Privacy Policy:

Introduction

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This Privacy Notice provides you with details of how we collect and process your personal data through your use of our site www.lucypaltnoi.com and when receiving services from us.

 

By providing us with data, you warrant to us that you are over 13 years of age.

 

Connecting Insight Limited is the data controller and responsible for your personal data (referred to as “we”, “us” or “our” in this Privacy Notice).  We are registered with the Information Commissioner’s Office (ICO: Registration No. Z242599X).

 

Contact Details

Full name of legal entity: Connecting Insight Limited

Registered address: 85 Woodfield Drive, East Barnet, Barnet EN4 8PD

Email address: lucy@lucypaltnoi.com

Data Protection Officer: Lucy Paltnoi

 

1.         How we use your personal data

1.1 Personal data means any information capable of identifying an individual. We are committed to protecting your personal data, as set out in this Privacy Notice. It is a condition of any coaching, advisory and/or complementary therapy consultations or treatments (“Services”) that you give your explicit consent to us documenting and processing your personal data in the manner described below, and in accordance with all applicable legislation.

 

1.2 The personal data we collect from you is as submitted by you via our website, by email, in response to questionnaire(s) and the data you provide us during telephone calls, by email or during the provision of our Services. Records and case notes of your consultations and our discussions will be kept, for efficient and careful practice.  We may automatically collect certain data from you as you use our website by using cookies and similar technologies.  Please see our cookie policy for more details about this.

 

1.3 Personal Data:  We will use your non-sensitive personal data to (a) register you as a new client, (b) manage payment (c) in the provision of our services to you and to manage our relationship with you, for example, to send you appointment reminders or information concerning your consultations/treatments, (d) collect and recover monies owed to us where applicable,  (e) send you details of our goods and services which we believe may be of interest to you and (f) if we promote other practitioners, who may not be connected to us in any way. Our legal grounds for processing your data in relation to points (a), (b), (c), (d) and (f) in this paragraph are for performance of a contract with you in the course of provision of Services, and in relation to points (b), (c), (d), (e) and (f) as may be necessary for our legitimate interests to develop our products/services, to respond to  enquiries relating to our services and grow our business and to recover monies owed.

 

1.4 Sensitive Data: We will use your sensitive personal data (that is data submitted by you which may include your personal information revealing detailed health information (such as background information relevant to your presenting problem, details of mental and physical health issues, information about any health or social care you have received from other providers such as GPs, counsellors or hospitals, details of medications administered, information about family relationships and early child development, and any session notes and assessments), racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic information, biometric information and information about sex life or orientation) via our website, by email, in response to questionnaire(s) and the data you provide us during telephone calls, by email or notes made during the provision of Services), for the purposes of providing our services to you or if we need to comply with a legal obligation. We will only collect what is relevant and necessary for your consultations/treatments. Our legal ground of processing this data is your explicit consent for us to do so, so that we can provide you with our services.   We will send you a further communication asking for you to confirm your consent to this processing.

 

1.5 User Data: We will collect and process data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

 

1.6 Marketing Data: We will collect and process data that includes data about your preferences in receiving marketing from us and your communication preferences. We process this data to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.  Under the Privacy and Electronic Communications Regulations, we will only provide you with marketing communications from us if (i) you made a purchase or asked for information from us that is relevant to our business or services or (ii) you specifically agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.   If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases.  As a provider of Services, we need to carry out these marketing services but are mindful of your rights and expectations in that regard. 

 

1.7 We will not share your details with third parties for marketing purposes except with your express consent. If we ask for your consent to use your personal information for marketing purposes you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. Please contact us if you would like to withdraw any consent given.

 

1.8 Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver our services to you). If you don’t provide us with the requested data, we will have to terminate our service for you as we are unable to practice without this information.

 

1.9 We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email lucy@lucypaltnoi.com.  In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

 

1.10 We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

1.11 We do not carry out automated decision making or any type of automated profiling.

 

2.         Disclosure of your personal data

2.1 We may have to share your personal data with (i) service providers who provide IT and system administration support, (ii) professional advisors including accountants, lawyers, bankers, auditors, insurers and/or in connection with the recovery of any unpaid fees (iii) HMRC and other regulatory authorities (iv) third parties to whom we sell, transfer or merge parts of our business or our assets, (v) to other professionals for the purposes of discussing our Services to you, (vi) to any relevant supervisory coach/training organisation, as part of training (and you will have been previously informed by us about such training) and/or (vii) to  investigate, detect,  prevent  or  mitigate any potential or actual fraud,  security  or  technical  issues; or  to  protect  against imminent  harm  to  the  rights,  property  or  safety  of  its  staff.

 

2.2 We may have to share your data with online video provider such as Zoom or Microsoft Teams.  You will need to check their respective privacy policies before utilizing their service.

 

2.3 We require all such third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data on our instructions.


 

3.         International Transfers

3.1 Some of our third party providers may be businesses outside of the UK and EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within the UK and EEA.

 

3.2 We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK and EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

 

• We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data by; or

• If we use US-based providers that are part of UK regulator approved privacy framework we may transfer data to them, as they have equivalent safeguards in place; or

• Where we use certain service providers who are established outside of the UK and EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in the UK and EEA.

3.3 If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

 

4.         Data security

4.1 We take your privacy very seriously and have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.

 

4.2 In certain circumstances you can ask us to delete your data. See the section entitled ‘your rights’ below for more information. We also may anonymise your personal data (so that you can no longer be identified from such data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

5.         Data retention

5.1 We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, insurance, regulatory body or reporting requirements, so for example we need to keep certain information about you for at least 8 years, and may be retained indefinitely, after you cease to be a client in order to comply with legal guidelines.  You have the right to ask us to delete the personal data we hold about you in certain circumstances. See section 6 below.

 

5.2 Where personal information is shared in an enquiry and you do not take up any of our services, all personal and sensitive data will be deleted.

 

6.          Your rights

6.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.

 

6.2 You have the right to:

 

6.2.1     Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

6.2.2     Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

6.2.3     Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

6.2.4     Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

6.2.5     Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

6.2.6     Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

6.3        Where we are relying on consent to process your personal data, you may withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

6.4        If you wish to exercise any of the rights set out above, please contact us at lucy@lucypaltnoi.com.

 

6.5        You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

6.6        We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

6.7        We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

7.         Third-Party Links

7.1 This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

8.         Cookies

8.1 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

 

9.          Keeping your data up to date

9.1 Where we have a duty to keep your personal data up to date and accurate then from time to time we will contact you to ask you to confirm that your personal data is still accurate and up to date. If there are any changes to your personal data (such as a change of address) please let us know as soon as possible by emailing the address set out at the beginning of this Privacy Notice.

 

10.         Complaints

10.1 We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However we would be very grateful if you would please contact us first if you do have a complaint, so that we can try to resolve it for you in the first instance.

 

CONNECTING INSIGHT LIMITED, 2022
 

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