1. Introduction

 

1.1    I am committed to safeguarding the privacy of my website visitors and service users; in this policy I explain how I will handle your personal data.

 

1.2    By using my website and agreeing to this policy, you consent to my use of cookies in accordance with the terms of this policy.

 

  1. Credit

 

2.1    This document was created using a template from SEQ Legal (http://www.seqlegal.com).

 

  1. How I use your personal data

 

3.1    In this Section 3 I have set out:

 

(a)    the general categories of personal data that I may process;

 

(b)    in the case of personal data that I did not obtain directly from you, the source and specific categories of that data;

 

(c)    the purposes for which I may process personal data; and

 

(d)    the legal bases of the processing.

 

3.2    I may process data about your use of my website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is my analytics tracking systems. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is legitimate interest, namely monitoring and improving my website and services.

 

3.3    I may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating my website, providing my services, ensuring the security of my website and services, maintaining back-ups of my databases and communicating with you. The legal basis for this processing is legitimate interest, namely the proper administration of my website and business OR the performance of a contract between you and I, and/or taking steps, at your request, to enter into such a contract.

 

3.4    I may process your information included in your personal profile on my website or social media sites (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of my website and services. The legal basis for this processing is legitimate interest, namely the proper administration of my website and business and the performance of a contract between you and I, and/or taking steps, at your request, to enter into such a contract.

 

3.5    I may process your personal data that are provided in the course of the use of my services (“service data”). The service data may include medical information, information and notes about you relating to any therapy sessions you attend, attendance records, information and notes about you relating to any courses you attend. The source of the service data is you. The service data may be processed for the purposes of providing my services, ensuring the security of my website and services, maintaining back-ups of my databases and communicating with you. The legal basis for this processing is legitimate interest, namely the proper administration of my website and business and the performance of a contract between you and I, and/or taking steps, at your request, to enter into such a contract.

 

3.6   I may process information that you post for publication on my website or through my services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering my website and services. The legal basis for this processing is legitimate interest, namely the proper administration of my website and business OR the performance of a contract between you and I, and/or taking steps, at your request, to enter into such a contract.

 

3.7   I may process information contained in any enquiry you submit to me regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.

 

3.8   I may process information relating to transactions, including purchases of goods and services that you enter into with me and/or through my website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and I, and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely my interest in the proper administration of my website and business.

 

3.9    I may process information that you provide to me for the purpose of subscribing to my email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and I, and/or taking steps, at your request, to enter into such a contract. You can unsubscribe from my direct marketing communications at any time.

 

3.10  I may process information contained in or relating to any communication that you send to me (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. My website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is legitimate interest, namely the proper administration of my website and business and communications with users.

 

3.11  I may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is legitimate interest, namely the protection and assertion of my legal rights, your legal rights and the legal rights of others.

 

3.12  In addition to the specific purposes for which I may process your personal data set out in this Section 3, I may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.

 

3.13  Please do not supply any other person’s personal data to me, unless I prompt you to do so.

 

  1. Providing your personal data to others

 

4.1   Under no circumstances do I reveal data that can identify a client to another person or organisation, with the only exception being when I am legally required to do so. I may disclose your personal data to my insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

 

4.2    In addition to the specific disclosures of personal data set out in this Section 4, I may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.

 

  1. Links to other websites

 

5.1     My website may contain links to other websites of interest. However, once you have used these links to leave my site, you should note that I do not have any control over that other website.

 

5.2     Therefore, I cannot be responsible for the protection and privacy of any information which you provide while visiting such sites, and such sites are not governed by this privacy statement.

 

5.3     You should exercise caution and look at the privacy statement applicable to the website in question.

 

  1. Retaining and deleting personal data

 

6.1    This Section 6 sets out my data retention policies and procedures, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.

 

6.2    Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

 

6.3    Contact information and Service Data will be retained indefinitely from the moment you consent to use my services.

 

6.4    Notwithstanding the other provisions of this Section 6, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.

 

  1. Amendments

 

7.1    I may update this policy from time to time by publishing a new version on my website.

 

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

 

  1. Your rights

 

8.1    You may instruct me to provide you with any personal information I hold about you; provision of such information will be subject to:

 

(a)    the payment of a fee (currently fixed at GBP 10); and

 

(b)    the supply of appropriate evidence of your identity for this purpose, I will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.

 

8.2    I may withhold personal information that you request to the extent permitted by law.

 

8.3    You may instruct me at any time not to process your personal information for marketing purposes.

 

8.4    In practice, you will usually either expressly agree in advance to my use of your personal information for marketing purposes, or I will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

 

  1. Cookies

By using my website and agreeing to this policy, you consent to my use of cookies in accordance with the terms of this policy.

 

How I use cookies

 

A cookie is a small file which asks permission to be placed on your computer’s hard drive.

 

The cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual.

 

The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

 

I may use traffic log cookies to identify which pages are being used.

 

Cookies help me analyse data about web page traffic and improve my website in order to tailor it to customer needs. I only use this information for statistical analysis purposes, and then the data is removed from the system.

 

Overall, cookies help me provide you with a better website, by enabling me to monitor which pages you find useful and which you do not.

 

A cookie in no way gives me access to your computer or any information about you, other than the data you choose to share with me.

 

You can choose to accept or decline cookies via the pop-up that appears on your first visit to my website. You can usually modify your browser setting to decline cookies should you wish to change your preference, however, this may prevent you from taking full advantage of the website.

 

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

 

  1. Data protection officer

 

10.1  The data protection officer is Gemma Holmes. The data protection officer’s contact details are: contact@gemmaholmes.co.uk.