Welcome to Inuka’s privacy policy

At Inuka we are obsessed about protecting your privacy

Updated 27 July 2023.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage and delete your information.

In a nutshell:

• We offer a Coaching service which can be chat-based or via videocall.
• In order to use our services, you sign-up on our platform. When you do, we have to process some of your data. For example, when you fill in your email address, we need to store that on our servers so that you can log in with that email address again. That is an example of processing your data.
• When you sign-up, we ask your consent to process your data.
• We shield your data from anyone or anything (including ourselves) who doesn’t need to see it.
• We constantly check and re-check all the preventive measures we have in place to protect your data
• We are honest and transparent about our activities concerning your data.
• We enable you to have full control over your data, regardless of the country you live in (power to the people!).
• We pick our friends wisely and make sure that they uphold the same standards for privacy protection.
• We have an independent Data Protection Officer appointed to ensure independent, high-quality, specialized support. You can contact him directly with any questions you might have at [email protected].

Introduction

You are here because you care about your Privacy and you would like to know what Inuka does with your personal data. We already have something in common, because as mentioned, at Inuka we are obsessed about protecting your privacy, and we would like to inform you how we do things around here.

Identity

Let’s first state who we are. We are:

• Inukacare B.V. (Netherlands / global activities)
• Mental wellbeing Company ltd (Kenyan / African activities)
• Stichting Inuka (non-profit activities) 

All can be reached on [email protected] or Rapsodieplantsoen 11, 1312EJ Almere, Netherlands. 

Subsidiaries of –

Inuka B.V. (Netherlands)
Rapsodieplantsoen 11,
1312EJ Almere,
The Netherlands.

Your data is processed by our holding company and possibly also by our subsidiaries. If you are based in the EU, your data is not processed by Mental Wellbeing Company, our subsidiary in Africa.

Contact information

If you have any questions for us, you can always reach us at: [email protected] 

If you have specific questions about privacy, your data subject rights, or you want to contact our data protection officer directly you can do so by sending an email to: [email protected].

What does Inuka do?

Our Inuka Coaching method is unique, since we offer high-level mental wellbeing support for an affordable price, in a super accessible format. Our formal intended purpose is as follows: “Inuka is a digital platform which is intended to be used for evidence-based personal support to people who are feeling low, stressed or overwhelmed by means of a wellbeing test and online Coaching by trained Coaches”.

We offer a Coaching platform where you can ask for support for any type of issue from our Inuka Coaches. This means that there might be sensitive topics you want to discuss with our Coaches – we understand this, and we are very happy to tell you that you’re safe to discuss them with us.

We offer you anonymous Coaching, in the sense that our Coaches and Coaching quality team will only know you by your username. They will not know any identifiable information about you (your name, phone number, email address, work-place,…) unless you tell them. Our Coaches and quality control team only know the sensitive information that you share under your username (self-scan results, Coaching conversations,…) in order to offer you Coaching. In turn, our supporting staff like customer care do not know any sensitive information about you, but only know your personal information, in order to help you if, for example, you have a problem logging in or finding a Coach. In this way we lower the barriers for all to find mental wellbeing support.

We also work together with universities and research institutes to ensure the quality of the Coaching is maintained, to find out if we can improve our Coaching even further, and if our method could be beneficial to groups of people we hadn’t thought of before.

How do we obtain your personal data?

Generally we obtain your personal data because you signed-up through our platform, and all the personal data we receive is directly supplied by you, the user. 

Sometimes our customers ask us to e-mail their associates directly, and supply us with the organizational e-mail addresses of their associates to do so. If this is the case, we notify you of that in the first e-mail we send, and you are able to unsubscribe from any e-mail we send to you with a click of a button. 

What personal data does Inuka collect?

About chatting with Inuka and anonymity.

