Sella Holding Ltd (the "Company", "we", "us" or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses our mental health and wellbeing platform (the "Platform").
Our Platform is intended to provide users with an accessible and supportive conversational experience designed to encourage self-reflection, emotional awareness and wellbeing support (collectively, the "Services").
Your privacy is important to us and this Data Privacy Notice (the "Privacy Notice") explains what personal data the Company collects and how it uses, discloses, or otherwise processes personal data of individuals who visit the Platform (the "data subjects", "you" or "your").
We therefore encourage you to read this Privacy Notice carefully to understand how we collect, use and protect your personal data. By accessing or using our Platform, you acknowledge and agree to the processing of your personal data as described herein.
LOUMNA is an AI-powered conversational wellbeing tool designed to provide general emotional support and self-reflection assistance. It is not a substitute for professional medical, psychological, psychiatric or therapeutic advice, diagnosis or treatment.
This Privacy Notice explains our approach to the collection, use, disclosure, storage and other processing of your personal data when you access or use our Platform or otherwise interact with us.
It describes the categories of personal data that we collect, the purposes for which we process such data, the legal bases upon which we rely, the circumstances in which your personal data may be shared with third parties and the safeguards that we implement to protect your information.
This Privacy Notice also explains your rights under the applicable data protection laws, including your rights to access, correct, erase, restrict or object to the processing of your personal data and, where applicable, your right to data portability and to withdraw your consent.
This Privacy Notice applies solely to personal data processed by the Company in connection with the Platform and the Services. It does not apply to personal data processed independently by third parties, including mental health professionals or other healthcare providers who may provide services through or be accessible via the Platform. Such persons or organisations remain responsible for their own processing activities and should provide you with their own privacy notices where required by law.
We may collect and process your personal data when you access or use the Platform, create an account, interact with our AI-powered conversational system, communicate with us, subscribe to our publications, or otherwise engage with our Services.
In particular, we may process information you voluntarily provide through your interactions with the AI-powered conversational system, including your questions, concerns, thoughts, experiences, emotions, reflections and other information shared during conversations. Such information is processed to enable the Platform to analyse your inputs and generate personalised conversational responses, reflections and wellbeing support adapted to the context of your interaction.
We only collect and process personal data that is necessary for the provision, operation, security and improvement of the Services, in accordance with this Privacy Notice and applicable data protection laws.
The personal data we may collect includes:
We may also collect sensitive personal data also known as "Special Categories of Personal Data" about you in accordance with the Data Protection Act 2017 (the "DPA") and where applicable, the European Union General Data Protection Regulation (the "GDPR") (the "DPA" and the "GDPR" being collectively referred to as the "applicable data protection laws"). The sensitive personal data we process may include information relating to your physical or mental health, wellbeing, medical history, counselling history, assessment responses or other health-related information voluntarily provided by you.
Any information you submit on the Platform must be true, complete and not misleading. Providing inaccurate, incomplete or misleading information may result in the rejection of your request.
Where you provide us with personal data relating to another individual, you represent and warrant that you have obtained all necessary authorisations or consents required by law to disclose such information to us and for us to process it in accordance with this Privacy Notice.
Our processing of personal data is justified by a "legal basis", that is, a specific condition. We may use personal data for the following purposes, in each case as justified by a legal basis:
We use your personal data to provide and facilitate access to our Services, including but not limited to:
Our Platform also uses AI, algorithms and automated technologies to provide personalised mental health and wellbeing information, resources and guidance based on the information you provide and your interactions with the Platform. The AI system does not make decisions affecting your legal rights or other significant interests.
Our processing of your personal data is justified under the following legal bases:
In some cases, we are required to process personal data to comply with legal obligations and regulatory requirements.
We may use your personal data to communicate with you about our Platform, services and relevant updates, including but not limited to:
As required by law, we will rely on your consent as the legal basis before sending you direct marketing communications.
We ensure that our processing respects your rights and freedoms, and you have the possibility to opt-out of receiving marketing communications from us at any time, free of charge, by following the unsubscribe instructions contained in each of our marketing communications to you or by contacting us in accordance with the section "Contact Us" below.
If you have subscribed to receive marketing communications, your personal data we use for marketing purposes will thus be kept with us until you unsubscribe or notify us that you no longer wish to receive our marketing offers or emails and request to destroy your personal information.
We may use your personal data to comply with legal, regulatory and other obligations, including but not limited to:
This processing is necessary for our compliance with our legal obligations and to fulfill regulatory requirements.
We may share your personal data with third parties in the following circumstances:
Sub-contractor data processors: we may engage subcontractors to process data on our behalf and upon our instructions such as, IT systems or software providers (including cloud storage and data security services), email, newsletter and communication service providers, IT support and maintenance service providers, data processing and analytics service providers, confidential waste disposal and secure document storage providers.
