Privacy Policy

Who is responsible for your information

JemSpace is operated by Jemma Dennis Ltd, a company registered in England and Wales (company number 14929839) whose registered office is at 85 Wimpole Street, London, England W1G 9RJ. Jemma Dennis, a psychotherapist registered with the British Association for Counselling and Psychotherapy (BACP), is director of the company. Jemma Dennis Ltd is registered with the Information Commissioner’s Office under registration reference ZB718750, and is the data controller for JemSpace, which means it decides what information is collected and why. This policy applies to the JemSpace website at www.jemspace.co.uk.

You can contact her about anything on this page at jemma@jemmadennis.com.

Which plan you are on

JemSpace is offered on more than one plan, and some of what follows depends on which kind of plan you are on.

Clinical plans are free and are offered only to people who are already in therapy with Jemma. They sit alongside that therapy.

Subscriber plans are paid and are open to the general public. They are journalling services. They are not therapy, and using one does not make you Jemma’s therapy client.

Where something below applies only to one kind of plan, it says so. Everything else applies to both.

What we collect

• Your name and email address, so you can sign in and be contacted.
• Your journal entries. These are likely to include information about your health and state of mind, which UK GDPR treats as special category data and protects more strictly.
• A record of your consent, including which boxes you ticked, the exact wording you agreed to, and the date, time and IP address of the request. This exists so we can show what you were asked and what you agreed.
• Your display preferences, meaning the font and colour you chose for your own journal.
• A log of every time Jemma opens your entries. This protects you, not us: it means access can be accounted for.

What we collect depends on how you came to JemSpace.

If you are on a clinical plan, Jemma already holds your personal details through your therapy agreement with her, so JemSpace does not ask you for them again. The list above is everything JemSpace itself collects from you.

Your therapy agreement covers your therapy. It does not cover JemSpace. What you write here is a separate record, and it is this policy that governs it.

If you are on a subscriber plan, we also collect the following when you sign up: your date of birth, which is used to confirm that you are 18 or over and is never displayed to anyone, including Jemma; the age range you select; your gender identity; and whether you are currently in therapy or have been in the past. The last three help Jemma understand who is using the service. None of your answers affect whether you can sign up.

The age range, identity and therapy questions are optional. You can skip any of them or choose “prefer not to say”, and your answers make no difference to whether you can sign up.

Payments are handled by our payment provider. JemSpace never sees or stores your card details. We keep a record of your subscription status and of any one-off purchases, so that your account knows what it has access to.

We do not use analytics, advertising, or tracking of any kind, we do not profile you, and we make no automated decisions about you. Fonts are served from our own servers rather than fetched from Google. Apart from the payment provider’s checkout, which you reach only if you choose to subscribe, the pages you use carry no third-party scripts.

JemSpace is intended for use by adults aged 18 and over.

Why we are allowed to hold it

For your account and the running of the service, our basis is performance of our agreement with you.

Your journal entries are likely to contain information about your health and your state of mind. The law calls this special category information and requires a further condition for holding it. Which condition applies depends on your plan.

On a clinical plan, we rely on the condition permitting processing necessary for the provision of health or social care by a professional who owes a duty of confidence. Jemma is a BACP-registered psychotherapist and owes you that duty.

On a subscriber plan, we rely on your explicit consent, given at sign-up. We do not rely on the health and social care condition for those plans, because they are not therapy and Jemma is not acting as your therapist.

Where we rely on your consent, you can withdraw it at any time in your account settings or by emailing Jemma. Withdrawing it does not undo processing that has already happened, and, as explained under “How long we keep it” below, some entries may still be retained for a period after withdrawal.

Who can see your entries

Jemma, and nobody else. Not other clients, and no other staff, because there are none.

To be precise about what that means: on clinical plans and on any plan where Jemma writes back to you, she reads your entries, because that is the point of those plans. On plans where she does not write back, your entries are not read. Her administrator account is technically able to open any entry, which is how she reaches the entries she does read, so we do not claim that yours cannot be opened. We say instead that they are not read, and the access log records every occasion on which any entry is opened.

This is enforced by the database itself, not merely by the app. Each person can only ever retrieve their own rows, so a fault on the website cannot expose one client’s journal to another. Jemma’s own account requires a second factor as well as a password.

Confidentiality has narrow limits. In exceptional circumstances Jemma may be required by law, or permitted by her professional obligations, to share information, for example where there is a serious and imminent risk of harm to you or to someone else. Her therapy agreement sets out how she handles that.

Where your information is held

Your entries are stored in a database in London, encrypted at rest, and encrypted in transit whenever they travel.

