Privacy Policy

I take my responsibility to protect your personal data very seriously.

I do not and will not sell your data to third parties.

I respect privacy and your rights to control your personal data and am aware of my legal obligations, in particular under the General Data Protection Regulation (GDRP). In view of that, this policy aims clearly to set out the data I collect through this website and why I do so:

The prime purpose of collecting your data is to provide you with services (“Services”) offered by my website (“Site”), primarily using the Site to find information, to contact me and to enable me to work with you delivering the my anger management programme or psychotherapy.

This privacy notice (“privacy notice”) (together with my terms of use and any other documents referred to in them) explains how I will process any personal data I collect from you through this Site, or that you give to me. It’s relevant to anyone who uses this Site – known as “data subjects” in the legislation and referred to below as “you” or “users”.

Your acceptance of this Privacy Notice is deemed to occur upon your first use of this Site, so if you do not accept and agree with it you must stop using the Site immediately.

Please be aware that this Site and Services may contain links to third party websites that are not covered by this Privacy Notice. For their privacy policies you will need to read their respective privacy statements.

On this page

  1. Who “I” am
  2. The Site
  3. The types of personal information I collect and the basis for my processing of it
  4. Cookies
  5. What I do with information I collect about you and why
  6. Where I store your data
  7. Disclosing your information
  8. Retaining your personal information
  9. Your rights
  10. Links to other sites
  11. Changes
  12. How to contact me about this privacy notice
  13. Complaints

 

  1. Who “I” am

Under GDPR I am known as a ‘data controller’.  My name is Florence Terry and my contact email is florence@stopseeingred.co.uk. My main trading address is 9 Orme Court, London W2 4RL.  I am registered with the ICO under registration number Z8780849.

 

  1. The Site

As the person responsible for data processing, I take a proactive approach to user privacy by taking technical, contractual and organisational safety measures.  I am committed to processing your data in accordance with the applicable privacy regulations.

When you use or contact the Site, though I strive to protect your personal information, I cannot guarantee the security of any information you transmit to me, and you do so at your own discretion and provide any personal details at your own risk. Information from the Contact Form and emails are transmitted normally over the internet and this can never be guaranteed to be 100% secure.

If you choose not to provide the personal information I request, you can still visit all areas of the Site but you will be unable to submit the contact form and unable to book an appointment to work with me. You have the final decision on whether to proceed with any activity that requests personal information.

You are responsible for any third-party personal data published or shared through this Site and confirm that you have the third party’s consent to provide the data to me through the Site.

  1. The types of personal information I collect and the bases for my processing of it.

I may collect and process the following data about you:

  • Information you give me. I collect information you voluntarily provide to me by filling in forms on the Site, by corresponding with me by phone, e-mail, or in other ways. The information you give me may include your name, address, e-mail address and phone number.

 

Although I only require initial contact information from you, you may choose to provide me with further information which may fall under the definition of sensitive personal information. Under GDPR explicit consent is required if you ask me to process Special Categories of Personal Data (previously called ‘sensitive personal data’) for you, such as information about your mental or physical health, your sexual life or orientation, or your religious or philosophical beliefs. By filling out and using the forms on the Site you agree to me processing your information.

I will not be held responsible for the type or nature of information that you have voluntarily disclosed using the contact methods provided on the Site; however, I will obtain your explicit consent before I use any such data by asking you to tick a box on the contact form before submitting it. This will mean that you explicitly affirm your agreement to me collecting and using this information for your benefit. (Brian, can this easily be added to my submit form? If not, let’s delete this paragraph and add it to the ToDo list for my next site.)

  • Information I collect automatically. Whenever you visit the Site, I may automatically collect the following information about you:
    • technical information. I may, for example, collect information about the type of device you use to access the Site, the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site;
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call me.
  • Like many websites, I use “Cookies” to enhance your experience and gather information about visitors and visits to the Site. For detailed information on the cookies we use and their purposes see my Cookie policy.
  • Information I receive from other sources. I may receive information about you from other sources e.g. if someone emails or rings on your behalf.
  • Analytics, includes third-party analytics services (such as Google Analytics) to evaluate your use of the Site, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the Site and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Site, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Notice.