Simply put, ‘Personal information’ and ‘Sensitive information’ like health-related data in the table don’t mix. This is how we guarantee your anonymity, by pseudonymising all our data streams. Your data is pseudonymised because there are only very few people at Inuka who can link the specific person to the transcript. We only connect Personal and Sensitive in extreme cases, inform you of this, and always with the purpose to help you.

Cookies

For information regarding Inuka’s use of cookies, please refer to our separate Cookie Statement. 

Why do we use your personal data?

We are honest and transparent about what we do with your personal data. We use your data to help you via our Inuka platform. Via this platform you supply us with personal data which our Coaches will use to help you with issues you might experience about your wellbeing, stress levels, anxiety levels and general state of mind. And of course, everyone on our team is trained to know exactly how to treat your data. We follow protocols every time we handle Sensitive or Personal data; we only handle the relevant data for our work, and we leave no data behind.

Why can we use your personal data?

We can use your personal data because you want to use the service offered by Inuka as described in this privacy policy. You are informed about the processing of your personal data via the privacy statement. We ask you for your consent before we offer our services, or fulfil a contractual obligation with the organization you belong with. In that latter case, we only process your organizational e-mail address.

With whom do we share your personal data?

Whenever we use the expertise of third parties to assist us in facilitating the Inuka platform, we only choose companies and entities with the highest standard of data protection. These services are for example our cloud server or our customer service platform. We make sure that these third parties only handle the absolute basic data necessary to provide a smooth service. We never sell your data.

With all the parties that we need to provide you with our Inuka service we sign data protection agreements in which we agree upon the highest standards of data protection.

Collaborations

Whenever we collaborate with third parties, and you did not give explicit consent to share personal information with them, we only supply them with completely anonymous data. This means data that cannot be linked back to you in any way. Examples of these collaborations are AMREF, who train our Coaches in Kenya, or when we collaborate with Universities. 

Special collaboration: DELA

If you reach Inuka through DELA and we have your explicit consent to do so, Inuka may share your phone number with DELA for quality control purposes.

Our people

Our SuperCoaches actively monitor our Coaches, and get advice to improve Coaching quality from therapists. Our Coaching quality control system makes sure that we can offer consistent, high quality support to everyone and that our Coaches are trained to perfection. Coaches and SuperCoaches will not know who is behind the chat conversations unless you tell them.

Employers

When our customer is your employer, we can share aggregated and anonymized data with your employer – this data is not traceable to you. For example, if there are 100 employees in the company, Inuka may share with the employer that 60% is resilient, 30% is at risk, and 10% is in a tough place, without disclosing who is who. This overview can therefore not be traced back to you. We require a minimum group size of 20 people before we report these figures to the employer, and round off the figures appropriately so that it remains impossible to trace back to individuals. Your individual data will never be shared with your employer, whether that’s your name, display name, email address, chat transcript, wellbeing test results… nothing of that will be shared with the employer; it is illegal for Inuka to do so.

The purpose of the aggregated, anonymous overview is so that the employer can take action to improve the wellbeing of their employees as a group, and can make sure that Inuka is providing a service that helps the wellbeing of their employees.

Emergencies

Disclosing sensitive information to local authorities without your consent, defined under Article 9.1 of the European GDPR law, will only happen in cases where the involved Coach, SuperCoach or Quality Manager has reason to believe that the you have engaged in, or has the intent to engage in, criminal activity. Before we get in touch with the authorities, we consult with a mental health professional. You will always be informed of such a disclosure.

How long do we store your personal data?

We only store your personal data for as long as you use our service, the Inuka platform. When you have not used the Inuka platform for a year, we’ll ask you if you want to continue using the service, and if not, your data will be anonymised, meaning it is no longer personal data. This means that all personal identifiers are removed or replaced by generic words. There is no secret code book to decipher the information back to its original state. If you want your account to be deleted and do not want that data to be stored just drop an email to [email protected] with your display name and we ensure even that data is deleted!

How do we secure your personal data?

