Privacy Notice

milenacounselling.co.uk

Introduction
1. This is a notice to inform you of our policy about all information that we record about
you. It sets out the conditions under which we may process any information that we
collect from you, or that you provide to us. It covers information that could identify you
(“personal information”) and information that could not. In the context of the law and
this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your
only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that
all visitors to our website are entitled to know that their personal data will not be used
for any purpose unintended by them, and will not accidentally fall into the hands of a
third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and
hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the
EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to
the processing and control of your personal data. We do this now, by requesting that you
read the information provided at https://milenacounselling.co.uk/ .
7. Except as set out below, we do not share, or sell, or disclose to a third party, any
information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different
categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we
shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any
new basis under which we have determined that we can continue to process your
information.
1. Information we process because we have a contractual obligation
with you
When you create an account on our website, buy a product or service from us, or
otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information
you give us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. sell products to you
1.3. provide you with our services
1.4. provide you with suggestions and advice on products, services and how to obtain
the most from using our website
We process this information on the basis there is a contract between us, or that you have
requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide
class information, for example to monitor our performance with respect to a particular
service we provide. If we use it for this purpose, you as an individual will not be
personally identifiable.
We shall continue to process this information until the contract between us ends or is
terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us,
such as when you browse our website or ask us to provide you more information about
our business, including our products and services, you provide your consent to us to
process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for
example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message
by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose,
we do not use your information in any way that would identify you personally. We may
aggregate it in a general way and use it to provide class information, for example to
monitor the performance of a particular page on 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.
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.
You may withdraw your consent at any time by instructing us at
[email protected]. However, if you do so, you may not be able to use our
website or our services further.
3. Information we 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, in
the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our therapy
services
• responding to unsolicited communication from you to which we believe you
would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage
clinical risk
• protecting your interests where we believe we have a duty to do so
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we 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 information.
Specific uses of information you provide to us
5. Information provided on the understanding that it will be shared
with a third party
Our website allows you to post information with a view to that information being read,
copied, downloaded, or used by other people.
Examples include:
5.1. posting a message our forum
5.2. tagging an image
5.3. clicking on an icon next to another visitor’s message to convey your agreement,
disagreement or thanks
In posting personal information, it is up to you to satisfy yourself about the privacy level
of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any
individual third party may do with it. We accept no responsibility for their actions at any
time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at
our discretion we may agree to your request to delete personal information that you
have posted. You can make a request by contacting us at
[email protected]
6. Complaints regarding content on our website
We attempt to moderate user generated content, but we are not always able to do so as
soon as that content is published.
If you complain about any of the content on our website, we shall investigate your
complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the
content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will
be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with
you about it.
7. Information relating to your method of payment
You are never asked through this website for payment information. Upon beginning
therapy services with us, through secure means, payment information will be acquired at
that point.
8. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we
collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our therapy
services.
We keep personally identifiable information associated with your message, such as your
name and email address so as to be able to track our communications with you to
provide a high quality service.
9. Complaining
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
We may also compile statistics showing information obtained from this source to assess
the level of service we provide, but not in a way that could identify you or any other
person.
Use of information we collect through automated systems when you
visit our website
10. Cookies
Cookies are small text files that are placed on your computer's hard drive by your web
browser when you visit any website. They allow information gathered on one web page
to be stored until it is needed for use on another, allowing a website to provide you with
a personalised experience and the website owner with statistics about how you use the
website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close
your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to
prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and
by software operated by third parties whose services we use.
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 will not be able to use all the functionality of our website.
We use cookies in the following ways:
10.1. to track how you use our website
10.2. to record whether you have seen specific messages we display on our website
10.3. to keep you signed in our site
10.4. to record your answers to surveys and questionnaires on our site while you
complete them
10.5. to record the conversation thread during a live chat with our support team
11. Personal identifiers from your browsing activity
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.
If combined with other information we know about you from previous visits, the data
possibly could be used to identify you personally, even if you are not signed in to our
website.
12. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website
in order to be able to serve to you an advert for our products or services when you visit
some other website.
We may use a third party to provide us with re-marketing services from time to time. If
so, then if you have consented to our use of cookies, you may see advertisements for our
products and services on other websites.
Disclosure and sharing of your information
13. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set
out in this notice), we sometimes receive data that is indirectly made up from your
personal information from third parties whose services we use.
No such information is personally identifiable to you.
14. Data may be processed outside the European Union
Our website is hosted in the United States.
We may also use outsourced services in countries outside the European Union from time
to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside
the European Union.
For example, some of the software our website uses may have been developed in the
United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European
Union:
14.1. the processor is within the same corporate group as our business or organisation
and abides by the same binding corporate rules regarding data processing.
14.2. the data protection clauses in our contracts with data processors include transfer
clauses written by or approved by a supervisory authority in the European Union
[, specifically that in the country of …]
14.3. we comply with a code of conduct approved by a supervisory authority in the
European Union [, specifically that in the country of …]
14.4. we are certified under an approved certification mechanism as provided for in the
GDPR
14.5. both our organisation and the processor are public authorities between whom
there is either a legally binding agreement or administrative arrangements
approved by a supervisory authority in the European Union relating to protection
of your information
Access to your own information
15. Access to your personal information
15.1. At any time you may review or update personally identifiable information that we
hold about you, by signing in to your account on our website.
15.2. To obtain a copy of any information that is not provided on our website you may
send us a request at [email protected]
15.3. After receiving the request, we will tell you when we expect to provide you with
the information, and whether we require any fee for providing it to you.
16. Removal of your information
If you wish us to remove personally identifiable information from our website, you may
contact us at [email protected]
This may limit the service we can provide to you.
17. Verification of your information
When we receive any request to access, edit or delete personal identifiable information
we shall first take reasonable steps to verify your identity before granting you access or
otherwise taking any action. This is important to safeguard your information.
18. Use of site by children
18.1. We do not sell products or provide services for purchase by children, nor do we
market to children.
18.2. If you are under 18, you may use our website only with consent from a parent or
guardian
18.3. We collect data about all users of and visitors to these areas regardless of age,
and we anticipate that some of those users and visitors will be children.
18.4. Such child users and visitors will inevitably visit other parts of the site and will be
subject to whatever on-site marketing they find, wherever they visit.
19. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and
to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using
SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar
or toolbar.
20. How you can complain
20.1. If you are not happy with our privacy policy or if have any complaint then you
should tell us by email. Our address is [email protected].
20.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by
engaging in good faith with us in a process of mediation or arbitration.
20.3. If you are in any way dissatisfied about how we process your personal
information, you have a right to lodge a complaint with the Information
Commissioner's Office. This can be done at https://ico.org.uk/concerns/
21. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information
only for as long as required by us:
21.1. to provide you with the services you have requested;
21.2. to comply with other law, including for the period demanded by our tax
authorities;
21.3. to support a claim or defence in court.
22. Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or
legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of
your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.
23. Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply
to you are those posted here on our website on the day you use our website. We advise
you to print a copy for your records.
If you have any question regarding ouur privacy policy, please contact us at
[email protected]