Privacy Policy

Identification of the Data Controller and Contact Details

Data Controller: YourBestYou (hereinafter, "Company" or "Controller")

Registered address: [COMPANY ADDRESS PLACEHOLDER]

Telephone: [PHONE NUMBER PLACEHOLDER]

Email: [EMAIL PLACEHOLDER]

Scope, Context and Definitions

This Privacy Policy applies to processing of personal data carried out by YourBestYou through:

• The Controller's website and mobile application
• Official corporate profiles on social media associated with the YourBestYou brand
• Contact and information request forms linked to these platforms

A "User" is defined as any natural person who interacts with YourBestYou through the website, mobile application, social media, or other communication channels.

Purposes of Data Processing

• Management of enquiries and pre-contractual relations: responding to requests and maintaining communication with User.
• Provision and support of counseling services: execution, maintenance, and technical assistance of mental health counseling services.
• Corporate communications and service updates: dissemination of company news and updates.
• Statistical processing: generation of aggregate metrics and reports.
• Own commercial communications (subject to consent): newsletters, updates, and promotional content.
• Recruitment processes: management of applications and evaluation of candidates.
• Regulatory compliance, security, and fraud prevention.

Personal Data Processed and Sources of Data

Sources

• Data provided directly by User (forms, registration, communications)
• Data generated through browsing (cookies and similar technologies, in accordance with the Cookies Policy)
• Data derived from the execution and maintenance of the relationship with YourBestYou

Categories of Data (depending on interaction)

• Identifying: name, surname, nationality, identity document or passport
• Contact: telephone number, postal and email address, social media profiles (if provided)
• Personal characteristics: date of birth and other data provided by User
• Economic: payment methods (card or others)
• Connection/online identifiers: IP, logs
• Browsing: use of the Website
• Health-related information: mental health data provided during counseling sessions (with enhanced protection)
• Any other additional information User decides to share

YourBestYou always applies the principle of data minimization, processing only the data that are adequate, relevant, and limited to what is necessary for each purpose.

Legal Basis for Processing

Artificial Intelligence and Automated Decision-Making

YourBestYou uses third-party artificial intelligence technologies integrated into its services in order to offer personalized support and recommendations to Users.

These tools may assist in various aspects of the platform, including mood tracking insights, personalized recommendations, and administrative support features.

• The User may request human intervention
• The User may ask for explanations regarding a recommendation
• The User may challenge an automated proposal

The use of these technologies is carried out in accordance with applicable data protection laws and regulations.

Statistical Processing

YourBestYou may process data in an aggregated and anonymized manner to prepare statistical and analytical reports aimed at improving its own service, with the purpose of enhancing the provision of its professional services.

This processing does not include any identifying data of the Users under any circumstances.

Data Retention Periods

• Service provision data: retained only for the time necessary to fulfil the purpose and subsequently blocked for the applicable legal retention periods.
• Job applications (HR): retained for 2 years from the last update; after this period, they will be deleted unless otherwise indicated by the candidate.
• Video surveillance (if applicable): images retained for a maximum of 30 days, except when relevant facts come to light for judicial proceedings.

YourBestYou will not retain data shared with other companies if the User withdraws consent for such communication. For further information on retention periods, you may contact [EMAIL PLACEHOLDER].

Data Disclosure to Third Parties

YourBestYou does not disclose data to third parties unless there is a legal obligation, vital interest, contract execution, overriding legitimate interest, or the User's consent, in accordance with applicable data protection laws.

Data Processors

To ensure proper and secure service delivery, the Controller may engage data processors who access data solely for the contracted purpose and under documented instructions. These may include:

• IT, cloud/hosting, and website maintenance services
• Electronic communications and messaging tools (with prior consent)
• Legal, accounting, and audit advisors
• Customer support and external consultants under contract with YourBestYou
• Archiving, digitization, and secure document destruction services

All such processors are bound by written data processing agreements imposing, at minimum: confidentiality, adequate technical and organizational measures, prohibition of unauthorized subcontracting, deletion or return of data upon completion of the service, and cooperation in ensuring user rights and processing security.

