Date made: 14 April 2016
Implementation Date: 25 May 2018
I, Heloisa Stephan, respect your privacy and am committed to protecting your personal data. This privacy notice will inform you as to how:
I look after your personal data:
When you visit my Website.
Subscribe to my news.
Or my service offers.
Or purchase any services from my Website.
About your privacy rights.
And how the law protects you.
Important information and who I am.
Purpose of this privacy notice.
This privacy notice aims to give you information on how I collect and process your personal data through your use of this Website, including any data you may provide through this Website when you:
- Make your own appointments
- Sign up to my News and/or any other of the services I offer, including courses, workshops, events, also with affiliates or other professional colleagues.
- Leaving comments on this website.
- Purchase a product/content or service
This website is not intended for children or anyone under 16 years of age and I do not knowingly collect data related to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice I may provide on specific occasions when I collect or process personal data about you so that you are fully aware of how and why I use your data. This privacy notice supplements any other notices and is not intended to override them.
Heloisa Stephan (referred to as “Heloisa”, or “I”, or the SiteOwner, in this privacy notice) is responsible for your personal data collected from my Website via booking, purchases, or supplied to me via email, a subscription form or telephone booking/purchase.
As the responsible for you Data Protection, if you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact me using the details set out below.
My full details are:
Email address: firstname.lastname@example.org
Postal address: At We Are Wellness, 2 North Hill Road, Leeds LS6 2EN
Telephone number: 07504772727
I would appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance, however, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
Changes to the privacy notice and your duty to inform me of changes
The data protection law in the UK changed on 25 May 2018 and this privacy notice sets out your rights under the new laws.
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
This Website may include links to third-party Websites such as YouTube and other Websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party Websites and am not responsible for their privacy statements. When you leave my Website, I encourage you to read the privacy notice of every Website you visit.
The data I collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
When you leave leave comments on the site, we collect the data shown in the comments form, and also the your IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Contact forms – Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
Analytics – Who we share your data with – How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
Additionally, depending on your purchases and/or bookings through my website, I may collect, use and store different kinds of personal data about you which I have grouped together as follows:
- Identity Data includes first name, last name, Skype, Messenger, or other usernames or similar identifier.
- Contact Data may include billing address, delivery address, email address and telephone numbers.
- Financial Data I keep a record of payments made to me to supply or run, yours or my, accounts, services or subscriptions. Any card details you securely provide to Stripe or Paypal for payment of services, sales or subscriptions are dealt with and protected by them and I do not receive any of your personal data with the confirmation notice from them or on my account on their websites.
- Transaction Data may be held by my credit control department to outline payment history and to comply with accounting and tax laws.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access my Website.
- Usage Data includes information about how you use my Website, products and services.
- Marketing and Communications Data might include your preferences in receiving service offers and your communication preferences.
- I do not collect any Special Categories of Personal Data about you. I only hold information relating to therapy treatments undergone with me, which I underly the general practitioner’s, and the GHR (General Hypnotherapists Register, code of ethics. Nor do I collect any information about criminal convictions and offences.
- To process your booking and retain your information on file for the purposes of carrying out your booking; proof of payment and for you to book again without you having to complete the registration process again, and to prevent and detect fraud.
How is your personal data collected?
I use different methods to collect data from and about you, including through:
You may give me personal information when you:
- Fill in forms or by corresponding with me by post, phone, email or otherwise.
- Enter a website membership for content or recurrent services.
- Buy products or services via my website.
- Subscribe to my newsletters and/or services offers and events.
- Enter a promotion, survey or poll.
- Write me some feedback or review.
- Automated technologies or interactions.
- As you interact with my Website, it may automatically collect Technical (Cookies) Data through Google analytics. These cookies are used to collect information about how visitors use the site. I use the information to compile reports and to help me improve the Website. The cookies collect information in an anonymous form about your equipment, browsing actions and patterns. including the number of visitors to the site, how visitors have come to the site and the pages they have visited. Click here for an overview of privacy at Google.
- Third parties or publicly available sources.
- I may receive technical data about you from various third parties and public sources as part of Google Analytics
- How I use your personal data
I will only use your personal data for the purpose you provide me it and when the law allows me to. Most commonly, I will use your personal data in the following circumstances to which I might need to use the following data:
- Identity data
- Contact data
- Financial data
- Transaction data
- Technical data
- Where I need it to be able to provide you with the service you require.
- Where I need to comply with a legal or regulatory obligation.
- To register you as a new client
- Performance of a contract with you
- Negotiation, Holistic offers and Communications
- To process and deliver your order including:
- Manage payments, fees and charges
- Collect and recover money owed to me
- Performance of a contract with you
- Necessary for my legitimate interests (to recover debts due to me)
- To manage my relationship with you which will include:
- Performance of a contract with you
- Necessary to comply with a legal obligation
- To enable you to partake in a prize draw or competition
- To administer and protect my business and this Website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
- Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise)
- Necessary to comply with a legal obligation
Generally, I rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent at any time by contacting me in writing via email or the postal address above.
