1. Who is the Data Controller? 

KTYOU, S.L. is the data controller of your personal data for the purpose of providing you with the services identified in this privacy policy, specifically for the creation of  profile and for the management of your contacts directly with u 

KTYOU, S.L., is a company domiciled at Vega Street, 12, E1, 2A, Alcobendas, Madrid, Spain, and its VAT number is B56453087 (“HealMind“).

At HealMind we are committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights under the General Data Protection Regulation (“GDPR“). 

For the processing operations related to the therapy service, including the processing of your health data, the Therapist will be the Data Controller. For more information on how the Therapist treats your personal data, you should contact him/her directly. 

2. What information do we process? 

a) The data you provide us directly:
We collect your personal data when you request information through our contact forms. The address field of name and surname in the forms will be mandatory, so that i omission results in the impossibility of providing you with the requested services. We also collect your data when you create your profile in our tool for therapy service related to your identification names, contact, and simple data such as date of birth a marital status. The impersonation of identity or the provision of third party data is prohibited. 

When you contact us through these channels, we will request your identification dat contact data, geolocation, personal and activity characteristics, as well as data related to your health status. 

So that the information provided is always updated and does not contain errors, you must inform HealMind, as soon as possible,

of any changes to your personal data that may occur. 

Likewise, by clicking on the “I accept” button (or equivalent) incorporated in the aforementioned forms, you declare that the information and data you have provided in them are accurate and truthful. 

When you enjoy, as an adult or minor patient, the benefits of our website in relation  the services provided within the platform at therapy level, HealMind will process your personal identification data (such as name and surname), contact data (such as email mental health data, and other data such as activity and fitness, sleep management a stress management, to enable therapy-related services. HealMind will process this data in its capacity as Data Processor, on behalf of and following the instructions of the therapists, who will act as Data Controllers. This data will be provided directly by you in our tool (e.g. in your diary), or through the sessions held with the therapists. For more

information on how the therapist processes your personal data, you should contact him/her directly. 

b) Data obtained indirectly:
When you browse, different cookies and other tracking devices may be installed on your device, as explained in our Cookies Policy . 

3. What is the origin of the data?

We consider that all data processed by HealMind has been freely provided by you. 

In the event that the personal data provided belong to a third party, you guarantee that you have informed them of this Privacy Policy and have obtained their authorization to provide the data to HealMind for the purposes indicated above. Likewise, you guarantee that the data provided are accurate and up to date, and you are responsible for any damage or harm, direct or indirect, that may be caused as a result of a breach of this obligation. 

4. For what purpose and on what legitimate basis do we process the data?

HealMind acts as the controller of personal data for the following purposes and in accordance with the following legitimate bases: 

• Based on HealMind’s compliance with legal obligations:

1. a) Allow users to exercise their rights.
2. b) Comply with the regulations applicable to HealMind.

• Based on the existence of a legitimate interest on the part of HealMind:

1. a) To respond to your request for information about HealMind’s products and services. 
2. b) To carry out periodic reviews to improve the quality of the service we provide. 

However, if you do not want your data to be processed for these purposes, you can object at any time by contacting us at catalina.ayuso@healmind.care, as indicated in the Exercise of Your Rights section of this Privacy Policy. 

Regarding the use of our tool, we clarify that the data will be processed by HealMind in the position of Data Processor, for the purposes of allowing and managing a space for interaction, exchange of information and personal data between therapist and patient

and information management, as well as offering functionalities to improve the experience of both during the therapy services within the platform. 

The goal of the tool is to make viable a space to perform therapy sections and, thus, have as a benefit to promote the welfare of users acting as a communication chann between users and professionals. The tool is aimed at adults and children, always accompanied by a therapist. To learn more about the conditions and disclaimers, please refer to the Terms and Conditions of Use. 

5. To whom is your data transfer? 

All transfers of personal data that we make are necessary for the fulfillment of t stated purposes, or are made to comply with a legal obligation: 

1. a) To the public administrations and the administration of justice, and to the security forces in compliance with the legal obligations that apply to us. b) Companies providing IT services, tools or IT infrastructure on which the services HealMind provides are based, such as hosting providers, CRMs, emailing service companies, etc.
2. c) To your therapist, including your personal health data, to support in the therapy sections and to allow the use in our tool. 