Disclosures to Third Parties

Personal data will only be disclosed to third parties with a valid legal basis, for the following purposes:

• Counselors and mental health professionals for service provision
• Financial institutions and payment providers: for billing and collection within contract execution
• Public administrations and competent authorities (including courts): when required by law or necessary for compliance or claims management
• Other third parties: where required to protect the vital interests of the User or others, or with the User's express consent

International Data Transfers

When communication involves recipients outside the jurisdiction where YourBestYou is established, appropriate safeguards established by applicable data protection laws will be applied, such as adequacy decisions or standard contractual clauses.

The use of services that involve international data transfers is voluntary and reversible.

Duty of Confidentiality and Security

All information provided will be treated confidentially and subject to strict security measures to prevent unauthorized access, loss, or misuse.

The Controller periodically reviews its providers and maintains minimum access controls necessary to ensure proper information protection.

User Warranties When Providing Data

Accuracy and Truthfulness

The User declares and guarantees that the personal data provided to YourBestYou are true, accurate, complete, and up to date. The User shall be liable for any damage, direct or indirect, resulting from breach of this obligation.

Updating of Information

The User undertakes to keep their data up to date and promptly notify YourBestYou of any changes affecting accuracy to ensure correct service delivery and communication.

Third-Party Data

If User provides data of third parties, they declare that:

• They have a valid legal basis (notably, the informed consent of the third party, where required)
• The third party has been informed of this Policy's contents
• They assume full responsibility for such disclosure, holding YourBestYou harmless from any related claim

The Controller may carry out reasonable verifications and will apply due diligence measures as required by data protection law.

Notification of Errors

Any damage caused to the Website, YourBestYou, or third parties as a result of inaccurate, incomplete, or false information shall be the sole responsibility of the User.

Age Requirement and Minors

In general, Users must be at least 18 years old to provide personal data through the Website and declare so upon submission, assuming full responsibility for such declaration. For minors under 18, parental or guardian consent is required.

Adequacy of Data Provided

Users shall refrain from sending YourBestYou excessive or irrelevant data, or special categories of data (e.g. health, ideology, biometrics, religion), unless expressly requested by the Controller and supported by a valid legal basis.

Security of Credentials

If the User holds an account on the Website, access credentials shall be personal and non-transferable. The User must safeguard them diligently and immediately notify YourBestYou of any unauthorized use or security incident.

Security Measures

YourBestYou implements appropriate technical and organizational measures, including but not limited to:

• Encryption of communications between the User's device and servers
• Encryption of data stored on servers
• Access and confidentiality controls for authorized personnel and providers
• Regular security assessments and updates

While these measures reduce risk, absolute Internet security cannot be guaranteed. In the event of a security breach with a high risk to affected individuals' rights and freedoms, YourBestYou will promptly notify those affected and, where applicable, the relevant data protection authorities within the statutory deadlines.

User Rights

Users may exercise the following rights under applicable data protection laws before YourBestYou:

• Access: to know which personal data concerning them are being processed
• Rectification or erasure: to correct inaccurate data or request deletion when data are no longer necessary
• Restriction of processing: to request limitation of processing in certain circumstances; data will then only be retained for legal claims
• Data portability: to receive their personal data in a structured, commonly used, and machine-readable format or request transfer to another controller
• Objection: to oppose processing based on personal circumstances, except where compelling legitimate grounds exist or for legal defense

Users may also object at any time to processing for advertising or promotional purposes and may withdraw their consent without affecting the lawfulness of prior processing.

Requests shall be addressed to:

YourBestYou
[COMPANY ADDRESS PLACEHOLDER]
Email: [EMAIL PLACEHOLDER]

Contact information for relevant data protection authorities in your jurisdiction is available upon request. However, it is recommended to contact YourBestYou first to resolve the matter within one (1) month.

Cookies and Similar Technologies

Browsing the website may involve the use of cookies or similar technologies to identify the browser or device and analyze browsing behavior.

Detailed information is available in the Cookie Policy.

Health Data and Confidentiality

YourBestYou processes health-related personal data in connection with the provision of mental health counseling services. This data is subject to enhanced protection measures and confidentiality requirements.

All communications between Users and Counselors are confidential and protected by professional confidentiality obligations and applicable laws.

Health data is only shared with the Counselors providing services to the User and with third parties when required by law, for vital interests, or with the User's explicit consent.

Changes to This Privacy Policy

YourBestYou may modify this Privacy Policy whenever deemed necessary. Updates will be communicated through the Website or other appropriate means.

Continued use of services following notification constitutes acceptance of the revised Policy, except where express consent is required.