Personal Data Processing Policy

Version v1 · Last updated: July 2026

This platform is not an emergency or crisis service, and does not replace medical or psychiatric emergency services. Requests received through the forms are reviewed on a deferred basis; there is no immediate attention.

If the User is in a situation of immediate risk to their life or physical integrity, or to those of another person, they must contact their local emergency services as a matter of priority. In Argentina, 911 and, for suicidal behaviour, 135 from the City of Buenos Aires and Greater Buenos Aires, or (011) 5275-1135 from the rest of the country (Centro de Asistencia al Suicida). In Spain, 112 and 024 (Suicidal Behaviour Helpline). In any other country, the emergency number for their place of residence.

Acceptance of this policy is a necessary condition for completing the intake form. Users who do not agree to it may contact the Controller by email without using the system.

1. Data controller

The Controller practises as an individual professional. The processing of the data and all decisions relating to it are his exclusive responsibility. No other users have access to the system, without prejudice to the processors listed in clause 5.

2. Data processed

The system collects the following categories of User data.

2.1. Identification and contact data

Name, surname, email address, telephone number, identity document, address, and the details of the person designated as emergency contact (name, relationship and telephone number).

2.2. Special categories of data

The following data constitute special categories of personal data under art. 9 GDPR and sensitive data under arts. 2 and 7 of Law 25.326 (Argentina), and are subject to reinforced protection:

• Health data: reason for consultation and its detail, previous treatments, therapeutic goals, expectations regarding treatment, other professionals involved, medication and substances (name, dose, frequency, prescribing professional and reason), health coverage, preferred hospital, responses to the therapeutic preferences questionnaire, and responses to the assessment questionnaires, of two kinds: a post-session questionnaire, on the course and usefulness of that session; and a progress and discharge questionnaire, roughly monthly, on overall feedback about the process, perceived progress and the fit of the treatment.
• Gender identity data. Collected for the purpose of addressing the person in accordance with their identity from the first contact and of properly contextualising their care. It has no bearing whatsoever on the fee (clause 4.4) and is not used for commercial, advertising or segmentation purposes.
• The socio-economic data listed in clause 2.3, to the extent that they reveal the User's personal circumstances.

2.3. Demographic and socio-economic data

Date of birth, marital status, whether the User has children and their ages, country and city of residence, country and city of origin, occupation, employment status, level of education, declared ability to afford a private fee, and declared economic circumstances.

These data serve a dual purpose, which is expressly stated for the purposes of art. 13.1.c GDPR:

• They constitute clinically relevant information for assessment and treatment.
• They feed the automated calculation described in clause 4, whose sole purpose is to assess whether a reduction on the reference rate should be applied, in order to safeguard access to treatment in circumstances that might otherwise hinder it — unemployment, student status, precarious employment, recent migration, or residence in countries with lower average incomes, among others. These data are never used to increase the fee above the reference rate.

2.4. Technical data

On each access to the forms and to the patient portal, the system records: IP address and the approximate location derived from it (country, region and city); browser and device; language and time zone configured on the device; and device and session identifiers.

Evidential and authentication purpose. When the User accesses the portal, accepts the informed consent form or confirms any other legal text, the system leaves a tokenised record of that act: it associates the access with a cryptographic fingerprint of the token — which uniquely identifies the session without allowing it to be reused — together with the IP address, the device, the date, and the cryptographic fingerprint (SHA-256 hash) of the exact text displayed.

The purpose of this record is to make it possible to demonstrate, in the event of a dispute and before a third party (professional body, supervisory authority or court): that the act was performed by the User to whom the data belongs and not by another person; which exact version of the document was displayed to them and accepted, and on what date; and that the text has not been altered after acceptance. This record protects the User and the Controller equally.

2.5. Forms in progress and behavioural data

While the forms are being completed, the system records the answers entered up to each point, together with the following usage data:

• Time spent on each step and number of visits to each step.
• Time spent on each field and number of edits or corrections to it.
• Time elapsed until the User's first interaction with the form.
• Effective time in use, as distinct from total session time.
• Scroll percentage over the informed consent text and whether it was read to the end.
• The step and field at which completion is interrupted, where applicable, and the moment of interruption.

