At Spirals of Life Transformational Therapies, we’re committed to protecting and respecting your privacy.
This Policy describes how we collect, use, retain and safeguard personal data. It also sets out your individual rights to know what data is held about you, how this data is processed and how and when you may place restriction on the use of your data. This Policy relates to all our business activities, not just this website.
What is personal data?
Personal data is information which can identify you, for example, your name and email address. It can also include your age, date of birth or gender.
Personal data may contain information which is known as special categories of personal data (sensitive data). This may be information relating to, and not limited to, an individual's health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to sexual orientation.
Changes to Policy
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.
For any questions regarding this Policy and our privacy practices, please .
1. Who I am
I am Liz Kozlowski, a therapeutic coach providing transformational mind-body therapies to clients in the UK and further afield. I am legally and ethically bound to protect your online confidentiality, including the confidentiality of your records, which are stored and secured according to professional guidelines.
2. How do I collect data from you?
I obtain data about you when you contact me to enquire about my services, either from direct conversations, email correspondence or intake form (either online or on paper). This information may be collected through email or telephone enquiries, website forms, at events or via social media. You have no legal requirement to share information with me, but if you do not then I won't be able to offer you any of my services.
3. What data is collected and how is it used?
I collect personal data from you (name, contact details and any other information you may offer):
- To enable me to decide whether I am able to offer you my services, to allow me to administer and deliver my services to you, to fulfil my obligations, to perform any contract agreed with you, to enable me to invoice you or receive payment, to respond to business enquiries and to provide you with information you have asked for.
- To protect my business from fraud or other illegal activities, which is necessary for my legitimate interests by ensuring the proper management of my business and financial risks.
- To provide you with information by email about other products and services I offer similar in nature to those you currently receive or have previously asked about. Information I may process for this purpose includes your name, address and email address. This processing is necessary for marketing my services, which is a legitimate business interest.
- I will only send marketing information to you by email if I have obtained your consent. You have the right to withdraw your consent at any time. (See below).
- To send you communications required by law or which are necessary to inform you about changes to the services I provide you, for example, updates to this Privacy Statement, and any information legally required which relates to any contracts between us. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. This processing is necessary for us to comply with our legal obligations.
- To ask you, via email, for feedback or to complete an occasional survey to help improve my services, although you do not have to respond.
3.1. Sensitive Data
I do not gather any sensitive personal data on this website. However, I collect sensitive data through a confidential health questionnaire (medical history, current treatment and therapeutic issues you are seeking help with) for your initial appointment. This information is used to help me assess how I may best be of assistance to you in helping you realize your goals and objectives. You are free to skip any questions you do not wish to answer.
Your sensitive data is kept secure and confidential and is not shared. I will only divulge sensitive information where there is a legal duty for me to do so e.g. where the Children's Act applies or a court order is issued, or when there is good cause to believe that if I do not disclose information you or others would be exposed to a serious risk of harm.
When you use my services you consent to me keeping the information you give me for a minimum of seven years after your treatment finishes, which is the minimum length of time suggested by my professional body and insurance company. However, records may be kept longer if necessary for legal and insurance requirements.
My professional body's code of ethics also allows me to share anonymous case histories verbally or in professional publications for the purposes of supervision, professional development or training. Anonymous means your personal details are removed and no information that might identify you is used.
3.2. Protecting your own privacy
To protect your own privacy, be prudent in how you store treatment-related emails. Make sure they are protected from unauthorized access by using and guarding your passwords. Consider deleting any emails (sent or received) or chat transcripts that you do not want others to see, followed by emptying your trash or recycle bins. If you make hard copies of emails or chat transcripts, store them securely. Be aware that emails sent from a workplace computer are the property of the employer. Continue reading to see how I ensure your online confidentiality and privacy.
3.3. Children's information
This website is for information purposes and is not directed to children under 16. If you learn that a child under 16 has provided me with personal information without consent, please . Parents or guardians of children under 18, however, may contact me to enquire about my services for children.
