Privacy & Cookie Policy

This privacy policy applies to your use of:

  • Our website;
  • The Psyma App mobile application software (App) available as a download for use on your mobile telephone or handheld device;
  • Any therapy services provided to you by Dr Saeema Ghafur; and/or
  • The Psyma referral service when using one of our associated practitioners.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our website, App and services are not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Psyma Mental Health Technologies Limited (Psyma) is the data controller and is responsible for your personal data (collectively referred to as "we", "us" or"our" in this policy).

Contact details

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

Fullname of legal entity: Psyma Mental Health Technologies Limited

Email address:

We always try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive aboutt his very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. If you do have a complaint, contact our Data Protection Officer, Dr Saeema Ghafur who will investigate the matter on your behalf.

If you are not satisfied with the response from us or believe we are not processing your personal data in accordance with the law you have the right toraise your complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in February 2024.  It is important that the personal data wehold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website and the Psyma App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App or our website, we encourage you to read the privacy policy of every website you visit.

1.             The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use,store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, title and date of birth.
  • Contact Data includes billing address, home address, email address, telephone numbers and GP details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes 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 this website.
  • Sensitive Data includes information about your appearance (for example if you upload a photo on your profile page of the App) and health information.  The health information wemay collect includes information about your existing and previous medical conditions, medication details, psychiatric history, and any other relevant health information to enable us to carry out our services to you. This also includes presenting problem information and therapy records (referral forms, therapist notes, letters, reports and/or outcome measures).

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

We do not collect any other Special Categories of Personal Data about you (this includes details about religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Psyma does not keep credit card details such as name, credit card number, card expiry date, CVV code and billing address. The Psyma App uses a specialist payment processing organisation, called Stripe, who keeps this information secure. Note that Stripe will process this information in accordance with its privacy policies and terms from time to time, a copy of which can be found at and by providing your payment details, you agree to Stripe processing those details in accordance with their privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our therapy or referral services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

2.             How is your personal data collected?

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

  • Direct interactions. You may give us your Identity, Contact and Financial Databy setting up a profile on our App, by filling in forms before or during an appointment, verbally during discussions at our practice, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our services or any of our products;
    • create an account on the Psyma App;
    • If you complete a web-based enquiry form, we may also collect any Identity or Sensitive Data you provide to us. Our website is hosted by Webflow and are verified by themselvesas GDPR compliant; or
    • give us feedback orcontact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies 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.
  • Third parties. We will receive personal data about you from various third parties who may refer you to us for therapy.  For example, we may receive your data from NHS Practitioner Health if you have been referred to us for therapy services.
  • Analytical Partners.  We work with partners who provide us with analytics.  This helps us understand how users interact with our service and measuring performance of our service.  Cookies and similar technologies may be used to collect this information.
  • Anonymised Data.  From time to time we may use your data in an anonymised manner for our own research purposes.  None of your data used in this way will be traceable back to you, and so your confidentiality will be maintained.

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 performthe contract we are about to enter into or have entered into with you.
  • Where it is necessary forour legitimate interests (or those of a third party) and your interests andfundamental rights do not override those interests.
  • Where we need to complywith a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent when collecting sensitive data (such as health information). You have the right to withdraw consent at any time by contacting us.

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. We have also identified what our legitimate interests are where appropriate.

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.

To register you as a new client
Type of data
Lawful basis for processing including basis of legitimate interest
(a) Identity
(b) Contact
Performanceof a contract with you
To provide our services to you, including:
(a) Provide our therapy or referral services to you
(b) To confirm our scheduled appointments with you and to send you push notifications before the start of any therapy sessions
(c) Manage referrals, payments, fees and charges
(d) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Sensitive Data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Explicit consent (in the case of Sensitive Data).
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review
(a) Identity
(b) Contact
(a) Identity
(b) Contact
(c) Technical
(a) Performance of a contract 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 clients 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)
(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 or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Transaction
(e) Technical
Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, client relationships and experiences
(a) Technical
Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
Necessary for our legitimate interests (to develop our services and grow our business)


We do not actively send marketing materials to our clients.  However, if you have opted into our email updates we may send you information about our services that might be of interest to you.

If you have not opted in, we are unlikely to send you any marketing communications.  However, under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our  services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Third-party marketing

We will not share your personal information with third-parties for marketing purposes, nor will we ever sell your information to others.

Opting out

You can ask us to stop sending you marketing messages, such as our email updates if you are subscribed, at any time by contacting us. You can also request that your personal contact information is deleted to prevent future proactive contact from ourselves.


Our website and the Psyma App uses cookies to distinguish you from other users of our website and App. This helps us to provide you with a good experience when you browse our website or use our App and also allows us to improve our website and App functionality for you.

A cookie is a small file of letters and numbers that we store on your browser, your device or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive or device.

We use the following cookies:

  • Srictly necessary cookies. These are cookies that are required for the operation of our website and App. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website and App when they are using it. This helps us to improve the way our website and App works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website or App. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website or App, the pages you have visited and the links you have followed. We will use this information to make our website and App more relevant to your interests.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title
Cookie Name
More information

We do not share the information collected by the cookies with any third parties.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Change of purpose

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.

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

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.

3. Disclosures of your personal data

We hold information about each of our clients and the details of any referral or therapy they receive in confidence. This means that we will not normally share your personal information with anyone else other than to therapists and counsellors who you have opted to provide you with services.

We will tell your mental health professional the time and date of your appointment.  They will also have access to your user profile that contains your name, date of birth, your presenting problem and GP details.

In exceptional circumstances, we may share your personal data with the parties set out below, or in the below circumstances, for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.

  • Service providers, acting as processors who provide IT and system administration services, including Stripe who provide us with payment processing services and our website and App developers.
  • Professional advisers, acting as processors or joint controllers, including healthcare professionals, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. This includes when there is need-to-know information for another health provider, such as your GP.
  • HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based who require reporting of processing activities in certain circumstances.
  • If you select a practitioner on the Psyma App that is not Dr Saeema Ghafur, your personal data will be shared with your alternative chosen practitioner.

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.

International transfers

We do not transfer any of your data outside the United Kingdom and European Economic Area (EEA).

4. Data security

Once we have received your information, we will use strict procedures and security features to try to prevent your data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Personal information is minimised in the App and email communication. If email communication is required, sensitive personal data will be sent to clients in an email attachment that is password protected. The Psyma App will never use open or unsecure Wi-Fi networks to send any personal data.

Personal information is also stored on secure servers. Mobile devices are protected with a passcode/thumbprint scanner, mobile security and antivirus software.

The security of your personal information is important to us, but no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Should there be any breach of your personal data, we will inform you within 72 hours of knowing of it. We strive to ensure your personal information is protected at all times.

Data retention

How long will you use my 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.

By law we have to keep medical information about patients for 7 years after treatment has finished. After this time, this data is deleted at the end of each calendar year. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Occasionally we may store your information longer, for example, if there is an unresolved complaint.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you 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.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. For example, if you would like to deactivate an unused account. 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 local 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. To request this, you are able to email

Object to processing of your personal data where we are relying on a legitimate interest (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 also have the right to 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.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • 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.

Request the transfer of your personal data to you or to a third party. We will provide to you, or 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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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.

Time limit to respond

We try to respond to all legitimate requests within 30 days or receiving a request. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We may also require further evidence from you to confirm your identity.

A copy of your personal information will usually be sent to you in a permanent form (that is, a printed copy).