PRIVACY POLICY

Website Terms of Use

Use of this Website
1. These terms and conditions (“Terms”) govern your participation in and use of these websites: https://annabeldevinetherapy.co.uk and https://annabeldevinetherapy.com (“Websites”) operated by Annabel Devine (“we”).
2. This Website is provided to you for your personal use, subject to these Terms. Please read these terms carefully as they affect your rights and obligations under the law.
3. If you do not agree to these Terms in full, please do not register with us or otherwise continue using the Website. By using this Website, you agree to be bound by these Terms.
4. You are responsible for ensuring that all persons who access our Website through your internet connection are aware of these Terms and that they comply with them.
5. Please note that these Terms may be amended from time to time. Notification of any changes will be made by posting new terms onto the Website. In continuing to use the Website you confirm that you accept the then current terms and conditions in full at the time you use the Website.

Registering with the Website

1.1 You may be required to register to enable you to access certain sections of the Website. When you register to use the Website, we may ask for some of your personal information. Any personal information you provide us with will be handled in accordance with our Privacy Notice.

1.2 If you register to use the Website you will be asked to create a password. In order to prevent fraud, you must keep this password confidential and must not disclose it or share it with anyone. If you know or suspect that someone else knows your password you should notify us immediately.

1.3 If we have reason to believe that there is likely to be a breach of security or misuse of the Website through your account or the use of your password, we may require you to change your password or we may suspend your account.

Intellectual property

1.1 The content of this Website is protected by copyright, trademarks, database right and other intellectual property rights. You may retrieve and display the content of this Website on a computer screen, store such content in electronic form on disk (but not any server or other storage device connected to a network) or print one copy of such content for your own personal, non-commercial use, provided you keep intact all and any copyright and proprietary notices. You may not otherwise reproduce, modify, copy, distribute or use for commercial purposes any of the materials or content on this Website without our written permission.

Availability of this Website

1.1 Although we aim to offer you the best service possible, we make no promise that the services on this Website will meet your requirements, be available at all times or be error-free. If a fault occurs with this Website you should report it to us and we will attempt to correct the fault as soon as we reasonably can.

1.2 Your access to this Website may be occasionally restricted to allow for repairs, maintenance or the introduction of new facilities or services. We will attempt to restore the service as soon as we reasonably can. Access to the Website may be restricted whether or not you have registered with us.

Our liability

1.1 This Website may provide content from other internet websites or resources and while we try to ensure that material included on this Website is correct, reputable and of high quality, we do not make any warranties or guarantees in relation to that content. If we are informed of any inaccuracies in the material on the Website, we will attempt to correct the inaccuracies as soon as we reasonably can.

1.2 If we are in breach of these Terms, we will only be responsible for any losses that you suffer as a result to the extent that they are a foreseeable consequence to both of us at the time you use this Website. Our liability shall not in any event include business losses such as lost data, lost profits or business interruption.

1.3 Commentary and other materials posted on this Website are not intended to amount to advice on which reliance should be placed. We shall not be liable for any losses that may be incurred by you or any visitor to this Website or by anyone who may be informed of any of its contents as a result of any reliance placed on such materials.

1.4 Nothing in these Terms will limit our liability for death or personal injury caused as a result of our negligence, fraud, or any other liability which cannot be limited or excluded by law.

Use and abuse of the Website

1.1 You may use the Website for your personal, information purposes only.

1.2 You must not misuse our Website by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, the server on which our Website is stored or any server, computer or database connected to our Website. You must not attack our Website via a denial-of-service attack or a distributed denial-of service attack.

1.3 We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any website linked to it.

1.4 We reserve the right at our discretion to remove any content from the Website, terminate your registration and/or restrict your access to our Website at any time for any reason.

Third-Party Websites

As a convenience to you, this Website includes links to other websites or material. We are not responsible for content on any site outside of this Website so if you do follow a link to any of these sites, you acknowledge you do so at your own risk and we will not be liable or otherwise be responsible in any way in relation to this.

General

1.1 You shall comply with all foreign and local laws and regulations which apply to your use of our Website in whatever country you are physically located.

1.2 You may not transfer any of your rights under these Terms to any other person. We may transfer our rights under these Terms to another business where we reasonably believe your rights will not be affected.

1.3 If you breach these Terms and we choose to ignore this, we will still be entitled to use its rights and remedies at a later date or in any other situation where you breach the Terms.

1.4 We will not be responsible for any breach of these Terms caused by circumstances beyond our reasonable control.

1.5 These Terms will be subject to the laws of England and Wales. We will try to solve any disagreements quickly and efficiently. If you are not happy with the way we deal with any disagreement and you want to proceed to court proceedings, you must do so within the United Kingdom.

1.6 This Website is owned and operated by Annabel Devine.

If you have any questions about these Terms, please contact us at our contact form on the Website.

This wording was purchased from Private Practice Paperwork Ltd. and no part of it may be copied, shared or published elsewhere without direct purchase and authorisation from their website.

Privacy Notice

General

1.1 Our Organisation Annabel Devine (“we” or “us”) is registered with the Information Commissioner’s Office (“ICO”) under registration number Z3531955. We take the privacy of your information very seriously and this Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal data which may be obtained via our website or other means including online forms, email, or phone.

1.2 In this notice “you” refers to any individual whose personal data we hold or process (but it does not relate to personal data relating to our employees or staff).

