Last Updated: December 2025
What is this document?
Privacy policies can be dense and difficult to understand. We've designed this document to be clear and accessible, so you can quickly find the information you need about how we handle your personal data.
If you have any questions while reading, don't hesitate to reach out to us at hello@fettle.ie.
About Fettle & This Policy
Kerwex Human Resources Limited, trading as Fettle, provides mental healthcare services for employers and individuals who want to make a real impact on their lives and their organisation's performance.
Combining a curated team of highly-qualified mental health professionals, personalised therapist matching by real humans, dedicated training & support for managers, and a hassle-free digital experience, Fettle is Ireland's & Europe's first mental healthcare solution that truly covers a broad spectrum of employee and individual mental health needs.
What's This Policy About?
We want to be completely transparent about how we collect and use your personal data. This privacy notice exists to tell you exactly how we do this.
Personal data is anything that could identify an individual, either on its own or combined with other factors that could lead to identifying an individual.
Any time we make a decision on processing personal data, we do it according to this notice—in data protection law terms, this means we're acting as a Data Controller.
Our privacy policy covers the entire journey of the personal data we process when you use our services—from the moment it enters our system, until it's time for us to say goodbye, as well as the various stops it makes along the way.
Data We Collect
We collect different types of data depending on how you interact with our services. Here's a breakdown of what we collect:
When you sign up for therapy sessions with Fettle, we collect basic information such as your name, email address, phone number, and contact details so that we can set up your sessions and communicate with you.
Legal basis: Article 6(1)(f) of the GDPR - Legitimate Interests
During therapy, we keep notes on information you share about your mental health, your reasons for booking therapy, and your history with therapy. Only our mental health professionals can view these notes.
We only keep information that you willingly share with our therapists and that is relevant to your therapy.
Legal basis: Article 9(2)(a) of the GDPR - Explicit Consent
After therapy sessions, we keep anonymous records of attendance, usage details, and clinical outcomes to help improve our service. For companies partnering with us, this data helps track Fettle's effectiveness.
Legal basis: Article 6(1)(f) of the GDPR - Legitimate Interests
When you place an order on our website, your payment is processed by Stripe, a third-party payment processor. Stripe collects, uses, and processes your payment information in accordance with their privacy policies.
You can access Stripe's privacy policy at: stripe.com/ie/privacy
For companies partnering with us, we collect regular feedback and usage data to better understand what your company needs from Fettle and to tailor our service accordingly.
We sometimes ask benefits managers or relevant points of contact for feedback via online surveys to find out how we can improve Fettle.
Legal basis: Article 6(1)(f) of the GDPR - Legitimate Interests
How We Use Your Data
We use your personal data for the following purposes:
- Providing therapy services: Setting up and managing your therapy sessions, matching you with appropriate therapists, and facilitating communication between you and your therapist
- Improving our services: Analysing usage patterns and feedback to enhance the quality of our platform and therapy offerings
- Communication: Sending appointment reminders, service updates, and responding to your inquiries
- Corporate reporting: For business clients, providing anonymous, aggregated data on service effectiveness (never attributable to individuals)
- Legal compliance: Meeting our obligations under applicable laws and regulations
Important: When we share data with your employer or organisation, it is always in an anonymous, aggregated form and will never be attributable to you personally.
Data Storage & Security
Where We Store Your Data
We use trusted, GDPR-compliant service providers to store and process your data:
| Service | Purpose | Data Location |
|---|---|---|
| Victa | Therapist session notes | Amazon Web Services (GDPR-ready, with Standard Contractual Clauses for US transfers) |
| Acuity | Booking management | Standard Contractual Clauses for US data transfers |
| Zoom | Online therapy sessions | Standard Contractual Clauses for US data transfers |
| Stripe | Payment processing | Stripe Payments Europe (Ireland) with transfers to Stripe, Inc. (US) |
| Google Applications | Company information storage | US (EU Commission Standard Contractual Clauses) |
| Typeform | Feedback surveys | Spain |
Our Security Measures
All Fettle employees adhere to strong security measures internally:
- We enable 2-factor authentication for all tools we use, or SSO with Google. This is strict company policy.
- Every single employee uses a password manager with a unique and strong password
- All our laptops are encrypted
- Company policy is to immediately install any OS software updates
- We tightly control who can access each tool we use, with a procedure to only provide access to tools if it's 100% necessary
Cookies & Tracking
Cookies are small files which are placed on your computer when you visit a website and are saved in your browser's history. They allow the website to recognise your device and store some information about your preferences or past actions.
Types of Cookies We Use
When you use our website, there are two types of cookies that can be set:
- First-party cookies: Placed and read by Fettle directly while you are using our website
- Third-party cookies: Set by third parties such as Google Analytics and Hotjar Analytics
Cookie Categories
These cookies are essential to the operation of our website. Without them, certain features may not work properly. These cannot be disabled.
These cookies generate anonymous statistics on how visitors use our website and can improve the browsing experience, for example by pre-filling information that has already been filled in.
These cookies will direct you to Fettle ads on other sites you visit and track your engagement with those ads. Our advertising service providers may also collect non-identifiable information about your visits to our site.
You can choose not to store non-necessary cookies on your computer when you visit our website, or you can adjust your browser settings to prevent cookies from being saved on your computer.
Your Rights
Your personal data is yours, and your rights in relation to it (granted by the Data Protection Commissioner) include:
You have the right to be informed about the collection and use of your personal data, why it's being processed, how long it'll be stored for, and who it'll be shared with.
You have the right to ask us for copies of the data we store about you.
You have the right to ask us to rectify personal information you think is inaccurate, or to complete information you think is incomplete.
You have the right to ask us to erase your personal information in some circumstances.
You have the right to ask us to restrict processing your personal information for a duration of time, in some circumstances.
You have the right to ask us to transfer your personal information to another organisation, or to someone else, in some circumstances.
Exercising Your Rights: You don't have to pay anything to exercise your rights. If you wish to make a request about your personal data, contact us at hello@fettle.ie or call +353 (0)1 912 0367. We'll respond to you within 1 month.
Data Retention
We only keep your personal data for as long as is necessary in order to use it as described above for business or legal purposes. We will also retain your personal data as long as necessary to deal with your queries and for as long as you might legally bring claims against us.
Counselling Records
All counselling records will be maintained as required by the applicable legal and ethical standards according to the various counselling and psychotherapy professions licensing boards (e.g. The Irish Association of Counselling and Psychotherapy), of the country in which the therapist resides.
Important: Recording of sessions is prohibited. We take all necessary steps to ensure that data privacy is maintained for the period of retention.
Contact Us
If you have any questions about this Privacy Policy or how we handle your data, please get in touch:
Not satisfied? If you have any concerns about our use of your personal information, let us know by writing to us at hello@fettle.ie. If you're not satisfied with our response, or you're unhappy with how we have used your data, you can complain to the Data Protection Commissioner. The DPC contact details are available at dataprotection.ie.