There are some bad seeds out there that might want to access the data, but don’t worry, we come prepared. Our app is built with an airtight security system:

• encryption of all data streams
• Company VPN restricted access to backend for developers with no direct connection of sensitive data to the internet.
• Database encryption
• Double factor authentication for employees
• Role based user access for employees
• Audit logs for users that have access to sensitive data  
• We use cloud servers which are state of the art

Everything that is stored on our servers is encrypted. We ask all employees to only store their data on our secured servers, not on their devices, meaning that if any of our employees loses their device, the device typically does not cause a data breach.

Our chat sessions

Knowing how we keep your chat content anonymous; it is also up to you to help maintain this. If you would like to be unknown by your coach and our quality control team, please refrain from sharing detailed personal information in your sessions. It is your responsibility to protect your anonymity by not sharing personal info in the chats – we do our very best to do the rest. We put this in the Terms of Service, to make sure you really stick to the promise.

Our video/audio sessions

We do not store video sessions. Please note that (video)calling cannot be done anonymously though. 

What rights can you exercise regarding your personal data?

As soon as we handle any of your data, you gain some amazing rights!

1. The Right of Access: You have the right to know what personal data is processed, by whom, why, and if the data is transported or shared with others.
2. The Right to Rectification: You can correct incorrect personal data, add more personal data when information is incomplete, and you have the right to be informed of how this rectification process progresses.
3. The Right to be Forgotten: You are in control of your personal information; you can always request the erasure of all your data as long as you have an account with Inuka.
4. The Right to Restriction of Processing: You can request that (part of) your data is not processed, for example during the time when incorrect data is corrected.
5. The Right to Notification: You always have the right to be notified when the conditions regarding your personal data change, specifically when the data will be corrected or erased, or when any other unforeseen situation occurs.
6. The Right to Object: You can object to the processing of your personal data, at any time.
7. The Right to Portability:You can request a copy of all your personal data processed by Inuka.
8. The Right to Storage Limitation: We always aim to keep as little personal data stored as possible; you have the right to expect that your personal data will not be stored any longer that reasonable for the purpose it serves. The standard length of storage is 12 months after you have logged in for the last time.

After 1 year of you not actively using your account, we anonymize the data and store them on our servers, and delete your account and your personal data. If you do share personal identifiable information during the chats, no problem, we will replace that information with random information when we anonymize your data. For example, if you share where you work, we will replace that word with “Company XYZ”. We do not store information that can help us decipher what “Company XYZ” means. Because your data is anonymous we cannot retrieve the data anymore, so exercise the rights when you are an active user of Inuka.

You can contact us regarding the exercising these rights by sending an email to [email protected]. When you do this you will get in touch with our privacy team and our data protection officer, who will help you right away. To verify that the data you would like to modify belongs to you, they may ask you for additional information. You will receive a confirmation of your request by email and we will aim to respond to your request within 30 days of you sending the request. Sometimes the exercise of a request will take more time, in that case we can take up to 60 days to respond to your request, but we will notify you within 30 days of your request when that happens, promise!

Children’s Data

Our Inuka platform is not structured to attract children. People under the age of 18 are not allowed to enter the Inuka Platform. Accordingly, we do not collect, store or process personal information from anyone we know to be under 18 years of age.

What can you do if you have any complaints about how we use(d) your personal data?

If you have any question or complaints about how we handle your personal data please contact our data protection officer at [email protected]. We will help you with all your questions and or complaints.

If you want to issue a formal complaint with the Dutch Data Protection Authority about Inuka you can do so via this page: Klacht indienen Autoriteit Persoonsgegevens.

Changes to this policy

When we make significant changes the privacy policy, we post a new version of our privacy policy here, with a new version number and date. You can see the version number and update data at the top of this privacy policy. We encourage you to check it from time to time!

And of course feel free to reach out to us directly with questions anytime at [email protected], or if you enjoy direct contact with an absolute amazing privacy-obsessed guru – and also our independent Data Protection Officer – you can reach out to [email protected] where Michael is ready for you!

All our love,

The Inuka Team