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Data Protection

Introduction is committed to providing a superior learning experience for everyone we work with. We know that our clients are committed to their success, and we are equally committed to ensuring that each consultation is optimized to maximize its potential in educational value. To enable us to fulfill our commitment to our clients, needs to gather and use certain information about individuals.

Individuals who we gather information from include customers, affiliates, business contacts, employees, and other people the organization has a relationship with or may need to contact to properly conduct business and provide services.

This policy describes how this personal data is collected, handled, and stored to meet the company’s data protection standards — and to comply with the law.

Why This Policy Exists

This data protection policy ensures Mental Defender LLC:

2.1  Complies with data protection law and follows industry best practices.

2.2  Protects the rights of staff, customers, affiliates, and partners.

2.3  Is open about how it stores and processes individuals’ data.

2.4  Protects itself from the risks of a data breach.

EU General Data Protection Regulation Protection Law (GDPR)

The GDPR (General Data Protection Regulation) protection law describes how organizations who conduct business with individuals or entities located in EU (European Union) nations — including — must collect, handle, and store personal information.

These rules apply regardless of whether the data is stored electronically, on paper, or in any other manner. To comply with the law, personal information must be collected and used fairly, stored safely, and not disclosed unlawfully.

The EU GDPR is underpinned by eight core principles. These state that personal data must:

3.1  Be processed fairly and lawfully.

3.2  Be obtained only for specific, lawful purposes.

3.3  Be adequate, relevant, and not excessive.

3.4  Be accurate and kept up to date.

3.5  Not be held for any longer than necessary.

3.6  Processed in accordance with the rights of data subjects.

3.7  Be protected in appropriate ways.

3.8  Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

Policy Statement

Our business will receive, use, and store personal information about our customers, affiliates, partners, and colleagues every day. It is important that this information is handled lawfully and appropriately, in line with the requirements of the Data Protection Act of 2018 and the General Data Protection Regulation (collectively referred to as the “Data Protection Requirements”).

We take our data protection duties seriously, because we respect the trust that is being placed in us to use personal information appropriately and responsibly.

About This Policy

This policy and any other documents referenced within this policy will set the basis for which we will process any personal data that we request and collect. This policy does not form part of any employee’s contract of employment and may be amended at any time.

The company (Mental Defender LLC) is responsible for ensuring compliance with the Data Protection Requirements and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Officer.

What is Personal Data?

Personal data is defined as data -- whether it is stored electronically or paper based -- relating to a living individual who can be identified directly or indirectly from that data, or data that can be used in conjunction with other information in our possession to identify said individual.

“Processing” is any activity that involves the use of personal data. It includes obtaining, recording, holding, organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring personal data to third parties under privacy control conditions.

Sensitive personal data includes contact information, billing address, session activity on our website or other external platforms managed by the company, IP location, etc. Sensitive personal data can only be processed under strict conditions and can only be used for the express purpose for which it was collected for.

Data Protection Principles

Anyone processing sensitive personal data must ensure that the data is:

7.1  Processed fairly, lawfully and in a transparent manner.

7.2  Collected for specified, explicit and legitimate purposes -- and any further processing is completed for a compatible purpose.

7.3  Adequate, relevant and limited to what is necessary for the intended purposes.

7.4  Accurate and where necessary, kept up to date.

7.5  Kept in a form which permits identification for no longer than necessary for the intended purposes.

7.6  Processed in line with the individual’s rights and in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage by using appropriate technical or organizational measures.

7.7  Not transferred to people or organizations situated in countries without adequate protection and without firstly having advised the individual.

Fair and Lawful Processing

The Data Protection Requirements are not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual.

In accordance with the General Data Protection Regulation (GDPR), we will only process personal data where it is required for a lawful purpose. The lawful purposes include (amongst others): whether the individual has given their consent, the processing is necessary for performing a contract with the individual, for compliance with a legal obligation, or for the legitimate interest of the business. When sensitive personal data is being processed, additional conditions must be met.

