Privacy Policy (Notice)

1.0 Purpose

Credo Therapies Ltd (“Credo Therapies” or “We” “Us” or “Our”) respects your privacy and is committed to protecting your Personal Data in line with current legislation.

This Privacy Policy informs you how we manage your Personal Data and explains your privacy rights and how the law protects you. This privacy policy is relevant to anyone who is using Credo Therapies services. It tells you what Personal Data is collected, what we do with that Personal Data, who we may share the data with, and how you can exercise your legal rights.

It is important you read this privacy policy together with any other notices we may provide so you are aware of how and why we are using your data.

Credo Therapies use your Identity and Health data (a combination of Personal Data and Sensitive Personal Data) collected voluntarily from you to fulfil the Credo Therapies Digital CBTe service. A full description of the Credo Therapies services can be found in the Terms of Service on our website: www.digitalcbte.co.uk. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out in the Contact details section.

1.1 Scope

This privacy policy applies to Personal Data used by, or on behalf of Credo Therapies, where Credo Therapies has overall control and legal responsibility for the use of your Personal Data (Data Controller). This includes how Credo Therapies processes your Personal Data when you register, when you engage with us directly to access our services, or when you engage with us via phone or email.

This privacy policy does not apply where another organisation (such as an NHS Trust) has commissioned our services for you and retains overall control and legal responsibility for the use of your Personal Data (Data Controller). In these circumstances Credo Therapies is appointed by the Data Controller under a contract to process the Personal Data strictly on their behalf and in accordance with their instructions (Data Processor). For more information and to exercise your legal rights in respect of this, you should contact the relevant Data Controller directly.

This privacy policy does not apply to our employees, workers and contractors.

1.2 About Credo Therapies (Data Controller)

Credo Therapies Limited is a company registered in England and Wales under company number 14441022. Our registered office is at 8 King Edward Street, Oxford, United Kingdom, OX1 4HL.

Credo Therapies Ltd is registered with the Information Commissioner’s Office (ICO) with registration number ZB494720.

1.3 Definitions

Personal Data means data which relates to a living individual who can be identified from the data or from the data in combination with any other information.

Sensitive Personal Data means Personal Data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health, data concerning a person's sex life or sexual orientation, or data relating to criminal convictions and offences.

The Data Controller is a person who determines the purposes for which and the manner any Personal Data are or are to be processed.

The Data Processor means any person who processes the data on behalf of the Data Controller.

2.0 What Personal Data do we collect?

The types of Personal Data we collect depends on the nature of the relationship you have with Credo Therapies. We endeavour to collect Personal Data only relevant for the purposes set out in this privacy policy.

We collect data you voluntarily share with us when you register and use our products and services. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

2.1 Personal Information.

Purpose: We collect Personal Information to identify you so that you can use our services securely and we can communicate with you to provide our services.

Type of data: First name, last name, email address and mobile phone number.

2.2 Health Information

Purpose: We collect health information, which is considered Sensitive Data, including data about your physical characteristics, impact of eating problems, general physical and mental status. This is required to ensure that our services are appropriate for the user, to determine the efficacy of the services, and to deliver the services. We only collect data that users provide to us voluntarily.

Type of data: We collect information including age, height, weight, menstrual cycle and pill usage (where appropriate), mood, ethnicity, demographics, Clinical Impairment Assessment (CIA), Eating Disorder Examination (EDE-Q), number of meals, laxative and diuretic usage.

2.3 Usage Data

Purpose: This includes information about how you use our services to help us improve our products and services.

Type of data: User status (active, blocked etc), session engagement (when the user starts and completes each session).

2.4 Research Data

Purpose: This includes aggregated and anonymised data which captures the level to which you believe our services have assisted you.

Type of data: User feedback on their perceived benefit and demographic information (including ethnicity and geography).

2.5 Communication Data

Purpose: Where applicable, we collect information that verifies you have consented for your Personal Information, Health Information and Usage Data to be shared with another person (such as a healthcare professional at an NHS Trust) where the Trust operates a Supporter model. A Supporter model is where another person will engage with a user to encourage them to complete the programme.

Type of data: Personal Information, Health Information and Usage Data.

2.6 Technical Data

Purpose of data: We collect technical data to allow us to provide you with a better service including understanding the browser versions and device versions used to access the services. This also allows us to investigate faults with the services.

Type of data: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our services.

