Privacy Policy

Privacy Policy

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This policy describes how I collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

This policy applies to personal data collected through my website and also through social media platforms.

Except as set out below, I will not share, or sell, or disclose to a third party, any information collected through my website.

If you have any questions about how I process your data, please ask me. 

Personal data

How I obtain personal data

The information we process about you includes information:

  • you have directly provided to me
  • that I gather from third party databases and service providers
  • as a result of monitoring how you use my website and services

Types of personal data I collect directly

When you decide to work with me, I will have some access to your information, such as

  • your first and last name
  • Your email address and maybe your phone number
  • Your bank account details if you have paid me by bank transfer. 
  • Email messages and other messages such as WhatsApp or Facebook messenger. 
  • Marketing preferences in terms of website cookies. 

I do not collect any information about you from 3rd parties.

Types of personal information I collect from working with you.

  • Any information you might contribute, such as a review.
  • technical information about the hardware and the software you use to access my website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
  • usage information, including the frequency you use my services, the pages of my website that you visit, whether you receive messages from me and whether you reply to those messages
  • transaction information that includes the details of working with you, and payments made
  • your preferences to receive marketing from me; how you wish to communicate with me; and responses and actions in relation to your use of our services

My use of aggregated information

I may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

Although, to be perfectly honest, I probably won’t do this data collection work. It would be very unlike me.

For example, I may aggregate usage information to assess whether a feature of our website is useful.

However, if I combine or connect aggregated information with your personal data so that it can identify you in any way, I treat the combined information as personal data, and it will be used in accordance with this privacy notice.

Special personal data

Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Some of these things may come into our conversation as we do therapeutic work together. I will only note these things down if they are relevant to this work, and you may see those notes at any time.

The bases on which I process information about you

The law requires me to determine under which of six defined bases I process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which I process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law I shall notify you of the change and of any new basis under which I have determined that we can continue to process your information.

Information I process because I have a contractual obligation with you

When we decide to work together, a contract is formed between us. (Please see terms of service).

There will be some use of your personal data as I fulfil my part of that contract.

When we are not working together any more I will not keep hold of your personal data, unless you have agreed for me to hold onto your contact details, for example.

Information my website people and AI process with your consent (this is cookies…)

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse my website or ask me to provide you more information, you provide your consent to us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

Personally, I hate this and always decline where possible. However it is how the internet works, unfortunately. There’s no such thing as a free lunch.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

I don’t know how this stuff works. I’m not sure anybody does, actually. But if you want me to get rid of these cookies on your device and stop using my website completely, please contact me on my email address and I will try to find out how to do it. 

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so. Crikey.

Information the internet angels may process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data, and whether you would consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

  • improving our services
  • record-keeping for the proper and necessary administration of my work
  • responding to unsolicited communication from you to which we believe you would expect a response
  • preventing fraudulent use of our services
  • exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
  • insuring against or obtaining professional advice that is required to manage risk
  • protecting your interests where we believe we have a duty to do so

Information I process because I have a legal obligation

Sometimes I must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

I would usually be able to tell you if this has happened. The only time I would be required not to tell you is in the case of the authorities using terrorism legislation in their demand for information.

This also applies to legal obligations on me to protect safeguarding interests of vulnerable people.

Service providers and business partners

We may share your personal data with businesses that provide services to us, or with business partners.

As examples:

  • we may pass your payment information to our payment service provider to take payments from you
  • we may use fraud prevention agencies and credit reference agencies to verify your identity and we may pass your information to those agencies if we strongly suspect fraud on our website

Personal identifiers from your browsing activity- more about cookies….

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate. 

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website.
  • Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

Re-marketing

Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for services when you visit some other website.

The benefit of re-marketing technology is that the internet can provide you with more useful and relevant adverts, and not show you ones repeatedly that you may have already seen.

One day, I may use a third-party advertising service to provide me with re-marketing services from time to time. If you have consented to my use of such tracking technologies, you may see advertisements for me on other websites. This is highly unlikely, however.

We do not provide your personal data to advertisers or to third-party re-marketing service providers. However, if you are already a member of a website whose affiliated business provides such services, that affiliated business may learn of your preferences in relation to your use of our website.

Other matters

Your rights

The law requires me to tell you about your rights and my obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

Use of my services by children

I do not sell products or provide services for purchase by children, nor do I market to children. If you wish to work with me in family therapy, because of health issues in your children, that’s fine, but I will deal with you and not your children directly and I will hold only minimal information on your child(ren).

If you are under 18, you may and should only use my website with consent from a parent or guardian.

We collect data about all users of and visitors to these areas regardless of age, and occasionally some of those users and visitors will be children, although probably not very often.

Delivery of services using 3rd party communication software

With your consent, I may communicate using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.

If you have any concerns about using a particular software for communication, please tell me.

Data to be processed outside the UK

My website is hosted in the UK. My email services are hosted in Switzerland, which has excellent privacy laws and emails are not screened for content.

Control over your own information

It is important that the personal data I hold about you is accurate and up to date. Please inform me if your personal data changes.

At any time, you may contact me to request that we provide you with the personal data I hold about you.

When I receive any request to access, edit or delete personal data I will first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

While having your consent is an important consideration as to whether to process your data, if there is another legitimate basis on which I may process it, I may do so on that basis.

Communicating with me

When you contact me, I collect the data you have given to us in order to reply with the information you need.

I record your request and my reply in order to increase my the efficiency. 

I may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track my communications with you to provide a high quality service.

Complaining

If you are not happy with my privacy policy, or if you have any complaint about my work, then it would be great if you could tell me.

When I receive a complaint, I record the information you have given to me on the basis of consent. I use that information to resolve your complaint.

If you are unable to talk to me about a complaint, you may complain to my registering body for psychotherapy, the BACP. Their complaints procedure is available on their website. Please note that the BACP is responsible to monitor my work as a psychotherapist. It is not responsible to monitor my work as a cancer coach.

If your complaint reasonably requires us to notify some other person, I may decide to give to that other person some of the information contained in your complaint. I do this as infrequently as possible, but it is a matter for my sole discretion whether I do give information, and if I do, what that information is.

If you are in any way dissatisfied about how I process your personal data, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

Retention period: compliance with the law

Except as otherwise mentioned in this privacy notice, I keep your personal data only for as long as required by me.

My privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

Please note that this privacy policy may be reviewed from time to time.