Built On The Rock Limited (“BOTR”) takes your privacy very seriously. This document is our "Privacy Policy" and it outlines our policies, procedures, and practices regarding the collection, use, and disclosure of any information you provide through the BOTR Platform or during Provider Services. This includes interactions with our Mental Health Advocates and the BOTR platform. Our Privacy Policy aligns with relevant regulations and legislation such as the General Data Protection Regulation (GDPR). The BOTR Platform and Provider Services are not intended for children, and we do not knowingly collect data related to children.

This Privacy Policy is part of our Terms of Use, which can be found on our website. Terms like "BOTR," "we," "our," "us," "Client," "Platform," "Provider," "Provider Services," "Session," etc., have the same meaning as in our Terms of Use document. By using our Platform, you agree to the Terms of Use and this Privacy Policy. If you disagree with the Privacy Policy, you should stop using the Platform immediately. By accessing and using our Platform, you confirm that you have read, understand, and agree to all the terms contained in both documents.

We are the data controller responsible for your personal data. We have appointed a Data Protection Officer (DPO) to oversee privacy-related questions. If you have any questions about this privacy policy, including requests to exercise your legal rights, please contact the DPO using the contact information provided below. Protecting your personal data is a top priority for us. We will never sell or rent your personal data. We will only use or disclose your personal data in limited circumstances as detailed in this Privacy Policy.

There are specific situations where we may share access to your personal data without your explicit consent, such as compliance with the law, protecting an individual's life, or responding to valid legal processes, government requests, rules, or regulations.

Personal data, or personal information, refers to any information about an individual that can be used to identify that person. This excludes data where the identity has been removed (anonymous data).

(a). We may collect, use, store, and transfer various kinds of personal data, which we categorise as follows:

• Identity data: Includes first name, last name, username or similar identifier, title, date of birth, and gender.
• Contact data: Includes address, email address, and telephone numbers.
• Technical data: Includes internet protocol (IP) address, 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 devices used to access the Platform.
• Profile data: Includes username and password and Session bookings made by you.
• Usage data: Includes information about how you use our Platform and the Provider Services.
• Marketing data: Includes your preferences for receiving marketing communications from us and our third parties, and your communication preferences.
• Provider Background Data: Includes information you provide to help us find a Provider, at your request.
• Provider Session Data: Includes any information you share during a Session. If you are a Provider, we may also collect, use, store, and transfer additional types of personal data, including:
• Financial Data: Includes bank account details.
• Qualification Data: Includes your professional qualifications and experience.
• Financial Data: Includes bank account details.

(b). We also collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data by law, as it does not directly or indirectly reveal your identity. For example, we may keep an anonymous, aggregated record of the number of Sessions used under a specific church’s allowance to share with the church without revealing individual users. However, if we combine or connect Aggregated Data with your personal data in a way that directly or indirectly identifies you, we treat the combined data as personal data in accordance with this Privacy Policy.




Other than Provider Background Data and Provider Session Data, we do not collect Special Categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.




If we need to collect personal data by law or under the terms of a contract with you and you fail to provide that data, we may not be able to fulfil our contract (e.g., to provide Provider Services). In such cases, we may have to cancel the services you have with us, but we will notify you if this occurs. You should not supply other people's personal data to us without their permission, and you are responsible for any data protection, confidentiality, or privacy implications of doing so.




We ensure that we collect and manage your personal data transparently, fairly, and securely. Whenever we collect information from you, we make sure you have access to the following information:

• Data we have collected from you.
• The basis on which we are holding it (e.g., because you gave us consent).
• What we will do with it.
• Where it is stored.
• Who it might be shared with.
• Your rights concerning the data.
• How you can access and manage this data.