In this regard, we inform you that any transfer that takes place will be made taking into account all the necessary legal safeguards. We also guarantee that we sign specif contracts with all our service providers in accordance with the regulations. 

Similarly, HealMind guarantees that in the case of providers located in countries outside the European Union or other countries not considered adequate in accordance with data protection regulations, the necessary precautions are taken to ensure that the data can be transferred securely, either because the supplier offers adequate guarantees, through, among others, the signing of Standard Contractual Clauses of the European Commission, or because any of the exceptions set out in the regulations are complied with. 

6. Exercise of your rights. 

We inform you that you may exercise the following rights: 

1. Right of access to your personal data to know which are being processed and the processing operations carried out with them.
2. Right to rectify any inaccurate personal data.
3. The right to have your personal data deleted, when possible.
4. The right to request the limitation of the processing of your personal data when the accuracy, lawfulness or necessity of the data processing is in doubt, in which case, we may retain the data for the exercise or defense of claims.
5. Right to object to automated decision making, including profilin
6. Right to object to the processing of your personal data when the legal basis that enables us to process it, in accordance with paragraph 4 above, is legitimate interest.
7. Right to the portability of your data, when the legal basis that enables us to process it of those indicated in paragraph 4 above is the existence of a contractual relationship or your consent.
8. Right to revoke consent given to HealMind.

You may exercise your rights at any time and free of charge in the following ways: 

1. By sending an email to catalina.ayuso@healmind.care using the email address you used to register for our services and indicating the right you wish to exercise. 
2. By sending a written request to the address Vega Street, 12, E1, 2A, Alcobendas, Madrid, Spain, indicating the right you wish to exercise. 3. In addition, when you receive any communication from us, by clicking on the unsubscribe section that will contain that communication, you will be able to unsubscribe from all previously accepted commercial communications.

When you exercise your rights, and only if we have doubts about your identity, we may ask you for additional information to verify your identity. 

We also inform you that you have the right to file a complaint with the Spanish Da Protection Agency if you consider that we have committed a breach of data protection legislation with respect to the processing of your personal data. 

We inform you that, during the use of our tool with the therapist, you will be able to self-manage the deletion of your personal data, in any way and free of charge, through two different ways:

– On the one hand from the app by selecting “My account”, entering “Password and security”, clicking on “Delete my account”. 

– On the other hand by entering the Healmind website: https://healmind.care/, clicking on the contact button and filling out the form available to request t deletion of personal and account data. 

We also inform you that you can join the Robinson List at www.listarobinson.es: the advertising exclusion system managed by the Spanish Digital Economy Association (ADIGITAL), in which you can register in order to show your opposition to the use of your data for the purpose of sending you commercial communications. 

7. Time period for the conservation of your data. 

We will only keep your data for as long as it is necessary to provide you with these services. Any of the data you provide through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available in case there is a legal obligation (derived from a request from the State Security Forces or Courts and Tribunals) as well as when you exercise your rights. 

8. Security and confidentialit 

In order to prevent unauthorized access to or unauthorized disclosure of personal data, we have taken appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you. For example, modern cryptographic measures and access restrictions are adopted. In this way, a secure procedure for processing users’ personal data is guaranteed. 

9. Minors. 

Minors under 18 years of age may not use the services available through our website without the prior authorization of their parents, guardians or legal representatives, who shall be solely responsible for all acts performed through the site by minors in their care, including the completion of the forms with the personal data of such minors and the marking, where appropriate, of the boxes that accompany them. In this sense, and to the extent that HealMind has no ability to control whether or not users are minors, parents and guardians must be those who enable the necessary mechanisms to prevent them from accessing the website and / or provide personal data without their supervision, not admitting HealMind any responsibility in this regard. 

10. Privacy policy update.

We make our best efforts to keep our privacy policy fully updated. If we make changes, they will be clearly identifiable in a clear and specific manner, as possible in relationship we have established with you (e.g., we may communicate changes to you by email). 

This privacy policy has been revised and posted as of 31 of 06 of 2025