Privacy policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
1.2 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
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via.
2. Credit
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services. 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 consent. Our legitimate interests, namely monitoring and improving our website and services.
3.3 We may need to process your personal data in order to fulfil our contractual obligations to you. Informations such as counseling/wellbeing notes 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 interest in the proper administration of our website and business.

3.4 We may process information contained in any inquiry you submit to us regarding products and/or services(“usage data”). The inquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is the proper administration of our website and business.
3.5 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website. The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. 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 and our legitimate interests, namely our interest in the proper administration of our website and business.

3.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. 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 consent]

3.7 We may process information contained in or relating to any communication that you send to us. 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.
3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.
3.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose [your personal data] to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
4.3 We may disclose (“usage data”) to subcontractors insofar as reasonably necessary for proper administration of our website and business.
4.4 Financial transactions relating to our website and services may be handled by our payment services providers, including Mastercard, Visa, American Express and Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at the following;
(a) https://www.mastercard.us/en-us/about-mastercard/what-we-do/privacy.html
(b) https://usa.visa.com/legal/privacy-policy.html
(c) https://web.aexp-static.com/au/content/pdf/Credit_Card_Conditions.pdf
(d) https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may also 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.

5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 Our office is located in 489 Blandford road, Plymouth, PL36JF. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission.
5.3 The hosting facilities for our website are situated in the United Kingdom. The European Commission has made an “adequacy decision” with respect to [the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data
6.1 This Section 6 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.
6.2 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.
6.3 We will retain and delete your personal data as follows:
(a) Personal data category will be retained unless you specify that we delete such data. Please contact us [email protected] if you would like view or delete any information we have on you

6.4 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 on the following criteria:
(a) the period of retention of personal data category will be determined based on your request.
6.5 Notwithstanding the other provisions of this Section 6, 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.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy [by email or through the private messaging system on our website].
8. Your rights
8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.
8.2 We may withhold personal information that you request to the extent permitted by law.
8.3 You may instruct us at any time not to process your personal information for marketing purposes.
8.4 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.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) sent by a web server to a web browser and stored by a browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be “fixed” cookies or “session” cookies: permanent cookies will be stored by a web browser and remain valid until their expiration date, unless they are deleted by the user before the expiration date; On the other hand, the session cookie expires at the end of the user session when the web browser is closed.
9.3 Cookies usually do not contain any information that would allow you to identify the user, but the personal data we store may be associated with information stored in cookies and obtained from cookies.
10. Cookies we use
10.1 We use cookies for the following purposes:
(a) Authentication – we use cookies to identify the user when visiting our website and when navigating our site. Cookies used for this purpose are:[ cookie identification];
(b) Status – we use cookies to help us determine if you are logged in to our site. [cookies used for this purpose are: identify cookies[;
(c) Personalization – we use cookies to store information about your preferences and to personalize the website for you. cookies used for this purpose are: [identify cookies];
(d) Security – we use cookies [as part of security measures used to protect user accounts, including the prevention of fraudulent use of login data and in general to protect our site and services. Cookies used for this purpose are: [identify files] cookie];
(e) Advertisement – we use cookies to help us display ads that are important to you. Cookies used for this purpose are: [identify cookies];
(f) Analysis – we use cookies [to help us analyze the use and operation of our website and services. Cookies used for this purpose are: [cookie identification]; and
(g) Consent to the processing of cookies – we use cookies to store preferences related to the more general use of cookies. Cookies used for this purpose are: [cookie identification].

11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.1 Our service providers use cookies, and these cookies may be stored on your computer when you visit our site.
11.2 We may use Google Analytics to analyze the use of our website. Google Analytics collects information about the use of the website by means of cookies. The information collected on our website is used to create reports on the use of our website. The Google privacy policy is available at: https://www.google.com/policies/privacy/. [The appropriate cookie files include: [identify cookies].
11.3 We may use Facebook as a marketing tool(Facebook Ads). This service uses cookie-like code called Facebook pixel for Ads retargeting.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
[additional list items]
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details
13.1 This website is owned and operated by Frances Rayner-Devon Holistic Therapies.
13.2 We are registered in England and Wales as a sole trader and our registered office is at 489 Blandford road, Plymouth, PL36JF.
13.3 Our principal place of business is at 489 Blandford road, Plymouth, PL36JF.

14. Contact Us
(a) Using our website contact form
(b) by telephone, on the contact number published on our website from time to time; or
(c) by email, using the email address published on our website from time to time.