2.7 Marketing Information

We do not collect data for the purposes of marketing.

2.8 Cookies

Purpose of Data: Cookies (small text files placed on your device while using our services) used by Matomo is used to assist with improving your experience and to safeguard your privacy whilst using our services. For more information see our cookie policy, see the Matomo cookies FAQ or visit www.allaboutcookies.org.

Type of Data: Strictly necessary cookies and tracking cookies

3.0 How is your Personal Data collected?

We use different methods to collect data from and about you including:

3.1 Direct interactions

You may voluntarily provide us with your identity and contact details by registering with us, utilising the services or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

apply for our services;
give us feedback or contact us.

3.1 Automated technologies or interactions

As you interact with our services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

3.3 Third parties or publicly available sources

We will receive Technical Data from analytics providers such as Matomo.

4.0 How we use your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a lawful bases for processing your Personal Data, relying on Health or Social care (Article 9(2)(h), although we will get your consent before sending certain information to you or before sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us using the details set out in the Contact details section.

4.1 Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful bases for processing including bases of legitimate interest
To register you as a new customer	(2.1) Personal Information, (2.5) communication Data (2.7) Marketing Information	(a) Performance of a service with you
To verify the suitability of the services (eligibility)	(2.2) Health Information	(a) performance of a service with you, (b) Covered by article 9(2)(h) Health or Social care
To monitor severity of eating problem.	(2.2) Health Information	(a) performance of a service with you, (b) Covered by article 9(2)(h) Health or Social care
To process and deliver the program.	(2.1) Personal Information, (2.2) Health Information, (2.3) Usage Data, (2.4) Research Data, (2.5) Communication (2.6) Technical Data, (2.7) Marketing Information	(a) Performance of a service with you, (b) Covered by article 9(2)(h) Health or Social care
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to provide feedback	(2.1) Personal Information, (2.5) Communication Data, (2.7) Marketing Information	(a) Performance of a service with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(2.1) Personal Information, (2.6) Technical Data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(2.3) Usage Data, (2.6) Technical Data	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business)

4.2 When can you ask us to stop using your data

You can ask us to stop using your data at any time, however in doing so we will be unable to continue providing the service.

To request that we stop using your data, you can contact us using details set out in the Contact details section stating that you wish for us to stop using your data immediately. Please refer to our User Terms relating to Removal of User Information for further information.

5.0 Disclosures of your Personal Data

We may share your Personal Data as set out below for the purposes set out in the table Purposes for which we will use your Personal Data above.

Externally to service providers acting as Data Processors who provide IT and system administration services.

With HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We may share limited Personal Data with third parties for legitimate purposes in connection with a corporate transaction concerning Credo Therapies, such as restructure, takeover, merger or acquisition.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

5.1 Who we share your information with and why

The Digital CBTe services are run by us with our third-party service providers to provide the overall service. These companies will, as necessary, process your data to enable us to fulfil the Credo Therapies service you use.

5.1.1 Referrer(s)

Purpose: We may need to share your information with your referring healthcare provider (e.g. NHS Trust, or Insurer) to provide the service to you, with your consent.

What data we share: Personal Information, Health Information

5.1.2 Amazon Web Services

Purpose: Amazon Web Services provides cloud hosting for our platform. All data is encrypted and therefore not accessible by Amazon Web Services. Servers are located in UK / EU.

What data we share: All data

5.1.3 Twilio

Purpose: Provide SMS text messages to remind you about using the service. To receive messages you must opt in. If you do opt in you can opt out at any time by using the details set out in the Contact details section.

What data we share: Mobile phone number, message content.

5.1.4 Global Initiative

Purpose: Global Initiative provides development support of our platform and services and therefore have full access to all data provided on the platform.

What data we share: Personal Information, Health information, Research Data, Cookies

6.0 International transfers

If we transfer your Personal Data to a country, territory or organisation outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented. For example:

The country, territory or organisation is deemed in UK law to provide adequate protection for your Personal Data. This includes all EU and EEA countries and institutions.

The organisation receiving the data has entered into standard data protection clauses recognised or authorised under UK law, to protect your Personal Data.

Please contact us if you want further information using the details set out in the Contact details section.