1.3 In general, we provide counselling and psychotherapy services. If we do provide such services to you, please note a separate privacy policy for clients will apply and will be provided to you. We do not process personal data on a large scale, but we will hold and process personal data in order to supply our services and this privacy notice explains how we do so.

1.4 This notice is governed by the EU General Data Protection Regulation (the “GDPR”), UK GDPR, Data Protection Act 2018 and any other applicable data or privacy legislation. For the purposes of this notice, “UK GDPR” means the GDPR as such regulation is adopted into the law of the United Kingdom pursuant to the European Union (Withdrawal Act) 2018 and as amended by the Data Protection Act 2018 and any successor regulation or law.

Categories of Personal Data and Legal Basis

1.1 Below we have set out the categories of data we collect and how we process the data (for information about legal basis, please see below):

we will hold contact information for our users who have registered with us, such as name, email address and telephone number (for authentication) (“Contact Information”) which we will use to provide our services and communicate with you;

we may hold certain financial information of yours, such as bank account details, in order for us to provide a refund if we have had to cancel services already paid for, and this has been agreed (“Financial Information”);

a record of any correspondence or communication between you and us (“Communication Information”) which we will use to provide our services and communicate with you;

we will hold “Cookie Information”. A cookie is a small text file, which asks permission to be placed on your computer’s hard drive or mobile device. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. We use Cookie Information to analyse and improve our services or in order to customise the website according to your personal interests;

1.2 We process Contact Information, Financial Information and Communication Information on the basis of the performance of our contract with our client and on the basis of consent.

2. We process Cookie Information on the basis you have consented to the use of cookies.

2.1 Generally, we will collect information directly from you. If we obtain your personal data from any other third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.

2.2 You do not have to supply any personal data to us however in practice we may be unable to provide our services to you without personal data (for instance we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but there are circumstances in which we may need to continue to process personal data (please see below).

Data retention

1.1 Our current data retention policy is to delete or destroy (to the extent we are able to) personal data in accordance with the following retention periods:

Information relating to our website users

We will hold information for registered users for 7 years from the date on which we collect the data, or, if later, from the date on which you cease to be a registered user.

We will hold information for non-registered users (for example users who have emailed through the website but do not become clients) for 3 months from the date on which we collect the data.

1.2 The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

1.3 We review the personal data (and the categories of personal data) we hold on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required.

1.4 If you wish to request that data we hold about you is amended or deleted, please see section 8 below, which explains your privacy rights.

Sharing your information

1.1 We do not disclose any information you provide to any third parties other than as follows:

1.1.1 From time to time we will transfer personal data to our sub-processors which will include Kiku (a confidential web hosting site for case notes and client information)

1.1.2 we may be required to disclose certain data to regulators or other lawful authorities;

1.1.3 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example if required to do so by a Court order or for the purposes of prevention of fraud or other crime);

1.1.4 in order to enforce any terms and conditions or agreements for our services that may apply;

1.1.5 if we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;

1.2 Other than as set out above, we shall not disclose any of your personal data unless you give us permission to do so. If we do supply your personal data to a third party, we will take reasonable steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

Security

5.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage.

Like most websites, we use cookies to help provide you with the best experience whilst using our service. A cookie is a piece of data stored locally on your computer or mobile device and contains information about your activities on the Internet. It helps you get the best out of the website and helps us to provide you with a more customised service.

If you choose not to accept or disable certain cookies, this will not affect your access to the majority of information available on our website however certain online services may not be available.

Your privacy rights

1.1 With respect to your personal data, you have the right to:

1.1.1 request that your personal data will not be processed;

1.1.2 ask for a copy of any personal data that we have about you;

1.1.3 request the correction of any errors in or update of the personal data that we have about you;

1.1.4 request that your personal data will not be used to contact you for direct marketing purposes;

1.1.5 request that your personal data will not be used for profiling purposes;

1.1.6 request that your personal data will not be used to contact you at all;

1.1.7 request that your personal data be transferred or exported to another organisation, or deleted from our records; or

1.1.8 at any time, withdraw any permission you have given us to process your personal data.

1.2 All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below.

1.3 We will endeavour to comply with such requests as soon as reasonably possible but in any event, we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data breaches

1.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager and/or the ICO as is deemed necessary.

If a breach is likely to result in a high risk to your data rights and freedoms, we will notify you as soon as reasonably possible.

Transferring your information outside the UK or EEA

We will not transfer your personal data in a systematic way outside of the European Economic Area or UK but there may be circumstances in which certain personal information is transferred outside of the European Economic Area or UK. For instance, from time to time some of our data processors or server providers may be based outside of the UK or EEA, if that is the case then we will ensure that we have an agreement with such processors or service providers to provide adequate safeguards and a copy of such agreements will be available on request;

If you access the services whilst outside of the UK or EEA, your information may be provided outside of the UK or EEA in order to provide you with our services;

We may communicate with parties outside of the UK or EEA, in providing our services. Those communications may include personal information (such as contact information).

2.1 If we transfer your information outside of the European Economic Area or UK, and the third country or international organisation in question has not been deemed by the EU Commission or Secretary of State (as the case may be) to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

Notification of changes

We will post details of any changes to our privacy notice on our website. Please ensure you check the website regularly for any updates.

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so by contacting us at annabeldevinetherapy@gmail.com

Complaints

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the ICO by visiting http://www.ico.org.uk/ for further assistance.

This wording was purchased from Private Practice Paperwork Ltd. and no part of it may be copied, shared or published elsewhere without direct purchase and authorisation from their website.