Legal basis of processing

I will only process your personal data if at least one of the following bases applies:

  • you have given consent to the processing of your personal data for one or more specific purposes.
  • processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract.
  • processing is necessary for compliance with a legal obligation to which I am subject;
  • processing is necessary to protect the vital interests of you or of another natural person;
  • processing is in my legitimate interests or those of a third party, where there is no good reason which overrides these legitimate interests.
  1. Cookies

The Site uses cookies to distinguish you from other users of the Site. This helps me to provide you with a good experience when you browse the Site and also allows me to improve the Site. For detailed information on the cookies I use and the purposes for which I use them see my Cookie policy.

  1. What do I do with information I collect about you and why?

If you correspond with me e.g. by filling out the form on my Contact Us page, or contacting me via email or telephone, I may use this information to improve my service or to communicate with you as outlined below.

Primarily, I may use your email address to communicate with you e.g. to send you information that you have requested or to set up a time to speak and I may use your telephone number to contact you to e.g. give you information you seek. If you decide to work with me, I will use personal information about you in order to provide you with the services I offer i.e. anger management and/or psychotherapy.

Exceptionally, if I judge that there is a risk of serious harm to you or others, I may use it to seek assistance for you/them. Such disclosure would be by way of contact with your GP or the appropriate authorities only. It is a very unusual step and I would normally seek to discuss the action with you first and, ideally, act with your consent.

Third parties may carry out certain activities, such as processing and sorting data and monitoring how customers use the Site. (see below).

My servers record the IP addresses of visitors to the Site for a short period to enable me to monitor the performance of the Site, but I will generally delete this data as I do not retain it any longer than necessary. I may also store information about you, such as your IP address or website activity, in certain database fields to record certain actions – for example, I use Google Analytics. I use this information to monitor and administer the Site.

This is a summary of the ways that I may use your personal information. Depending on the way that you use the Site some of these may not apply:

  • To present Site content in the most effective manner for you and your device(s).
  • To provide information, products and services that you request, or which I think may interest you.
  • To carry out my contract with you.
  • To tell you about changes to my Services.
  • To administer the Site and for internal operations like trouble shooting, data analysis, testing and statistical purposes.
  • As part of my efforts to keep the Site safe and secure.
  • For my business records, e.g. I have to retain accounting records for at least 6 years.
  • For dispute resolution.
  • To give me feedback.
  1. Where I store your data

Data security is of great importance to me, and to protect your data I have put in place suitable physical and electronic methods and suitable organisational procedures to safeguard and secure data collected through the Site. For example, emails are stored on an encrypted, password-protected computer. As part of this, I limit access to your personal data to those agents, contractors and other third parties who have a business need to know. They are subject to a duty of confidentiality (subject to the same rights to disclose I retain for myself set out below).

The data that I collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for one of my suppliers. These staff may be engaged in, among other things, the processing of your payment details and the provision of support services like email communications.

By submitting your personal data, you agree to this transfer, storing or processing. For my part, I will take all steps reasonably necessary to keep your data secure and up to date. For example, where such processing takes place, appropriate controls, such as the adoption of agreements containing appropriate clauses, will be in place to require that your information is protected to the same standard as if it were in the UK.

Unfortunately, the transmission of information via the internet is not completely secure. Although I will always do my best to protect your personal data as outlined in this Privacy Notice, I cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk.

I have put procedures in place to deal with any suspected personal data breach, and will notify you and any applicable regulator of a breach where I am legally required to do so.

  1. Disclosing your information

I am allowed to disclose your information in the following cases:

  • I will disclose information to third parties if I consider that such disclosure is necessary to comply with the law
  • I may disclose it if I judge that there is a risk of serious harm to you or others. Such disclosure would be by way of contact with your GP or the appropriate authorities only. It is a very unusual step and I would normally seek to discuss the action with you first and, ideally, act with your consent.
  • I am in professional supervision and I may discuss my contact with you in this context. Any such discussion is normally on an anonymised basis and I have agreements in place that the supervisor will treat it in confidence; subject to the same exceptions provided in this section.
  • I can disclose it if I’m obliged to in order to enforce or apply my terms of use and as part of this can disclose them in connection with legal proceedings (including prospective proceedings).