Absence of identifying data. This record contains no identifying data. The name, surname, email address, telephone number, identity document and date of birth are neither transmitted nor stored. Of the age, only the number of years is retained. Identifying data are transmitted upon submission of the form, and not before.

The information relating to a form that has not been submitted is not associated with any identifying data, nor with any record that would make it attributable to a specific person. It is therefore anonymous (Recital 26 GDPR), and is retained solely as statistics.

Upon submission of the form, the identifying data are incorporated into the processing and are governed by clauses 2.1 to 2.3 and by the legal bases set out in clause 3.

Purpose. These data are processed for the purpose of assessing and improving the design of the forms and the quality of the service provided, and of identifying barriers to access. In particular, recording the step and field at which Users interrupt completion makes it possible to determine:

• whether a question is confusing, excessive or poorly worded, and should be amended or removed;
• whether the length of the form is itself an obstacle;
• whether the fee communicated operates as an economic barrier to access, in what proportion of cases and for which profiles. Consistent with the accessibility purpose set out in clause 4.1, this information is used to review the reference rate, the applicable reduction limits and the scope of the bursary scheme, so that price does not prevent access to treatment for those who need it.

This analysis is carried out in aggregate form, aimed at detecting patterns in the instrument and in the service, not in individual persons.

Exclusion from clinical use. Behavioural data are not incorporated into the clinical record, nor used as material for the clinical assessment of the User, nor cross-referenced with their health data for interpretative purposes.

Resuming completion. A User who interrupts a form may resume it from the same device: what has been entered is kept in the User's own browser, on their own equipment, and does not depend on the record described in this clause.

2.6. Patient portal usage data

For Users who access the portal, the system records usage events, the duration of visits, the fee displayed, bookings and payments reported, receipts provided and questionnaires completed, together with the technical data described in clause 2.4.

Access to the portal takes place by means of an individual cryptographically signed token sent to the User's email address. The record of each access is associated with the fingerprint of that token, for the dual purpose of demonstrating that the actions carried out in the portal — bookings, payment notifications, submission of documents and completion of questionnaires — were carried out by the User and not by a third party, and of making it possible to detect unauthorised access.

2.7. Public website and cookies

The public website uses Google Analytics for statistical purposes, which involves third-party cookies. Such cookies are only installed if the User gives consent, by means of the notice displayed on the first visit. Users may refuse them without this affecting the operation of the site, and may reverse their decision at any time by clearing their browser cookies.

The intake form, the assessment forms and the patient portal do not incorporate analytics tools or advertising tracking technologies of any kind.

3. Legal bases for processing

Withdrawal of consent. Where processing is based on consent, the User may withdraw it at any time and without giving reasons. Withdrawal does not affect the lawfulness of prior processing. Data forming part of the clinical record whose retention is required by health legislation (clause 7) are excepted from withdrawal, and must be retained for the legally prescribed period regardless of withdrawal and of the end of the therapeutic relationship.

4. Discounts and bursaries

The functionality described in this clause is not currently in operation. Information is provided in advance of its implementation.

4.1. Purpose of the processing

The service has a single reference rate. Sessions have a price set in advance and on a general basis, identical for all Users within a comparable monetary zone, which is not determined by reference to the personal characteristics of each User.

The sole purpose of the automated calculation described in this clause is to consider whether a reduction on that reference rate should be applied, in order to safeguard access to psychological treatment in those personal, economic or geographical circumstances in which paying the reference rate could be disproportionately burdensome or directly prevent access to the service — including, without limitation, unemployment, student status, precarious employment, recent migration, or residence in countries whose average income level is substantially lower than that of the zone in which the reference rate is set.

The processing is not intended to increase the fee on the basis of the User's profile, nor to identify Users with a greater ability to pay in order to charge them more than the reference rate. The system can only operate downwards from the applicable reference rate.

4.2. Description of the processing

On the basis of data provided by the User in the intake form — country and city of residence, country of origin, length of residence in the country, occupation, employment status, level of education, mode of care and time slot — the system will calculate an indicative fee proposal and display it to the User, on the terms and for the accessibility purpose set out in clause 4.1.

