data processing, visit https://stripe.com/payment-terms/legal under “Financial Services Terms” and “Payment Terms” and read Stripe’s Privacy Policy at https://stripe.com/privacy.

How long is my data processed when I use the Portal?

We may keep your personal data for different periods of time, depending on the purpose for which it is processed:

In the case of Specialists, we keep your data for as long as you have an account on our Portal. If you delete your account, or if we have to delete your account (e.g., due to you violating the rules of our Portal or breaking the law), we will delete or render anonymous your personal data. However, we may store some of your data for a longer period in order to comply with legal, tax and accounting requirements (e.g., until the expiration of the statutory statute of limitations for contractual claims or the statute of limitations for tax liabilities arising from the fact that you purchased our services), or if the data is necessary for ongoing or anticipated legal proceedings. We make every effort to keep the retained data to the minimum necessary and for no longer than required.

We also store some of your personal data on the basis of a legitimate interest (ours or that of a third party) until you object to the processing or we determine that the data has become obsolete, or we have fulfilled our purpose for using the data.

We are also required to keep some of your data as required by applicable laws, in which case we use it for a period which is in accordance with applicable laws.

Personal data that we process based on your consent is processed until: (i) you withdraw your consent or (ii) the purpose for which the data was collected is fulfilled, whichever comes first.

Is my data transferred outside the European Economic Area?

Your data may be transferred to countries outside the EEA.

Is my personal data profiled?

Your personal data will not be processed by automated means, including profiling.

How is my personal data safeguarded?

To ensure the security of the processing of your personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, we take, among other things, the following technical and organizational measures:

  • access to the Specialist Account is password protected;
  • passwords to the Specialist Account are encrypted;
  • only the controller responsible for the personal data on the Portal has access to databases;
  • connections on the Portal are encrypted using HTTPS/SSL protocols;
  • backup databases are created;
  • database keys are rotated.

Is information provided to the Specialist by the Client during video consultations, including sensitive data such as health, safe?

As a portal, we do not have access to the data the Client provides to the Specialist during video consultations, and therefore it is not processed by us in any way. As a Specialist, you are responsible for the safety and confidentiality of data concerning health provided by the Client during the video consultations, on the same basis as during an in-person visit. For our part, we ensure the security of the transmission of this data by establishing a network infrastructure that prevents third parties from intercepting the transmitted information. In accordance with the terms and conditions of the Portal, audio or video recording of consultations by either party without the written consent of the other party is prohibited. Consultly does not in any way enable or provide tools for either party to record consultations.

Is my data transferred to separate entities for marketing purposes?

Consultly does not transfer any personal data to other parties for marketing purposes.

Data collected by us automatically through third parties

For statistical purposes, Consultly collects some data automatically (including IP address, browser type, access time, operating system type, information about links that are clicked on or other actions taken on our Portal), using technologies that monitor actions taken on the website – i.e., Mixpanel and Sentry. This data is only material for statistical analysis and system error correction mechanisms, so this data is not combined in any way with other data you provide to us; thus we are not able to identify the data subject based on this data. 

What cookies are used on the Portal?

A cookie is a text file containing information downloaded by your browser on your terminal device (computer or other mobile device) when you use our Portal. This information is then shared with us through your browser.

Consultly does not store Personal Data via cookies.

Consultly uses cookies to collect other, non-personal information. They are used to provide top-quality services, optimize the content available on the Portal, and for statistical purposes. These data are not personal data and do not uniquely identify the data subject.

Types of cookies used in Consultly:

  1. Session cookies – so-called “first party cookies,” i.e., cookies placed by our portal on your browser. This allows us to remember your active session information, which means you do not have to log in each time you visit a new page on the Portal, and provides access to features and areas of the Portal reserved for logged-in users only. These files are deleted when you log out.
__consultly_specialist_jwt - a unique token to identify the logged-in user.
  1. Persistent cookies – stored even after a one-time visit to the Portal and,as a standard, used to obtain anonymous information about the User’s next visit to the Portal.
__consultly_region_spec_cookie_consent_required - stores data on whether user consent is required for the use of cookies on the Portal.

__consultly_region_spec_right_to_withdraw - stores data on whether, in a particular case, a waiver of the Client’s 14-day right to withdraw from a distance contract is required.
  1. Analytical cookies – stored to allow Mixpanel to collect data about user behavior.
mp_*_mixpanel - stores anonymous user data, allowing Mixpanel to collect analytical data.

You can read about what data Mixpanel collects at https://help.mixpanel.com/hc/en-us/articles/115004613766-Default-Properties-Collected-by-Mixpanel .

If you refuse to use analytical cookies on Consultly, we will set a so-called opt-out cookie to remember your preferences and prevent us from sending you analytical content when you visit the Portal again.

You can read all the information about the cookies used by Stripe when handling subscriptions and financial transactions at Consultly at https://stripe.com/cookies-policy/legal.

What rights do I have regarding Consultly’s processing of my personal data?

Your rights in connection with their processing by Consultly vary depending on the law in your jurisdiction. If you live in the United Kingdom or the European Economic Area, you may request that we provide you with access to the data you have provided to us, rectify it, supplement it, and, with certain restrictions, erase it, restrict and stop its processing, or you may exercise the right to data portability. To do so, please send an email to: contact@consultly.com.

You also have the right to object to the processing of your personal data and to withdraw your consent at any time. However, the withdrawal of consent does not affect the lawfulness of the use (processing) of your personal data before its withdrawal. 

To ensure the security of the processing of your personal data, in cases where we receive a request as mentioned above, we may ask you to provide additional information necessary to confirm your identity, such as an identity document with a recent photograph.

If you have reservations related to the processing of your personal data on the Portal, you may lodge a complaint with the President of the Personal Data Protection Office.

Final provisions

Stripe’s Privacy Policy available at https://stripe.com/privacy and Stripe’s Cookies Policy available at https://stripe.com/cookies-policy/legal is an integral part of this Privacy Policy.

Please note that we may update this privacy policy. If changes are made, we will notify you by email or through our Portal. 

Any changes to this Privacy Policy become effective upon publication of the revised Privacy Policy. By continuing to use our Portal, you acknowledge that you have read and understand the latest version of this Privacy Policy.

If you have any questions, comments or concerns regarding this Privacy Policy, please contact our Data Protection Officer at contact@consultly.com.

This Privacy Policy is part of Consultly’s Terms and Conditions available here: Terms and Conditions.