Some parts of the service may be delivered from servers outside the UK, which means your entries may pass through another country at the moment they are displayed to you, even though they are stored in the UK. Where that happens, the transfer is covered by our supplier’s data processing agreement, which incorporates the safeguards approved by the UK government for transfers of this kind.

Who else is involved

• Our hosting provider stores the database, in London.
• Our website provider runs the website.
• Our email provider sends emails, such as confirming your address or resetting your password. Emails never contain your journal entries.
• Our payment provider takes payments on the paid plans and receives your card details directly.

Each supplier acts only on our instructions under a written data processing agreement, and none of them may use your information for its own purposes. If you would like to know who they are at any time, ask us and we will tell you. Your information is never sold, never used for advertising, and never shared with anyone else.

How long we keep it

How long we keep your information depends on which kind of plan you are on, because the reasons for keeping it are different.

Clinical plans. Your entries form part of the record of your therapy and are kept for a minimum of 7 years after your last contact with Jemma. This is a condition of Jemma’s professional indemnity insurance and reflects the standard expected of therapists keeping clinical records. Because it is a professional obligation we cannot delete your entries before that period has run, even if you ask. If you ask us to close your account within it, we will stop using your entries, end your access, and move them into a restricted archive that only Jemma can reach until the period ends and they are deleted.

Subscriber plans. Your entries are not clinical records and no insurance condition applies to them. You can ask us to delete them at any time and we will. If you cancel, you keep access for 90 days so that you can read and export what you have written, and at the end of that period your entries and account are deleted.

Removing an entry is not the same as deleting it. If you remove an entry, it disappears from your journal and you will no longer see it. On subscriber plans a removed entry is permanently deleted after 30 days, so you have a short window in which to change your mind. On clinical plans it is not erased: the entry is retained, stays visible to Jemma and is marked as removed. Jemma can put it back if you ask her to.

When an account is deleted, your entries, account details, consent records, access log and display preferences are removed from the live database immediately. Copies may remain in our encrypted backups for a short period afterwards, in line with our backup cycle, before being overwritten. We do not restore deleted accounts from backups.

We keep one thing: a dated note that a deletion took place, containing nothing you wrote. Without it there would be no way to show a request had been honoured.

Your rights

You can ask us to:

• Give you a copy of everything we hold about you
• Correct anything that is wrong
• Delete your account and your entries. On subscriber plans we will do this on request; on clinical plans this is subject to the retention period described above
• Stop processing your information, or restrict how we use it
• Provide your data to you, or transfer it, in a portable format
• Withdraw your consent, where we are relying on it, at any time

You can start a deletion yourself in your settings. For anything else, email Jemma. We will respond within one month and will not charge you. If a request is unusually complex we may need up to a further two months, and will tell you within the first month if so.

If you are unhappy with how your information has been handled you can complain to the Information Commissioner’s Office at ico.org.uk, though we would rather you told us first so we can put it right.

Cookies and local storage

JemSpace keeps you signed in using a single browser cookie. When you sign in, our authentication provider sets a first-party cookie on your device containing a session token. The site reads that token as you move between pages, so that you do not have to sign in again on each one. The cookie can be read only by JemSpace, and it contains no part of your journal.

That cookie is strictly necessary for the service to work. Without it there is no way to keep you signed in, and the site could not tell your journal from anyone else’s. Strictly necessary cookies are exempt from the consent requirement under regulation 6(4) of the Privacy and Electronic Communications (EC Directive) Regulations 2003, which is why JemSpace does not show a cookie banner.

The session token expires after one hour and is renewed automatically for as long as you stay signed in. Signing out clears the cookie.

We set no analytics cookies, no advertising cookies, and nothing that follows you to other websites. JemSpace does not use local storage, session storage, or any other means of keeping information on your device.

If you subscribe to a paid plan, our payment provider sets its own cookies on its checkout page in order to take the payment and to guard against fraud. Those cookies are set by the provider rather than by us and are covered by the privacy information it shows you at the point of payment.

Reviews and testimonials

If you leave a review or send us feedback, we may quote it on the JemSpace website or on social media. We will never publish your name, your age, your gender identity, anything about whether you are or have been in therapy, or anything you have written in your journal.

If something goes wrong

If there is a breach of security affecting your information, we will assess it without undue delay. Where the law requires it, we will report the breach to the Information Commissioner’s Office within 72 hours of becoming aware of it. If the breach is likely to result in a high risk to you, we will tell you without undue delay and tell you what you can do about it.

Changes to this policy

If this policy changes, we will update it here and change the date at the top. If a change is significant, we will also tell you directly.