The system also records, with no bearing whatsoever on the fee, other variables: device language and time zone, health coverage, age, whether the User has children, and marital status. They are recorded in order to assess subsequently whether they constitute useful indicators for the accessibility purposes indicated. Should any of them come to affect the fee, this policy will be updated and communicated to the User in advance.

4.3. Logic applied

The calculation follows a deterministic formula, not a machine-learning system:

• The User's monetary zone of residence determines the applicable reference rate. The reference rate is a single rate for each monetary zone and is identical for all Users residing within it: it is the price of the service.
• The country of residence determines a reduction range —a minimum reduction and a maximum reduction— applicable to that rate. Both limits are set by reference to the average income level of the country. In higher-income countries the minimum reduction may be zero, so that the reference rate is effectively applicable; in the others there is a structural reduction that applies irrespective of any other circumstance of the User.
• Where the User resides in a country other than their country of origin, and only where the country of residence has a higher average income level than the country of origin, a recent-migration adjustment applies, operating in two ways, both exclusively in the User's favour: (a) it widens the maximum reduction, lowering the minimum attainable fee; and (b) it lowers the score referred to in the following point, which increases the reduction actually applied within the range.
  
  The strength of the adjustment depends on the difference in average income level between the two countries and decreases with length of residence, until it disappears. It reflects the fact that effective integration into the economy of the destination country is not immediate, and that recent migration usually entails lower income than that of an already established resident.
  
  Migration to a country of equal or lower income level has no effect whatsoever. This adjustment can in no case increase the fee.
• Occupation, employment status and level of education produce a score that places the applicable reduction within the range described above.
• Adjustments are applied for mode of care and time slot, which can only operate as a discount, and the result is always rounded down.

The resulting fee can in no case exceed the reference rate of the User's monetary zone. The structure of the calculation makes this impossible by design: the calculation starts from the reference rate and only subtracts.

Consequently, the country of residence can only reduce the fee, never increase it. No User pays more than the reference rate of their monetary zone by reason of their residence or nationality.

4.4. Excluded variables

Gender identity, marital status, the reason for consultation and the severity of the clinical presentation have no bearing whatsoever on the fee. In particular, the fee is neither increased nor varied according to the severity, urgency or nature of the User's condition. Nor is data collected on the income of the User or their household, this having been considered unnecessarily intrusive for the purpose pursued, in application of the principle of data minimisation (art. 5.1.c GDPR).

4.5. Human intervention and the User's rights

The fee displayed by the system is indicative and is reviewed by the Controller before being finally determined. The User may in any event state that the proposed amount does not match their circumstances, without any need for documentary evidence, in which case the Controller will consider applying a further reduction or a bursary in accordance with clause 4.6.

Under art. 22 GDPR, the User has the right to obtain an explanation of the logic applied and of the result obtained in their particular case; to contest the result and obtain its review by a natural person; and to express their point of view and not to be subject to a decision based solely on automated processing of their data.

4.6. Bursaries and reductions on grounds of financial hardship

Independently of the automated calculation, and consistent with the accessibility purpose set out in clause 4.1, the Controller offers bursaries which cover part of the cost of a given number of sessions in cases of financial hardship — including unemployment, reduced income, student status or family responsibilities.

A bursary does not alter the rate: it operates as a reduction on the amount actually paid by the User. It is offered but not guaranteed, is granted for a set number of sessions, and may be applied for again once exhausted, without a previous grant creating any entitlement to a further one.

In order for a bursary to be assessed, the User may describe their circumstances freely. Any information provided for that purpose is processed exclusively for the purpose of assessing the bursary and is not incorporated into the clinical record, nor used for any other purpose.

5. Recipients of the data

Data are not disclosed to third parties, except in the cases set out in this clause. The Controller is bound by professional confidentiality under Law 26.529 and the professional code of ethics (Argentina) and under Law 41/2002 (Spain), an obligation which subsists after the end of the therapeutic relationship.

5.1. Processors

The following providers process data on the Controller's behalf, under the corresponding data processing agreements (art. 28 GDPR), and do not use it for their own purposes:

5.2. Other disclosures

• Judicial and administrative authorities, where there is a legal obligation to disclose.
• Other healthcare professionals, exclusively with the User's prior explicit consent or in a situation of risk to life, on the terms of the informed consent document.

Data are not sold, transferred or disclosed for commercial or advertising purposes.