 

Third parties

I contract with some third parties to enable me to supply my Services to you. I use a variety of third-parties, such as for email communications, taking payments and technical issues. In some cases, these third parties may require access to some or all of your data. In these cases, I only share the appropriate level of personal data to enable the supplier to provide their services and take all reasonable steps to ensure it is handled safely and securely and in accordance with my obligations under GDPR and the law.

Third parties may carry out certain activities, such as processing and sorting data and monitoring how customers use the Site. This information is anonymous in that only IP addresses can be identified.

For questions about such third-parties, please send me an email to florence@stopseeingred.co.uk

 

  1. Retaining your personal information

I will retain your personal information for as long as I deem it necessary to enable you to use the Site, to provide Services to you, to comply with applicable laws (including those regarding document retention), resolve disputes, and otherwise as necessary to allow me to conduct my business.

All personal information I retain will be subject to this Privacy Notice and my internal archiving and retention guidelines. I will also retain data in an anonymous form for statistical and analytical purposes, for example, to understand how my users interact with my service. If you have a question about a specific retention period for certain types of personal information I process about you, please send an email to florence@stopseeingred.co.uk.

 

  1. Your rights

Under the GDPR, you have the right to control how your personal information is used in the following ways:

  • You can ask for a copy of your personal data held by me, at no cost to you
  • You can ask me to correct any personal information that I hold about you, or inform me about any changes to your personal information
  • You can request that your personal data be transferred to another person (data portability)
  • You can ask to be informed of what data processing is taking place
  • In certain situations, you can ask that I restrict processing of, or object to processing of, your personal data
  • In certain situations, you can ask that I delete personal information that I hold about you.

Where I am using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Where I process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.

I rely on you to ensure that your personal information is complete, accurate and up to date. Please do inform me promptly of any changes to or inaccuracies in your personal information by contacting florence@stopseeingred.co.uk. I will respond to your request as soon as possible, but certainly within 30 days.

I am committed to working with you to obtain a fair resolution of any complaint or concern you may have about my use of your personal information. If, however, you believe that I have not been able to assist with your complaint or concern, you may have the right to file a complaint with the UK supervisory authority – details of which are found in section 13 of this policy.

  1. Links to other sites

Please note that my terms and conditions and my policies will not apply to other websites that you get to via a link from this Site. I have no control over how your data is collected, stored or used by other websites, and I advise you to check the privacy policies of any such websites before providing any data to them.

  1. Changes

If I change this Privacy Policy, I will post the changes on this page. If I decide to, and if I have a valid email address stored for you as outlined in the sections above, I may also email you to let you know about any changes.

  1. How to contact me about this privacy notice

If you have questions about this privacy notice or have a request to exercise your rights (set out below) please contact me at 9 Orme Court, London, W2 4RL or via email: Florence@stopseeingred.co.uk.

 

You can contact me using these details for one or more of the following reasons:

  1. To ask me to fix information about you that is wrong or incomplete, or to delete personal information about you (the so-called “Right to be Forgotten”).
  2. To tell me you no longer agree to, that you object to, or that you wish to restrict me using information about you and ask me to stop.
  3. To tell me to stop using your personal information to tell you about products or services that may be of interest to you.
  4. A right of access, namely to ask me to provide you with a copy of all of the personal information that I have about you.
  5. A “data portability” right, namely to obtain and reuse the information that you have provided to me for your own purposes across different services. You may ask for this information to be provided directly to you or directly to another organisation. I will provide the information in a machine-readable format so that another organisation’s software can understand that information.

 

Sometimes I will not be able to stop using your personal information when you ask me to (e.g. where I need to use it because the law requires me to do so or I need to retain the information for regulatory purposes).

In other cases, if I stop using your personal information, I will not be able to provide services to you.

I will tell you if I am are unable to comply with your request, or how your request might impact you, when you contact me.

  1. Complaints

If you have any concerns about my use of your personal information, please raise it with me by emailing florence@stopseeingred.co.uk.  You also have the right to complain to the Information Commissioner’s Office (ICO).  Contact details for the ICO are:  https:ico.org.uk/global/contact-us/

Telephone: 0303 123 1113.  Textphone 01625 545860.

29th October 2019