Privacy Policy
Last updated: June 2023
MENTIAL HEALTH TECHNOLOGIES S.L. hereby informs you of its privacy policy applied to personal data. Use of this website implies that the user must provide information regarding their identity; such data will be collected and used in accordance with the limitations and rights set out in the aforementioned regulations.
Data Controller
Identification data of the Data Controller of your data
Company name
Mential Health Technologies S.L.
Tax ID (CIF)
B44859536
Registered office
C/ Sueños, 5. Portal 5. 4-C. 28100 Alcobendas (Madrid)
Data Protection Officer
Types of data we process
Depending on the services or functionalities you wish to use at any time, we will need to process different types of data. In general, such data will include, as the case may be: Your identification data (e.g. name, surname, language, country from which you interact with us, contact details, etc.); connection, geolocation and navigation data (e.g. when you interact with us from a mobile device); data on your preferences; special category data for the provision of psychological/psychiatric treatment; data relating to personal circumstances; data relating to behaviour, habits and customs; data necessary to fulfil the purposes requested by the client through the selected service; health data. Please note that when we ask you to fill in your personal data to access any functionality or service on the web, we will mark certain fields as mandatory, as they are data we need to provide the service or grant access to the functionality in question. The provision of this personal data, including the transfer of images, is voluntary. Please note that if you choose not to provide such data, you may not be able to complete your registration as a user or access those services or functionalities.
Purpose and legal basis for processing
You do not need to provide any personal data to browse the platform. You provide your personal data when: contacting us through contact forms or sending an email; posting a comment on an article or page; taking any of our health diagnostic tests; contracting any of the services we offer on the platform and during the performance of the activities included in such services. By providing this information, you consent to your information being collected, used, managed and stored by the Platform, only as described in this Privacy Policy. Personal data and the purpose of processing by the Platform varies according to the information capture system: Contact forms, subscription forms, tests, video calls, chat. There are other purposes: ensuring compliance with the conditions set out in the Legal Notice and applicable law; payment for services; managing and controlling Enterprise and Partner Programmes; managing your registration as a User; making the technical means of the platform available; proposing Psychologists to Users; verifying the quality of services provided; handling requests, queries or suggestions; controlling the platform's IT security; managing and controlling promotions; sending information by email; supporting and improving services; analysing navigation (cookies); regulatory compliance; responding to requests from competent authorities.
Retention of personal data
Mential will retain the personal data of patients only for as long as necessary to fulfil the purposes for which they were collected or while legal or contractual obligations so require. In particular: Clinical and therapeutic data: retained for five (5) years in accordance with applicable healthcare regulations. Recordings, usage data, GPS location and digital behaviour: retained for five (5) years, except where clinically justified. Administrative or contractual data: for as long as necessary to comply with tax, accounting or regulatory obligations. Once the aforementioned periods have elapsed, the data will be irreversibly deleted or anonymised so that they cannot be re-identified. As these are medical data, they must be properly stored for a period of 5 years.
Sharing data with third parties
Personal data will be disclosed to: Employees and/or authorised collaborators (medical specialists and psychologists) by Mential, always subject to applicable data protection rules; financial institutions and payment gateways for the management of collections and payments; technology providers offering their products, marketing tools, communications, analytics and cloud computing services. Except for these exceptions, personal data will not be transferred or disclosed to third parties, except: 1) where legally required, 2) where we have your express consent, or 3) where we consider that we have a legitimate interest, which will be duly communicated to you. We are present on social networks (Facebook, LinkedIn, Twitter, Instagram and Telegram). You may access these social networks voluntarily. This website is not responsible for the use that these social networks may make of your data. However, when such data are generated on the social network and derive from an interaction with our official account, we will be joint controllers of the processing together with the social network. For more information and to consent to our transfer from this website and the processing of your data, you should read the privacy policy of the social network you wish to access: Facebook: https://es-es.facebook.com/privacy/explanation | LinkedIn: https://es.linkedin.com/legal/privacy-policy | Instagram: https://about.instagram.com/es-la/safety | Twitter: https://twitter.com/es/privacy | Telegram: https://telegram.org/privacy?setln=es. Other technology services: WhatsApp: https://www.whatsapp.com/legal/updates/privacy-policy/?lang=es
Data transfer and international transfers
The User understands and accepts that, if they request/offer Psychologist services, their identification data and the preliminary information provided about the services they request/offer may be communicated to other Users as the counterparty necessary for the provision of the requested/offered service. In addition, Mential may make international transfers of personal data. In relation to Users benefiting from Enterprise or Partner Programmes, Mential will necessarily transfer personal data to companies and partners. Mential will not transfer Users' health data to companies or partners. Mential will prepare reports on Platform use for companies and partners containing only aggregated information. Where any of our service or IT system providers are located outside the EEA, Mential will adopt all applicable safeguards under the regulations to ensure adequate data management.
