Privacy Information Notice
At Holistic Therapy Practice, we’re committed to protecting and respecting your privacy.
This Policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and what choices you have. It relates to all our business activities, not just this website.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our services, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to firstname.lastname@example.org or via the other methods on our contact page.
Date: 11th May 2018
Next Review Date: 11th May 2019
Author: Rodney Robinson
1. Who are we?
We are Wellbeing Energetics, a company providing holistic therapy services and training services to clients in Spain and occasionally further afield.
Our registered address is Nivel 1, numero 7, El Zoco de Nerja, Urb. Paco Romo, Nerja 29780 SPAIN
2. How do we collect information from you?
We obtain information about you when you contact us to enquire about our services.
3. What information do we collect & how is it used?
We collect information to allow us to fulfil our obligations to our clients, and to respond to business enquiries. The table in section 3.3 below outlines exactly what information we collect, and for what purpose.
3.0. Sensitive Data
Sensitive personal data is necessarily collected and stored as part of your health resume that you provide in your consultation. These are kept in a file 'Clients records'. Your communication with us will be stored here also.
3.1. Children’s information
If you learn that a child under 13 has provided us with personal information without consent, please contact us.
3.2. Third Parties
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
We also use a number of 3rd party services to help us fulfil our contractual obligations. These 3rd party services are listed in full below; we have verified that these 3rd party services are GDPR compliant (or are working towards GDPR compliance), and are certified under the EU-US Privacy Shield Framework (or are working towards certification) where these organisations are based outside of the EU.
The following table outlines the personal data we collect and for what purpose. The table also outlines the 3rd parties the data is processed by or shared with, and how long the data is stored for:
|Name||What||Legal Ground||Purpose||3rd Parties||Data Retention|
|Prospect, client & supplier contact information||Contract||To allow initial and ongoing contact with prospects, clients, suppliers, etc.||Google Mail
We have signed EU model contract clauses.
|Until request for deletion.|
|Analytics||Website visitor behaviour (anonymised – full IP address is NOT stored)||Legitimate interests||To analyse popular content, website performance, etc – so we can further improve.||Google Analytics
We have signed EU model contract clauses & anonymise IP addresses
|Indefinitely/for as long as Google Analytics retains. NB: not personal data|
|Server Logs||IP address||Legal obligation||To help prevent DoS (Denial of Service) attacks; for website security and diagnostics.||20i||Server logs are stored unencrypted for 7 days, and then moved to an encrypted backup which is stored indefinitely and only accessible by 20i|
|CRM||Client database||Contract||To maintain contact information for clients and notes for the web design process||Held locally||Until request for deletion.|
|Doc||Health resume||Contract||To plan therapeutic interventions and record progress||Held locally||Until request for deletion|
4. Controlling your information
You have certain rights concerning the information we hold about you, as defined under the General Data Protection Regulation. If you wish to exercise these rights, please contact us, including your email address in the first instance (this is the unique identifier we use to identify and collate personal information).
4.0. Requesting a copy of your information
You may request a copy of any data we hold about you. Upon request, we will provide a pdf file containing the personal data we hold on record about you.
4.1. Updating or correcting your information
The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please contact us so we may correct our records.
4.2. Deleting your information
You have the right to request erasure of your personal information. Unless there is a compelling reason for the data not to be erased (for example, if we need to use that data to fulfil our contractual or legal obligations), your personal data will be deleted on request.
4.3. Automated decision making
We do not use any personal information for automated decision making or profiling; your data is not subject to automated decision making or profiling.
5. Use of ‘cookies’
- Google Analytics: Google Analytics sets cookies to help us accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that our website is responding to your needs in the best way possible.
By using and browsing the Wellbeing Energetics website, you consent to cookies being used in accordance with this Policy.
If you do not consent, you must turn off cookies or refrain from using the site. Most browsers allow you to turn off cookies. To do this, look at the ‘help’ menu on your browser. Switching off cookies should not noticeably restrict your use of this website.
Wellbeing Energetics takes security seriously. In order to protect your information from loss, misuse or unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include the following:
- Data minimisation
- Security best practice concerning devices (PCs, laptops, mobile devices), online accounts, website hosting, physical access and storage
- Password best practice
- Staff training and accountability on data protection
7. Data Breaches
Our Data Security Policy includes a clear process for handling a personal data breach, should one occur. Where appropriate, Wellbeing Energetics will promptly notify you of any unauthorized access to your personal information.
If you wish to raise a complaint on how we have handled your personal information, you can contact us directly and we will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).