3.4. Email, contact form or letter
When you make an enquiry about my services, records of your correspondence are kept. I also collect information that you provide by filling in forms on this website which includes requesting further services. I use this data to respond to your enquiries; to contact you if I need to obtain or provide additional information; to check my records are correct and to check every now and then that you're happy and satisfied or if you need extra support.
3.5. Third parties
I will never sell your data to any third parties. I will not share your information with any third parties for their own marketing purposes.
In some circumstances, I may need to share your data with the following to support the efficient running of my business:
- Accounting software company
- Email marketing distributor e.g. Mailchimp
- Cloud-based back-up service
If this is necessary, I will provide only the information they need to perform the services which are required and they will only use the data for the purposes I specify. I require third parties to maintain appropriate security to protect information from unauthorized access or processing.
In some circumstances, I may need to share your personal data with other third parties (including legal or other advisers, regulatory authorities, courts and government agencies) to enable me to enforce my legal rights, or where such disclosure may be permitted or required by law.
Unless I specify otherwise, your data will not be processed outside the EEA.
3.6. Payment transactions
3.7. Site analytics and cookies
Website analytics (Google) may collect details of your visits to this website including, but not limited to, traffic data, location data, web logs, your IP address, where available, operating system, browser type for statistical purposes and other communication data and the resources that you access and use. This is statistical data about your browsing actions and patterns, and does not identify any individual.
Like many other websites, cookies are used to collect statistics through Google Analytics. Cookies are small pieces of information that are stored on your computer or mobile device when you visit a website.
The following list outlines what cookies are used for:
- Google Analytics sets cookies to help accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that this website is responding to your needs in the best way possible.
4. Where is your personal data is stored?
I will take appropriate technical and organizational measures to protect the personal data I transmit, store or otherwise process against accidental or unlawful destruction, loss, alteration or unauthorized disclosure or access. My computers and mobile devices are password protected. Paper storage is locked securely.
5. What uses are made of the data?
- To provide you with information, products or services that you request from me.
- To provide you with with information about services or products similar to those which were the subject of a previous contract or sale to you (for existing clients).
- To provide you with other information relating to my services which I think may interest you where you have consented to be contacted for such purposes (e.g. newsletter).
- To carry out my obligations arising from any contracts entered into between you and me in the administration and delivery of my services.
- To notify you about changes to my service.
6. Disclosure of information
You have the right to ask me not to process your personal data for marketing purposes. I will inform you (before collecting your data) if intending to use your data for such purposes. You can choose not to opt-in in the case of receiving a request to subscribe. You can also exercise the right if you to opt out of any marketing communcations. You can unsubscribe from (Mailchimp) newsletters by click on the 'Unsubscribe' link.
This site may, from time to time, contain links to and from other websites or affiliates. If you follow a link to any of these websites, please note that they should have their own privacy policies and that I do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7. Controlling your information
7.1. Requesting a copy of your information
You may request a copy of any information you have given.
7.2. Updating or correcting your information
The accuracy of your information is important to me. If your contact details or any of the other information I hold is inaccurate or out of date, please so I can correct my records.
7.3. Deleting your information
In some circumstances, you may 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 I need to use that data to fulfil my contractual, professional or legal obligations), your personal data will be deleted on request.
7.4 Withdrawal of permission
You can withdraw your permission for me to use your information at any time, although it would mean terminating your treatment programme and excludes any instances where adherence to my professional and legal obligations is required.
7.5. Automated decision making
I do not use any personal information for automated decision making or profiling.
You have the right to object to your personal data being used for direct marketing (I will always ask for prior consent) or to stop it being used where it is being processed on the basis of legitimate interest, in which case I will do so unless I believe I have a legitimate overriding justification to continue processing your personal data.
If you wish to raise a complaint on how your personal information has been handled, you can directly and I will investigate the matter. If you are not satisfied with the response you can complain to the Information Commissioner's Office (ICO).