Use of Artificial Intelligence (AI)
Mential uses artificial intelligence algorithms integrated into the platform to offer personalised digital therapies adapted to each patient's clinical status. These algorithms process information from therapeutic exercises, app usage and other clinical markers (voice, text, digital behaviour) to support professional supervision and optimise therapeutic progress. All recommendations or micro-interventions generated by the system are reviewed by a qualified psychologist before being applied to treatment. Mential does not make automated clinical decisions nor does it replace human professional judgement. The legal basis for this processing is Article 6.1.b of the GDPR (performance of the therapeutic service contract) and Article 9.2.h of the GDPR (processing necessary for healthcare purposes). Data processed by AI are not used for commercial purposes nor communicated to third parties outside the provision of the service.
Recording of video calls and therapeutic analysis
During video call sessions, Mential may record the interaction between the patient and the psychologist solely to improve therapeutic quality and personalise the psychological intervention. These recordings allow analysis, through supervised AI models, of voice, text and emotional tone markers relevant to clinical progress. Processing of these recordings is based on the patient's explicit consent (Articles 6.1.a and 9.2.a of the GDPR), given within the application before starting the recorded session. The patient may revoke this consent at any time, without affecting the provision of digital treatment, but it may affect the capacity for personalisation and its effectiveness. Recordings will be retained for a maximum period of 3 years, unless it is necessary to retain them for clinically justified reasons, after which they will be irreversibly deleted or anonymised.
Location data (GPS) and digital behaviour
With the patient's explicit consent, the Mential application may collect information on their geographical location (GPS) and on the use of the mobile device (e.g. frequency and time of app use). These data are used exclusively for therapeutic purposes: to improve treatment personalisation, adjust micro-interventions and generate early risk alerts, always under the supervision of a qualified psychologist. The legal basis is explicit consent (Articles 6.1.a and 9.2.a of the GDPR). The patient may revoke this consent at any time from the privacy section of the application or by writing to the Data Protection Officer (DPO). GPS and digital behaviour data will be retained for a maximum of three years, unless clinically or legally justified, after which they will be deleted or anonymised.
Your rights
We are committed to respecting the confidentiality of your personal data and ensuring you can exercise your rights. You may exercise them at no cost by sending us an email to dpo@mential.io, simply indicating the reason for your request and the right you wish to exercise. If we consider it necessary to identify you, we may ask you for a copy of an identity document. In particular, you have the right to: request access to your data that we hold; request rectification of the data we hold; request erasure of your data where they are no longer necessary; request restriction of processing; where you have given consent for any purpose, you also have the right to withdraw it at any time; receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format, and to transmit them to another controller; where processing is based on our legitimate interest, you also have the right to object to the processing of your data. The patient may exercise the rights of access, rectification, erasure, objection, restriction of processing and portability of their data, as well as revoke any consent given (including that relating to GPS, recordings or digital behaviour analysis). To do so, they may send a request to dpo@mential.io indicating the reason and the right they wish to exercise. Mential will respond to all requests within a maximum of one (1) month of receipt, in accordance with Articles 15 to 22 of the GDPR. Finally, we inform you of your right to lodge a complaint with the competent data protection supervisory authority, in particular the Spanish Data Protection Agency: https://www.agpd.es/portalwebAGPD/index-ides-idphp.php
Information about cookies
We use cookies and similar devices to facilitate your navigation on the Platform, to understand how you interact with us and, in certain cases, to show you advertising based on your browsing habits. Please read our Cookie Policy for more detail on the cookies and similar devices we use, their purpose and other relevant information.
Note on the use of the Mential platform
Mential is a digital clinical support tool supervised by qualified psychologists. Currently, the platform does not have CE marking as a medical device, so its use is for support purposes and does not replace professional clinical judgement. All decisions related to psychological treatment or clinical follow-up are validated by mental health professionals.
Changes to the Privacy Policy
We may modify the information contained in this Privacy Policy when we deem it appropriate. If we do so, we will notify you through various channels on the Platform, or we may communicate it to your email address when the change is significant for your privacy, so that you can review the changes, assess them and, where appropriate, object or unsubscribe from any service or functionality. This clause was last updated in June 2023. Data Protection Policy v1_2023
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