6. International transfers

Data may be transferred between Argentina, Spain / the European Union, the United States and Switzerland, where the processors' servers are located.

• The Argentine Republic has been recognised by the European Commission as providing an adequate level of protection (Decision 2003/490/EC), so transfers from the European Union to Argentina do not require additional safeguards.
• Transfers to the United States are covered by the EU-US Data Privacy Framework and/or by the Standard Contractual Clauses approved by the European Commission.
• Switzerland has likewise been recognised by the European Commission as providing an adequate level of protection, so transfers to that country do not require additional safeguards.

7. Retention periods

Once these periods have elapsed, the data are deleted or irreversibly anonymised.

8. The User's rights

The User may exercise the following rights, free of charge and without having to give reasons:

• Access to the data processed and to obtain a copy.
• Rectification of inaccurate data.
• Erasure, subject to the limits applying to data forming part of the clinical record whose retention is required by law.
• Restriction of processing.
• Portability of the data in a structured, commonly used format.
• Objection to processing based on legitimate interest.
• Withdrawal of consent at any time.
• Not to be subject to automated individual decision-making, including the fee calculation, with the right to obtain human intervention, to express their point of view and to contest the decision (clause 4.5).

Scope as regards forms not submitted. These rights are exercised over personal data. The information relating to a form that has not been submitted (clause 2.5) contains no identifying data and cannot be attributed to a specific person, so it is not possible to identify the records of a particular User nor, consequently, to access, rectify or erase them at their request. That same impossibility is what makes the exercise of these rights unnecessary: the data does not refer to them.

How to exercise them. By writing to psi.ivanwaisman@gmail.com. The Controller will respond within a maximum of one month (art. 12.3 GDPR). Proof of the applicant's identity may be required.

Complaint to a supervisory authority. If the User considers that the processing does not comply with the applicable rules, they may lodge a complaint with the Spanish Data Protection Agency (AEPD, aepd.es) in Spain and the European Union, or with the Agency for Access to Public Information (AAIP, argentina.gob.ar/aaip) in Argentina.

Exercising any of these rights has no effect whatsoever on the provision of the therapeutic service.

9. Security measures

• Access to the administration panel is protected by a password stored as a cryptographic digest (SHA-256), not in plain text.
• Access to the patient portal uses cryptographically signed tokens (HMAC-SHA256) valid for 90 days. The database stores the fingerprint of the token, not the token, so that it cannot be reconstructed from the record.
• Hosting on infrastructure with encryption in transit and at rest.
• Audit log of every modification made to the records, with date and previous content.
• Storage of the cryptographic digest of the legal texts accepted, in order to demonstrate the version displayed.

Security of the hosting account. The data is hosted on Google services (Workspace, Sheets, Drive and Gmail), which act as processors in accordance with clause 5. Access to that account is protected by two-step verification, so that knowledge of the password alone is not sufficient to access the data. The access credentials are of high complexity and are themselves kept under a system protected by two-factor authentication.

Notwithstanding the above, no information system is entirely invulnerable. In the event of a security breach entailing a risk to the User's rights and freedoms, the Controller will notify the supervisory authority within 72 hours and will communicate the breach to those affected where the risk is high, in accordance with arts. 33 and 34 GDPR.

10. Minors

The service is aimed exclusively at adults. The Controller does not provide psychological care to persons under 18 years of age.

The intake form must not be completed by minors. Should the Controller become aware that the data provided relate to a minor, it will be deleted and, where appropriate, the person will be directed towards care resources appropriate to their age.

11. Changes to this policy

The Controller may amend this policy. Any substantial amendment — in particular the bringing into operation of the automated calculation aimed at applying reductions on the reference rate (clause 4), or the inclusion in it of variables that are currently only recorded — will result in the version of the document being raised and in it being communicated to the User before it applies to them. The system keeps a record of the version accepted by each User.

It is expressly stated that any amendment allowing the automated calculation to determine a fee higher than the reference rate, or to increase it on the basis of the User's profile, would alter the purpose declared in clause 4.1 and would require, in addition to the updating of this policy, fresh consent to be obtained.

12. Contact

For any query concerning the processing of personal data: psi.ivanwaisman@gmail.com