Version 4 – updated 13 August 2021.
Welcome at Inuka’s privacy page!
At Inuka we are very keen about protecting your privacy. So we did our best not only to protect your data but also describe in the simplest possible ways how we go about it below. And of course feel free to reach out to us directly with questions anytime at firstname.lastname@example.org , or if you enjoy direct contact with an absolute amazing privacy-obsessed nerd – and also our independent Data Protection Officer – you can reach out to email@example.com where
Michael is ready for you!
All the best,
Robin van Dalen
In a nutshell:
- We will always ask for your consent before collecting your data.
- We only ask you for the personal information we need to offer the best service possible.
- Everything we do with your data serves the same purpose.
- We shield your data from anyone or anything (including ourselves) who doesn’t need to see it. For example, the coaches and their supervisors only see the chat and wellbeing test results, but never have access to your email.
- 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!). So yes we are as strict in Kenya as we are in the Netherlands.
- We pick our friends wisely and make sure that they uphold the same standards for privacy protection.
- We would never betray your trust and supply your personal info to outsiders, only to our partners, who are completely trustworthy and adhere to the same standards as we do.
- We have an independent Data Protection Officer appointed to ensure independent, high-quality, specialized support.4
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.
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 firstname.lastname@example.org or Rapsodieplantsoen 11, 1312EJ Almere, Netherlands.
Subsidiaries of –
Inuka B.V. (Netherlands)
Your data is processed by our holding company and possibly also by our subsidiaries.
If you have any questions for us, you can always reach us at: email@example.com 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: firstname.lastname@example.org.
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 (complicated legal term to describe what we do) 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 an app-platform that is built on trust, anonymity and safety; where you can ask for support for any type of issue via 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 are also working together with universities and research institutes to ensure the quality of the coaching is maintained and 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. None of the involved parties (including us) makes money on the research that is done; all conclusions and results are published publicly. And as you will read later, we work our bums off to make sure that your data protected throughout the research process. Since we don’t know what you discuss with our coaches, we regard every single chat as top secret sensitive data, which means that we protect your personal data from misuse and breaches. Of course, we also need some simple personal
information about who you are; this data is handled with the same amount of love and care as your chat conversations, top secret!
How do we obtain your personal data?
We obtain your personal data because you accessed our web-app or installed and use our native Inuka app on your phone. We do not collect your personal data via any other sources or parties. All the personal data we receive is directly supplied by you, the user.
What personal data does Inuka collect?
About chatting with Inuka and anonymity.
Simply put, ‘Personal information’ and ‘Sensitive informatino’ 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.
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. Everything we do with your data serves the same purpose. 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?
With who do we share your personal data?
Facilitating the Inuka Platform
Whenever we use the services 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 personal data and or chat transcripts!
With all the parties that we need to provide you with our Inuka service we sign data protection assignments in which we demand the highest standards of data protection.
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 Super Coaches and Therapists actively monitor our Coaches; our supervising system makes sure that we can offer consistent, high quality support to everyone and that our Coaches are trained to perfection. Of course, all transcripts are made anonymous, so Coaches and their supervisors will never know who is behind the chat conversations. And on top of that, all our Coaches and supervisors have signed a professional non-disclosure agreement (like lawyers and doctors), so you can definitely trust them.
In the case that 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.
Disclosing sensitive information to local authorities, 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 no longer use the Inuka platform, your data gets 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 at email@example.com 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:
- TLS 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 provided by Oracle
- Double factor authentication for employees
- Role based user access for employees
- Audit logs for users that have access to sensitive data
- We only use AWS servers which are state of the art
Everything that is stored on our secure private server is encrypted, ask all employees to only store their data on our secured servers, not on their devices and Meaning that if any of our employees loses its device, the device typically does not cause a data breach.
Our chat sessions
Knowing how we keep your chat content completely anonymous; it is also up to you to maintain this. Please refrain from sharing any sort of 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. If you do share personal identifiable information with us, we will replace that information with random information. For example, if you share where you work (please don’t! Just say I work at a big tech company) we will replace that word with “Company XYZ”. We do not store information that can help us decipher what “Company XYZ” means.
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!
- 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.
- 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.
- 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.
- 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.
- 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.
- The Right to Object: You can object to the processing of your personal data, at any time.
- The Right to Portability: You can request a copy of all your personal data processed by Inuka.
- 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 used all your coaching credit or when you have deleted the Inuka app.
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. 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 exercise of these rights by sending an email to firstname.lastname@example.org. When you do this you will get in touch with our independent, external data protection officer, which will help you right away.
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!
To identify that it is you making the request, we ask you to send an email to email@example.com, and for the right to be forgotten or portability to login to your Inuka account and submit your request. At our FAQ page you can find more details how to do this.
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 firstname.lastname@example.org. 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
And of course feel free to reach out to us directly with questions anytime at email@example.com, or if you enjoy direct contact with an absolute amazing privacy-obsessed nerd – and also our independent Data Protection Officer – you can reach out to firstname.lastname@example.org where Michael is ready for you!
All our love,
The Inuka Team