PRIVACY POLICY

Introduction
We are committed to safeguarding the privacy of our visitors. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. By using our website, you are agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. In this policy, “we”, “us” and “our” refer to Nirvana Counselling. For more information about us, see Section 7.

How we use your personal data

In this Section 2 we have set out the general categories of personal data that we may process; in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; the purposes for which we may process personal data; and the legal bases of the processing.

We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed [for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely [monitoring and improving our website and services.

We may process your account data (“account data“). The account data may include your name, postal address, phone number, email address and payment details. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person’s personal data to us unless we prompt you to do so.

Providing your personal data to others
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Retaining and deleting personal data
This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

• usage data will be retained for a minimum period of 12 Months and for a maximum period of 36 months.
• account data and transaction data will be retained for a minimum period of 60 Months after the 31 January of the relevant tax year.
• notification data and publication data will be retained for a minimum period of 12 Months or until you request for the data to be removed.
• enquiry data and correspondence data will be retained for a Maximum period of 24 Months.

In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based the needs of the business and individual.

Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Amendments
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.

Your rights
You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

• the supply of appropriate evidence of your identity

We may withhold personal information that you request to the extent permitted by law. You may instruct us at any time not to process your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

Our details
Nirvana Counselling, Samantha Robinson, Nirvana Close, Ivybridge, Devon (‘we’ or ‘us’).

We’re the data controller in respect of all personal data collected via Nirvana Counselling website, email, telephone, or in person. Whenever you submit your information to us, by these or any other means, we’ll only collect and use this information in accordance with the terms of this policy and ensure that all personal data we hold is treated properly and in accordance with GDPR and all other applicable data protection legislation.

If you have any concerns about the way we’ve used, shared or processed your data you have the right to lodge a complaint, so please contact us by email at samantha@nrivanacounselling.co.uk or by writing to Data Officer, Nirvana Counselling, Nirvana Close, Ivybridge, Devon, PL21 0AP