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

• Direct Interactions You may provide Identity, Contact, Provider Background, Session, Financial, and Qualifications Data by filling out forms or corresponding with us via post, phone, email, or otherwise. This includes personal data provided when you:
  • Apply for our products or services
  • Interact with our platform
  • Create an account on our Platform
  • Request marketing materials
  • Enter a competition, promotion, or survey
  • Provide feedback or contact us.
• Automated Technologies or Interactions As you interact with our Platform, we collect Technical Data about your equipment, browsing actions, and patterns using cookies and similar technologies. Please see our cookie information (section 15) for further details.
• Third Parties or Publicly Available Sources We may receive personal data about you from various third parties and public sources, such as:
  • Technical data from the following parties: Analytics providers like Google. Advertising/affiliate networks
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Publicly available sources from the Providers directly or from third party referees (where relevant).

• Clients

  We use your personal data for the following purposes, indicating the type of personal data and the lawful basis for each purpose:

  • Account Creation and Access: To create your account, log you in, and provide access to the Platform. (Lawful basis of using Identity and Contact data for the performance of a contract with you)
  • Account Management and Customer Support: To manage your account, provide customer support, and ensure quality service. (Lawful basis of using Identity and Contact data for the performance of a contract)
  • Communications: To contact you with information, alerts, and suggestions related to our services. (Lawful basis of using Identity, Contact, Technical, Usage, Profile, and Marketing data for (a) the performance of a contract and (b) for our legitimate interests to develop our products and service)
  • Session Reminders: To send reminders before your scheduled sessions. (Lawful basis of using Identity, Contact, and Profile data for the performance of a contract)
  • Provider Matching: To match and connect you with a Provider. (Lawful basis of using Identity, Contact, Profile, Provider Background, and Session data for the performance of a contract and your explicit consent)
  • Service Facilitation: To enable and facilitate Provider Services. (Lawful basis of using Identity, Contact, Profile, Technical, Usage, Provider Background, and Session data for the performance of a contract and explicit consent)
  • Service Supervision and Monitoring: To supervise, administer, and monitor our services. (Lawful basis of using Identity, Contact, Technical, and Usage data (a) for the performance of a contract and (b) for our legitimate interests in running our business)
  • Service Improvement: To measure and improve the quality and delivery of our services. (Lawful basis of using Identity, Contact, Technical, Profile, and Usage data for our legitimate interest in monitoring and improving our services)
  • Marketing and Promotions: To provide information about our platform, including sending email newsletters, social media marketing, communicating promotions and offers. (Lawful basis of using Identity, Contact, and Marketing data for our legitimate interests to develop our products and services and grow our business)
  • Safety and Legal Obligations: To contact you, either ourselves or using the appropriate authorities, if there's a belief that you or others may be in danger or involved in criminal acts. (Lawful basis of using Identity, Contact, Profile, Usage, Provider Background, and Session data for protecting the vital interests of yourself or another person)
  • Business Administration: To support our business operations, including legal claims. (Lawful basis of using all personal data for the legitimate interests of administrative record-keeping, processing transactions, and maintaining business records or for the protection and assertion of our legal rights)
• Providers

  In addition to the above purposes set out for clients, if you are a Mental Health Advocate or Provider, we collect your personal data for:

  • Verification: To verify your suitability to provide Provider Services. (Lawful basis of using Identity, Contact, Qualifications, and Transaction data for the performance of a contract and to fulfil legal obligations)
  • Payment and Invoicing: To manage payments, fees, and charges and to collect and recover money owed to us. (Lawful basis of using Identity, Contact, Financial, and Transaction data for the performance of a contract and our legitimate interests in recovering debts)
  • Supervision: To supervise, monitor, and evaluate your services. (Lawful basis of using Identity, Contact, Qualifications, and Provider Session data for the performance of a contract and our legitimate interests in ensuring service quality and compliance)
  • Communications: To manage our relationship with you, including notifying you about changes to our terms or privacy policy. (Lawful basis of using Identity, Contact, Technical, and Usage data for the performance of a contract and our legitimate interests in keeping our records updated and understanding how providers use our services)
  • Compliance: To comply with legal or regulatory requirements. (Lawful basis of using all personal data for compliance with legal obligations)
• Marketing

  We strive to provide choices regarding personal data uses for marketing and advertising.