Before engaging any sub-contractor, we conduct an appropriate level of due diligence and put in place contractual safeguards to ensure that they process personal data according to our legal obligations. We ensure that they have in place all the security and organizational measures to protect your data and that they will process your data in accordance with our instructions.
External data controllers and professional advisers: we may share personal data with third-party data controllers where necessary to facilitate the provision of Services including professional advisers, auditors and/or legal counsel. When doing so, we comply with our legal and regulatory obligations and ensure that appropriate safeguards, such as contractual agreements or data transfer mechanisms, are in place to protect your data.
Depending on the technical architecture of the Platform, certain personal data may be processed by third-party AI technology providers acting as processors on our behalf. Such providers are contractually required to process personal data only in accordance with our instructions and appropriate safeguards.
Other third parties required by law: we may also share personal data with other third parties, including governmental and/or regulatory authorities where required by applicable laws. We also limit the data shared to what is strictly required for the specified purpose.
We may share your personal data without first obtaining your consent as follows:
In order to provide the Services effectively, we may need to transfer your personal data to locations outside Mauritius. This may occur when we engage third-party service providers based overseas to perform certain functions on our behalf, such as data hosting, cloud storage or analytics services and AI technology providers located outside Mauritius.
When personal data is transferred outside of Mauritius, we implement appropriate safeguards to ensure your data remains protected in accordance with applicable data protection laws, including contractual protections as well as technical and organizational measures.
We only retain your personal data for as long as necessary to fulfil the purposes for which they were collected, including for the purposes of satisfying any legal, accounting and/or reporting requirements.
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 as well as the applicable legal requirements.
The legal prescription period in Mauritius (i.e., the period during which one party may sue another party or be sued after the happening of an event) is ten (10) years for non-immovable-property-related matters ("actions personnelles"). Depending on the nature of our relationship with you, we may, in this context, also choose to keep your personal data after our last transaction with you, for at least the legal prescription period in order to be able to defend or enforce our rights or for such number of years according to the applicable data protection laws.
Please contact our Data Protection Officer for further details on retention periods for different aspects of your personal data.
We are committed to keeping personal data secure and we have implemented and maintain appropriate technical, administrative, physical and procedural security measures consistent with local and international information practices designed to protect the personal data that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.
Additionally, all of our partners, employees, consultants, workers and data processors (i.e., those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of such personal data.
However, no transmission over the Internet is completely secure or error-free, and we cannot guarantee that our Platform will function without fault, bugs and/or without any interruptions. The information security policies, rules and technical measures utilized and maintained by us may also be subject to compromise due to factors outside our control.
We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception or manipulation of electronic communications by third parties or by computer programs used for electronic communications and transmission of viruses.
The Platform is intended for individuals aged 16 years or older. We do not knowingly provide the Services to individuals below this age, except where required under applicable data protection laws.
If you are under the age of 16, you may use our Platform and Services only with the written consent of your parent or guardian. In such cases, the parental or guardian consent must be sent to contact@loumna.com before creating a profile and submitting any personal information. The decision to accept or approve the creation of a profile remains at the sole discretion of the Company.
When using our Platform, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly.
For more information about the cookies we use, please consult our Cookie Policy at loumna.com/cookies.
The Platform may contain links to other websites, apps, content, plug-ins, services or resources on the internet which are operated by third parties.
If you access other websites, apps, content, services or resources using the links provided, please be aware they may have their own privacy policy, and we do not accept any responsibility or liability for these policies or for any personal data which may be collected and shared through these sites. Please review these policies before you submit any personal data to these sites.
Under applicable data protection laws, you have the following rights, subject to exceptions, in relation to the personal data we hold about you, which you may exercise by writing to us as set out below under "Contact Us":
Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, you can report it to the Data Protection Office of Mauritius or any other supervisory authority. The supervisory authority in Mauritius is the Data Protection Commissioner who may be contacted at:
The Data Protection Office
Fifth floor, SICOM Tower Wall Street
Ebène, Mauritius
Phone: +230 460 0251
Email: dpo@govmu.org
We would appreciate the chance to deal with your concerns in the first instance before you approach the Data Protection Commissioner or the relevant supervisory authority.
The Company reserves the right to amend and update this Privacy Notice as necessary to ensure that it reflects current best practice, official guidance and applicable current legislation.
Any changes to this Privacy Notice will be posted on our Platform so that you are always informed of the way we collect and use your personal data, and we encourage you to review this Privacy Notice whenever you access our Platform or otherwise interact with us to stay informed about our practices and the ways you can help protect your privacy.
If you have any questions about this Privacy Notice, please contact:
The Data Protection Officer
Email: contact@loumna.com