7.0 Data security

The security of your Personal Data is important to us. We use reasonable security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Data is encrypted at rest using Amazon RDS encrypted database instances using industry standard AES-256 encryption. Data is encrypted in transit using SSL certificates. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We maintain the Cyber Essentials certification to help guard against the most common cyber threats and to demonstrate our commitment to cyber security. We also have procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You are responsible for the security of your device and passwords. If you believe that your details have been compromised then please notify us immediately using the details set out in the Contact details.

Our services may contain links to other websites and resources for your convenience and information. Credo Therapies do not endorse these sites, nor control them, we therefore encourage users to review the privacy policy of all external sites and resources.

7.1 How long may we keep your Personal Data for

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of the retention periods for your Personal Data can be provided on request. By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for financial accounting purposes.

We may delete your Personal Data by anonymising it such that you are no longer identified or identifiable from it.

7.2 Aggregated and Anonymised Data

Credo Therapies may use your Personal Information to create de-identified and aggregated data such as statistical or demographic data for research or statistical purposes. Aggregated Data could be derived from your Personal Data but will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy. We may use this aggregated or anonymised information indefinitely without further notice to you.

8.0 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you wish to exercise any of the rights set out below, please contact us using the details set out in the Contact details section.

You have the right to:

8.1 Request access to your Personal Data (commonly known as a “data subject access request”).

You may request a copy of the Personal Data we hold about you and further information about how we process it.

8.2 Request correction of the Personal Data that we hold about you.

You may ask to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

8.3 Request erasure of your Personal Data.

You may ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with the law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

8.4 Object to processing of your Personal Data

You may object to our processing where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You may also object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

8.5 Request restriction of processing of your Personal Data.

You may ask us to suspend the processing of your Personal Data in the following scenarios:

If you want us to establish the accuracy of the data.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

8.6 Request the transfer of your Personal Data to you or to a third party.

You may ask us to provide to you, or to a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

8.7 Withdraw consent at any time where we are relying on consent to process your Personal Data.

This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee or refuse to deal with your request if it is clearly unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We endeavour to respond to all legitimate requests within one month. Particularly complex requests or multiple requests may take longer than a month, in which case, we will notify you and keep you updated.

9.0 Automated Profiling

We may use logic which may be considered automated profiling. We will not use this logic to make decisions which would significantly affect you. The services use user entered data to identify if the service is suitable for them e.g. the product only supports specific eating problems. It also uses user entered data to identify if a user should be presented with information about addressing laxatives and purging. If a user believes any decisions are incorrect then they can request the decision be reviewed using the details set out in the Contact details section.

10.0 Children

Our services are not intended for children and we do not knowingly collect data relating to children. If you believe that a child is accessing this service then please report this using the details set out in the Contact details section. If we discover that we have collected Personal information from anyone under the age of 18 we will delete that information unless under a legal requirement to retain it.

11.0 Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Credo Therapies Limited

Data Protection Officer: Gareth Downing

Email address: compliance@credotherapies.com

Postal address: 8 King Edward Street, Oxford, United Kingdom, OX1 4HL

Telephone number: +44 (0) 1865 570067

12.0 Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The ICO can be contacted at:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113 (local rate) or 01625 545 745

Online: https://ico.org.uk/global/contact-us/

13.0 Change of purpose

We keep our privacy policy under regular review. We may update this privacy policy from time to time. We will notify you of the changes where required by law to do so and will ensure that new consent is obtained where required.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal bases which allows us to do so.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

14.0 Cookie Policy

What Are Cookies

As is common practice with almost all professional websites, this site uses cookies, which are tiny files that are downloaded to your device to provide the expected service. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the sites functionality.

For more general information on cookies see the www.allaboutcookies.org.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the site. Therefore disabling cookies may prevent you from accessing, or degrade your experience of, our services.

The Cookies We Set

We only set cookies where at least one of the following applies:

You have provided us with your consent to do so, via our pop-up cookies banner. You can manage your preferences via your browser settings.

The cookie is essential to provide a service over the internet that you have requested.

The cookie is for the sole purpose of carrying out the transmission of a communication over an electronic communications network.

If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your site preferences when logged out.

Essential /Security Cookies

We use cookies when you are logged in so that we can remember that you are logged in. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.

Analytics Cookies

In some special cases we also use cookies provided by trusted third parties.

This site uses Matomo for analytics helping us to understand how you use the site. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.

For more information on Matomo cookies, see the official Matomo cookies FAQ.

From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.

More Information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you are still looking for more information you can contact us at compliance@credotherapies.com. 

Last modified 16th August 2024