1.  Gathering Information

We receive and store information about you such as:

A.  Information you provide us: We collect the information you provide to us which includes: your name, email address, address or postal code, payment method, and telephone number. We collect this information in a number of ways, including manual entry while you are using our service, interacting with our customer service, participating in surveys or marketing promotions, providing reviews or ratings, or otherwise providing information to us through our service or elsewhere.

B.  Information we collect automatically: We collect information regarding you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service.

This information includes:

  • Transcripts of any chat conversations that you initiate while on our platforms.

  • Your phone number in the event that phone support were to ever be offered and if you were to initiate any conversation through phone support.

  • Information collected via the use of cookies, web beacons and other technologies, including ad data (such as information on impressions delivered to a cookie, the site URL where the impression was delivered, as well as the date and time). See our Privacy Policy for more information.

2. Use of Information

We use the information we collect to provide, analyze, administer, enhance, and personalize our services and marketing efforts. We use the information to process your orders, payments, and any other form of communication on these and other topics.

Adequate, Relevant and Non-Excessive Processing

We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.

Accurate Data

We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.

Timely Processing

We will not keep personal data for longer than necessary for the purpose or purposes for which it was collected. We will take all reasonable steps to destroy or erase from our systems, all data which is no longer required.

Data Security

We will take appropriate security measures against unlawful or unauthorized processing of personal data. We will use adequate protocol to prevent against accidental or unlawful destruction, damage, loss, alteration, unauthorized disclosure of, or access to personal data that has been transmitted, stored, or otherwise processed.

We will put in place procedures and technologies to maintain the security of all personal data from the point of data processing, the point of data collection, and the point of data destruction. Personal data will only be transferred to a data processor if he or she agrees to comply with those procedures and policies, or if he or she puts in place adequate measures himself/herself.

We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

A.  Confidentiality: Only people who are authorized to use the data can access it.

B.  Integrity: Personal data should be accurate and suitable for the purpose for which it is processed.

C.  Availability: Authorized users should be able to access the data if they need it for authorized purposes. Personal data should therefore be stored on the Mental Defender LLC central computer system and databases instead of individual PCs.

Our Security Procedures:

A.  Entry Controls: Any stranger seen in entry-controlled areas will be reported.

B.  Staff Security and Required Practices: Securing lockable desks and cupboards all the time. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)

C.  Adequate/Relevant Data Collection: Data minimization will be practiced.

D.  Data Storage: Pseudonymization and encryption of data will be the primary state and method of storing the data.

E.  Methods of Disposal: Paper documents would be shredded. Digital storage devices would be physically destroyed when they are no longer required. Electronic data would be deleted once it’s intended purpose is fulfilled.

F.  Equipment: Staff has to ensure that individual monitors do not show                      confidential information to passers-by and that they log off from their PC when it is left unattended.

G.  Transferring Personal Data Outside of the EEA: We may transfer any personal data we hold to a country outside the European Economic Area (EEA) or to an international organization, provided that one of the following conditions apply:

  • The country to which the personal data is transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.

  • The data subject has given his/her consent.

  • The transfer is necessary for one of the reasons outlined in the Companies Act of 2006 (link provided below), including the performance of a contract between us and the data subject, or to protect the vital interests of the data subject.

  • The transfer is legally required on important public interest grounds or for the establishment, exercise or defense of legal claims.

  • The transfer is authorized by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.


Disclosure and Sharing of Personal Data

We may share personal data we hold with any member of our group, which means our subsidiaries, or our ultimate holding company and its subsidiaries, as defined in the Companies Act of 2006:

Changes to this Policy

We may modify this Privacy Statement at any time, but we will provide prominent advance notice of any material changes to this Statement, such as sharing the updated revisions through our Services, posting a notice on our website(s), or sending you an email to provide you the opportunity to review the changes and subsequently choose whether you wish to continue using our Services.

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