We are ClinicalWill.app Ltd (trading as EthicsInPractice.app) (we, us or our). We are a private limited company registered with company number 14131785 and our registered office is Amelia House, Crescent Road, Worthing, BN11 1RL.
We are committed to protecting the privacy and security of your personal data. This Privacy Notice describes how we collect, use and look after your personal data when you visit our website https://ethicsinpractice.app (our Site) - regardless of where you visit it from, or whether you subsequently register as a practitioner to use our platform (our Platform) - and when you use our Platform. It also tells you about your rights and how the law protects you.
1.1. Supplemental Terms - This Privacy Notice supplements the other notices and terms published on our Site (including our User Agreement, Data Processing Agreement, and Website Terms) (Terms) and is not intended to override them. In particular, while this Privacy Notice describes how we process your own personal data as a visitor to our Site or as a user of our Platform, the Data Processing Agreement governs the processing of any personal data relating to third parties which is inputted by you or on your behalf onto the Platform.
1.2. Controller - In most circumstances, we are the controller of, and are responsible for, your personal data. We are registered as a data controller with the UK Information Commissioner's Office. Our data protection registration number is ZB709337. However, please note that we act as processor only in respect of personal data relating to third parties which practitioners or other users of the Platform share with us via our Platform, and this may include information relating to you which the practitioner or other user shared with us prior to your first access to the Site or Platform. In such circumstances, the initial sharing of your information was undertaken by the relevant practitioner or other user in the role of controller of your personal data, and we would recommend that you refer to their privacy notices or policies for further information on how they handle and process your data.
1.3. Beta Platform - Please note that the Platform is currently made available on a free prototype and beta-testing basis. It is under active development and may be changed or withdrawn at any time.
1.4. Questions - If you have any questions about this Privacy Notice, or wish to exercise your legal rights, please contact us in writing by email at support@ethicsinpractice.app.
1.5. Complaints - You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) (www.ico.org.uk). We would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
1.6. Who can use our Platform - Our Platform is not intended for minors, and we do not accept minors as users of the Platform.
1.7. Changes to this Privacy Notice - We may change this Privacy Notice from time to time by updating this page. Please check it regularly.
1.8. Changes to your personal data - It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
1.9. Third-party links - Our Site and our Platform may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy notices, therefore you should read their privacy notices to understand what personal data they collect about you and how they use it.
1.10. Understanding - To assist you further in understanding this Privacy Notice, we have set out in the Schedule a glossary of terms used in this Privacy Notice, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
2.1. We may collect, use, store and transfer the types of personal data about you listed in Part 1 of the Schedule.
2.2. We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
2.3. We do not collect clinical or therapeutic client data through the Platform. The Platform is designed for practice administration purposes only. If you inadvertently upload information of this kind, please contact us so that we can assist you in having it removed.
2.4. Failure to provide personal data - If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it:
2.4.1. we may not be able to enter into or perform the contract with you; and/or
2.4.2. we may have to cancel the contract (as applicable).
We will notify you of this at the relevant time.
| Direct interactions | You provide personal data when you complete our registration form, set up and use your account on the Platform, or otherwise correspond with us. |
| Automated technology | We automatically collect technical and usage data when you browse or interact with our Site, by using cookies, server logs and similar technologies. |
| Third parties | We may receive personal data from analytics providers, website support providers, and other suppliers. |
4.1. We will only use your personal data when the law allows us to. Most commonly, we will use it:
(a) to perform the contract we have entered into with you for access to the Platform;
(b) to comply with a legal obligation; or
(c) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.2. Part 2 of the Schedule sets out the lawful basis we will rely on to process your personal data.
4.3. Please 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 information.
4.4. Marketing
4.4.1. You will only receive marketing communications from us if you have:
(a) provided your contact details when you made an enquiry with us regarding our Platform;
(b) registered to use our Platform; or
(c) provided your consent to receive marketing communications;
or where we are otherwise permitted to market to you in accordance with applicable law in respect of marketing communications, and in each case you will only receive marketing communications from us if you have not opted out of receiving marketing communications, unsubscribed from our mailing list or withdrawn your consent.
4.4.2. We will not share your personal data with third parties for their marketing purposes.
4.4.3. How to opt out - You can opt out of email marketing by following the process described within the particular marketing email. You can also withdraw your consent to receive marketing communications and ask to be removed from our mailing list at any time by contacting us.
4.4.4. Even if you opt out of receiving marketing communications, we may still use your personal data for other purposes provided we have a lawful basis to do so.
4.5. Change of purpose - We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or we have a lawful basis to change the purpose.
4.6. 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 use your personal data in this manner.
4.7. We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
We may share your personal data with the third parties set out in Part 4 of the Schedule. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6.1. To deliver our services, we use carefully selected third-party service providers. Wherever possible, we choose providers that process personal data within the UK or European Economic Area (EEA).
6.2. Some of our Sub-Processors conduct certain processing operations outside the UK/EEA (for example, in the United States). In these cases, we rely on recognised safeguards such as the EU–US Data Privacy Framework and/or the European Commission's Standard Contractual Clauses (SCCs) to ensure your personal data remains protected.
7.1. We operate appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal data is restricted to individuals who have a business need to know it, are under confidentiality obligations and can only process it on our instructions.