- Purposes for which I use your personal data
Below is a description of ways I may use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.
Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I use your data. Please contact me if you need details about the specific legal ground I rely on to process your personal data where more than one ground has been set out in the table below.
- Email correspondence/Newsletter/Holistic Promotions and phone communication
I strive to provide you with choices regarding certain personal data uses, particularly about holistic promotions/newsletters that you give me consent to send to you. You may opt out at any time by contacting me in writing or using the unsubscribe button.
- Third-party holistic treatments/promotions/marketing
I will not share your data with any one nor with any company unless you request me to.
- Opting out
You can ask me to stop sending you any messages or emails, including holistic offers at any time by following the opt-out links on any newsletters, or unsubscribe from any email sent to you or by contacting me in writing at any time.
Where you opt out of receiving these news/promotional messages and/or emails, this will not apply to personal data provided to me as a result of a product/service purchase, quality control or product/service experience.
When you opt out of any newsletter the email company will still securely hold your data to ensure that you are not contacted again in the future by mistake.
- Disclosures of your personal data
I may have to share your personal data with the parties set out below for the purposes of running my business:
They will only process your personal data on my instructions and are subject to a duty of confidentiality.
- Third Parties including, but not exhaustive, my hypno-psychotherapy, and other supervisors, my email service provider, financial company, bank, technical or legal representatives, accountants and auditors or, if required by a court order, or by the police or another authority investigating illegal activity. authorities with the relevant authorisations.
- Working with or transferring your personal information in the UK and outside of the EEA. As part of my business operations I use an Internet supplier in the UK (Hyperoptics) and also may need to transfer your data out of the European Economic Area or EEA. For example, to my business suppliers: for Internet access, Microsoft, for office software and Skype for video remote therapies or consultations, Hostgator, my hosting server, Mailchimp, or Constant Contact, for email communication purposes, which some are outside the EEA. In this case, I’ll take steps to ensure that your privacy rights continue to be protected as outlined in this notice.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.
- Data security
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. I take every precaution to protect your data, and I’ve developed and adopted technologies, practices and policies to safeguard you and your data.
I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I are legally required to do so.
Your data is securely stored on Google Cloud and only accessible via signing in to my account and with my own password, and also my mobile phone, which is protected by a PIN number or pattern lock of the phone and the password on the Google account to access it. In case of the phone being lost or stolen, I have put in place the measures to remotely erase all contents and make the phone unusable thereafter.
- Data retention
How long will I use your personal data for?
Records will not be deleted automatically unless you request that they are in writing, with proof of identity.
I will retain your personal data for as long as you wish to receive communication (concerning psychic and spiritual, psychotherapy, hypnotherapy consultations, other holistic treatments, courses, workshops, offers), and consent me to, to fulfil the purposes I collected it for, including for the purposes of satisfying your additional interests in other therapies modalities and treatments, any business, legal, accounting, or reporting requirements.
By law, and by insurance purposes, I have to keep basic information about clients for tax purposes (including Contact, Identity, Financial and Transaction Data) for at least six years after they cease being clients.
In some circumstances you can ask me to delete your data: see request erasure below for further information.
In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.
- Your legal rights
Under certain circumstances, you have rights under data protection laws (more detailed below) in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw
Although I strive to always give you a personal benefiting treatment, if you wish to exercise any of the rights set out above, please do first contact me. For more information regarding your individual rights please visit the ICO Website or follow the link here.
- No fee usually required
You will not be charged a fee to access your personal data (or to exercise any of the other rights). However, I retain the right to charge a reasonable fee if your request is clearly unfounded, or excessive. Depending on the circumstances, I may refuse to comply with your request.
- What I may need from you
I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up the response process.
- Time limit to respond
I will respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made several requests. In this case, I will notify you and keep you updated.
Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your own request, consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.
Companies I use:
- Paypal and Stripe and Google Cloud, OneDrive for Business, Google different services, Google Wallet, Google Analytics, Google adsettings, Hostgator, Mailchimp, Constant Contact, Microsoft Office 365, Facebook, Setmore, and I’ll do my best to keep this list updated with new or additional service providers.
YOUR LEGAL RIGHTS EXPLAINED
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I are lawfully processing it.
- Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I are required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where I rely on a legitimate interest (or those of a third party) and there is something about your personal situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I process your personal data for direct holistic promotional purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios:
- If you want me to establish the data’s accuracy
- Where my use of the data is unlawful, but you do not want me to erase it;
- Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims
- You have objected to my use of your data, but I need to verify whether I have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.
- Withdraw consent at any time where I rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.