Privacy Policy

Privacy policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

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

2. Credit

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

3. How we use your personal data

3.1 In this Section 3 we have set out:

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

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

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

(d) the legal bases of the processing.

3.2 We may process data about your use of our 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 our analytics tracking system and Facebook pixels. 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 our legitimate interests, namely monitoring and improving our website and services.

3.3 We 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 our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 We may process your information included in your personal profile on our website (“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 our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.5 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include medical information, information, notes and recordings 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 our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

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

3.7 We may process information contained in any enquiry you submit to us 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 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our 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 us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.9 We may process information that you provide to us for the purpose of subscribing to our 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 us and/or taking steps, at your request, to enter into such a contract. You can unsubscribe from our direct marketing communications at any time.

3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our 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 our legitimate interests, namely the proper administration of our website, business and communications with users.

3.11 We 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 our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are 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 us, unless we prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to our 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 Financial transactions relating to our website and services may be handled by our payment services provider, Santander Online Banking. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.santander.co.uk/uk/help-support/security-centre/data-protection

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

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 The hosting facilities for our website are situated in United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of this country. Transfers to this country will be protected by appropriate safeguards, namely the Privacy Shield Framework. 

5.3 Our website has an SSL certificate given by the Certification Authority GeoTrust. This ensures any data is encrypted. 

5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

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

6.2 Personal data that we 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, personal data and service data will be retained indefinitely from the moment you consent to use our services for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. All data is kept strictly private and confidential by either password, encryption or lock and key. The legal basis for this retention complies with our registration and recommendation of QCHPA, it is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. You can find information about the QCHPA’s recommendation here https://www.qchpa.com/privacy-policy/

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

7. Amendments

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

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

8. Your rights

8.1 You may instruct us to provide you with any personal information we 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, we 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 We may withhold personal information that you request to the extent permitted by law.

8.3 You may instruct us 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 our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9. Cookies

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

9.2 A cookie is a small file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookie’s ask permission to be placed on your computer’s hard drive.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. How we use Cookies

10.1 We use cookies for the following purposes:

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

(b) A web application such as Facebook can tailor it’s operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

(c) We use traffic log cookies from Stat Counter to identify which pages are being used.

(d) Cookies help us analyse data about web page traffic and improve our website in order to tailor it to your needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

(e) Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not.

(f) A cookie in no way gives us access to your computer or any information about you, other that the data you choose to share with us.

(g) You can choose to accept or decline cookies on the website’s homepage. Most web browsers automatically accept cookies but you can usually modify your browser setting to decline cookies if you prefer. However this may prevent you from taking full advantage of the website.

11. Our details

11.1 This website is owned and operated by Michala Lota.

11.2 We are registered in England as a Sole Trader and our registered office is at Barley Hill Cottage, 25 Woodbine Street, Leamington Spa, Warwickshire CV32 5BG.

11.3 Our principal place of business is as above and online.

12. Data protection officer

12.1 Our data protection officer’s contact details are: michala@michalalota.co.uk Reference number: ZA370624

12.2  If you have any concerns or think your rights have been breached, you can make a report to the Data Protection Officer sited above or to the ICO at https://ico.org.uk/for-the-public/