7.2. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8.1. We will retain your personal data only for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
8.2. We may update our data retention practices from time to time and you can request details by contacting us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after the end of the tax year in which they cease being customers, for tax purposes.
8.3. We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
9.1. Your legal rights in relation to your personal data are set out in full in Part 3 of the Schedule. If you wish to exercise any of your rights, please contact us.
9.2. You will not have to pay a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive. In which case, we may charge a reasonable fee for this information or refuse to comply with your request.
9.3. We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
9.4. We aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests it may take us longer to respond. In this case, we will notify you and keep you updated.
This Privacy Notice was last updated on 25.6.26.
If you have any questions, please email support@ethicsinpractice.app.
| Identity data | First name, last name, username or similar identifier. Business or trading name and location (including territory in which the business is based, which may be personal data in respect of a sole trader). |
| Contact data | Email address, telephone number, and billing address (where provided). |
| Profile and login data | Username, password and login credentials for your account on our Platform. |
| Marketing and communication data | Your preferences in receiving marketing from us. |
| Technical data | 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 the devices you use to access our Platform and Site. |
| Professional membership data | Professional body memberships and accreditation details, membership numbers, links to online profiles, registers and/or certificates, and renewal dates. |
| Supervision data | Name and contact details of supervisor(s) and/or peer supervisees; details of supervision arrangements. |
| CPD data | Details of continuing professional development activities, dates, and providers. |
| Insurance data | Professional indemnity and other insurance details, including insurer name, policy reference and/or certification. |
| Practice administration data | Details relating to contracts and agreements, record keeping arrangements, data protection compliance arrangements, clinical will arrangements, and self-care/ fitness-to-practise arrangements. |
| Ethical standards data | Self-assessment responses and related notes in respect of professional and ethical conduct. |
The lawful basis upon which we may rely on to process your personal data are:
| Consent | You have given your express consent for us to process your personal data for a specific purpose. |
| Contract | The processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you. |
| Legal obligation | The processing is necessary for us to comply with legal or regulatory obligations. |
| Legitimate interests | The processing is necessary for our or a third party's legitimate interest and your fundamental rights do not override those interests. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest. |
Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To register an account for you to access and use our Platform. | Contact and identity. | To perform our contract with you. |
| To process and deliver our Platform to you, | Contact, identity, communications, professional membership, Supervision, CPD, insurance, practice administration, ethical standards | To perform our contract with you. |
| To manage our relationship with you and notify you of changes to our Terms or Privacy Notice. | Identity, contact, profile, marketing and communications. | (i) to perform our contract with you; (ii) as necessary to comply with a legal obligation; and (iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our Site and our Platform. |
| To administer and protect our business and in particular our Site and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Identity, contact and technical. | (i) as necessary for our legitimate interests in 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; and (ii) as necessary to comply with any legal obligations. |
| To deliver relevant content/advertisements to you and measure or understand the effectiveness of our advertising. | Identity, contact, profile, usage, marketing and communications and technical. | As necessary for our legitimate interests in studying how customers use our Site and our Platform, to develop them, to grow our business and to inform our marketing strategy. |
| To use data analytics to improve our Site and our Platform, marketing, customer relationships and experiences. | Technical and usage. | As necessary for our legitimate interests to define types of customers for our Site and our Platform, to keep them updated and relevant, to develop our business and to inform our marketing strategy. |
| Access your data | You can ask for access to and a copy of your personal data and can check we are lawfully processing it. |
| Correction | You can ask us to correct any incomplete or inaccurate personal data we hold about you. |
| Erasure | You can ask us to delete or remove your personal data where: |
| (a) there is no good reason for us continuing to process it; | |
| (b) you have successfully exercised your right to object (see below); | |
| (c) we may have processed your information unlawfully; or | |
| (d) we are required to erase your personal data to comply with local law. | |
| We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request. | |
| Object | You can object to the processing of your personal data where: |
| (a) we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms; | |
| (b) 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 and in such circumstances, we can continue to process your personal data for such purposes. | |
| Restrict processing | You can ask us to suspend or restrict the processing of your personal data, if: |
| (a) you want us to establish the accuracy of your personal data; | |
| (b) our use of your personal data is unlawful, but you do not want us to erase it; | |
| (c) you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or | |
| (d) you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it. | |
| Request a transfer | You can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contract with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format. |
| Withdraw your consent | You can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent. |
| Service providers | Acting as processors who provide IT and system administration services. For further information in respect of the Service Providers we use, please see Schedule 2 of our Data Processing Agreement. |
| Professional advisors | Acting as processors or controllers including, lawyers, bankers, auditors, insurers and accountants who provide consultancy, banking, legal, insurance and accounting services. |
| HM Revenue & Customs, regulators and other authorities | Acting as processors or controllers who require reporting of processing activities in certain circumstances. |
| Other third parties | Such third parties whom we may choose to sell, 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 Notice. |
| Aggregated data | Information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject. |
| Controller | A body that determines the purposes and means of processing personal data. |
| Data subject | An individual living person identified by personal data. |
| ICO | Information Commissioner's Office, the UK supervisory authority for data protection issues. |
| Personal data | Information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data. |
| Processor | A body that is responsible for processing personal data on behalf of a controller. |