  • Promotional Offers: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or requested services from us and you have not opted out of receiving that marketing.
  • Third-Party Marketing: We will obtain your express opt-in consent before sharing your data with third parties for marketing.
  • Opting Out: You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
  • Change of purpose: We will only use your personal data for the purposes outlined unless otherwise notified. If we use your data for a different, compatible purpose, we will ensure your data's protection. For unrelated new purposes, we will notify you and explain the legal basis for the change.
  • Cookies: We use cookies for marketing, which you can control via browser settings. For details, see our cookie policy.

We may share your personal data with the parties set out below for the purposes set out above.

• Other companies in the BOTR Group who may provide IT and system administration services and undertake leadership reporting.
• The following external third parties:
  • administration services
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Specific third parties listed in section 4 (How We Use Your Personal Data) above such as Providers acting as independent controllers who provide the Sessions directly to you (where you are a Client booking Sessions).
• Third parties to whom we may choose to transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Other Legitimate Interests of our affiliates, contractors, or advisors.

We ensure these third parties maintain the same level of protection for your data as we do. 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.

We do not sell your personal data to third parties and only share it with your explicit consent or as required by law.

Some of our external third parties may be based outside the UK and the European Economic Area (EEA), so their processing of your personal data may involve a transfer of data outside these regions. Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection by implementing specific safeguards, such as:

• Transferring data only to countries that have been deemed to provide an adequate level of protection for personal data.
• Using specific contracts approved by the European Commission, which give personal data the same protection as it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorised way. Additionally, we limit access to your personal data to those employees, agents, contractors, and other third parties who need to know such data for business purposes. They are subject to a duty of confidentiality and will only process your data according to our instructions.

• In the unfortunate event of a suspected data breach, we will notify you and any applicable regulator as required by law.

We will retain your personal data only for as long as necessary to fulfil the purposes we collected it for, including satisfying 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.

In some circumstances you can ask us to delete your data: see section 10 (“Your 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.

Generally, we will retain data for a minimum of 7 years after the termination of the contract or the last active use of the Platform, whichever is later.

Our Platform may contain 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 Platform, we encourage you to read the privacy policy of every website you visit.

You have specific rights concerning your data under data protection laws. These include:

• The right to be informed about the collection and use of your personal data
• The right of access to your personal data and any supplementary information
• The right to have any errors in your personal data rectified
• The right to have your personal data erased
• The right to block or suppressing the processing of your personal data
• The right to move, copy or transfer your personal data from one IT environment to another
• The right to object the processing of your personal data in certain circumstances.
• Rights related to automated decision-making (i.e., where no humans are involved) and profiling (i.e., where certain personal data is processed to evaluate an individual).

To exercise these rights, contact our Data Protection Officer (DPO). We may require verification of your identity before fulfilling your request. We strive to respond to requests within one month, though complex requests may take longer.

• No fee is 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 one month. 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.

BOTR may revise this Privacy Policy from time-to-time. Any revised Privacy Policy will apply to the use of the Platform and Provider Services from the date of the publication of the revised Privacy Policy on this website. Please check this page regularly to ensure you are familiar with the most current version. BOTR is not obligated to update you on variations of this Privacy Policy, and you agree to regularly check this page to ensure that you are up-to-date with our policies, and terms at all times.

Our Platform uses cookies and other similar technologies to distinguish you from other users. This helps us provide you with a good experience when you browse our Platform and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookie Policy.

By using our Platform, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and transfer of your data as described.

BOTR cooperates with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process including but not limited to subpoenas, and to prevent or stop an activity that may be illegal or dangerous or unethical. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment. In addition, you should be aware that Providers may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities.

We are Built on the Rock Limited and our address is 74 Bramwell House, Harper Road, London, SE1 6RJ, England. For any questions or concerns regarding your privacy, please contact our Data Protection Officer at DPO@builtontherock.app

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.