Privacy Policy

PRIVACY POLICY

This Privacy Policy explains how Mendara (“we”, “us”, “our”) collects, uses, and processes personal data in connection with the Platform. We may update this Privacy Policy from time to time.

1. Controller

   1. Mendara is the data controller of your personal data.

   2. Contact details:
      Mendara Limited Registered Number 17177762 and Registered Office at 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE; privacy@mendaracare.com

REGISTERED WITH ICO

2. Overview of Processing

   1. We operate a peer-to-peer support platform involving facilitated sessions.

   2. Personal data is processed to: 

      1. provide access to the Platform;

      2. allocate participants to appropriate sessions;

      3. operate and improve sessions;

      4. support facilitators during sessions;

      5. conduct research and generate insights.

         
         

3. Categories of Data

   1. Marketing Data

   2. Contact details and engagement data.

      1. Retained until you opt out (given the nature of the service).

3. Platform Data

   1. Includes:

      1. registration details;

      2. questionnaire responses;

      3. payment records (processed via Stripe).

4. Session Data

   1. Includes:

      1. session recordings;

      2. transcripts;

      3. participant contributions.

This is a highly sensitive dataset.

4. Questionnaire and Triage

   1. During onboarding, you complete a questionnaire.

   2. This is designed to:

      1. understand your circumstances;

      2. allocate you to appropriate sessions.

   3. While anonymisation is intended, responses may still constitute personal data. We aim to anonymise session data wherever possible. However, true anonymisation may not always be achievable as specific inputs may relate to social media content or other data that could identify you.

5. Session Recording and AI Analysis

   1. Sessions are recorded and transcribed.

   2. AI tools are used: 

      1. during sessions to support facilitators by highlighting signals or contributions requiring attention;

      2. after sessions to analyse:

         1. session quality;

         2. facilitator performance.

   3. AI operates as a facilitator-facing support tool, and does not autonomously make decisions about participants.

   4. Your data may be used to:

      1. improve future sessions;

      2. identify anonymised case studies;

      3. support research into participant needs and outcomes.

   5. We may develop additional analytical capabilities (e.g. wellbeing tracking), which will be implemented in accordance with applicable law and reflected in updated policies.

6. Legal Bases

   1. We process personal data on the following bases:

      1. performance of a contract (providing the Platform);

      2. legitimate interests (improving services, research, safeguarding);

      3. consent where required;

      4. compliance with legal obligations.

   2. Special category data (where applicable) is processed on:

      1. explicit consent; and/or

      2. substantial public interest (safeguarding), where applicable. 

7. Safeguarding

   1. AI tools and facilitators may identify indicators of risk.

   2. Where appropriate:

      1. facilitators may recommend external support;

      2. participants may be removed from sessions.

8. Data Sharing

   1. We may share data with:

      1. service providers (e.g. hosting providers such as Supabase);

      2. payment processors (Stripe);

      3. technology providers supporting AI processing.

   2. We require all providers to maintain appropriate confidentiality and security.

   3. Data will not be transferred outside the UK.

9. Data Retention

   1. Marketing data: retained until opt-out.

   2. Platform data: retained for as long as necessary to operate the service.

   3. Session data: retained for research and service improvement purposes, subject to safeguards. 

10. Your Rights

    1. You have the right to:

       1. access your data;

       2. request correction;

       3. request deletion;

       4. restrict or object to processing;

       5. data portability (where applicable);

       6. complain;

    2. These rights may be limited in practice where:

       1. data is anonymised or aggregated;

       2. identification of your specific contributions is not feasible;

       3. fulfilling requests would adversely affect other participants.

11. Transparency at Onboarding

    1. At onboarding and/or prior to session access, you will be provided with a clear notice confirming that:

       1. the service is peer-to-peer and non-clinical;

       2. participants may be referred to external support;

       3. sessions are recorded and analysed (including via AI);

       4. data is used for improvement and research purposes.

12. Contact and Complaints

    1. You can contact us at: privacy@mendaracare.com

    2. You have the right to lodge a complaint with the Information Commissioner’s Office (ICO).