Privacy Policy

IN PLAIN ENGLISH
I only collect the minimal amount of personal information to process your order or send you resources you’ve signed up for. I absolutely respect your privacy and only keep what I require and keep it secure. I do not pass this on or sell it to any 3rd party.

For completeness here’s my privacy policy in full.

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INTRODUCTION
This privacy policy provides you with details of how we collect and process personal data through the use of this site. This includes any information you may provide through the site when you purchase a product or register for the free resources.

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

Lucinda Leo is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

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Contact Details
Lucinda Leo, Giraffe Life Cognitive Hypnotherapy
Address: 37 Highcroft Villas, Brighton BN1 5PS. If you are not happy with any aspect of how we collect and use your data please contact us so we can try and resolve it for you.  The UK supervisory authority for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk).

DATA HELD
I hold and use data in order to provide support, treatment and advice. Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process certain types of personal data as follows:

Identity Data may include first name, maiden name, last name, marital status, title, date of birth and gender.
Contact Data may include home address, delivery address, email address and telephone numbers.
Marketing and Communications may include preferences in receiving marketing communications from us.
Transaction Data may include details about financial payments made by our customers & clients.
Technical Data may include internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Usage Data may include information about how people use our website, products and services.
Aggregated Data.  We may also process aggregated data but this does not reveal people’s identity and as such in itself is not considered personal data. An example of this is where we review website visitors usage to work out the percentage of visitors using a specific feature of our site.
HOW DATA IS COLLECTED
We collect data about you through a variety of different methods including:

Direct interactions:  You may provide data by completing the contact form or subscribe forms on our website.
Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
Website analytics providers such as Google based outside the EU;
Internet search providers based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Paypal based outside the EU.
We will only use your personal data where legally permitted. The most common uses of your personal data are:

Where we need to perform the contract between us.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
USES OF DATA
Set out below is a description of the ways we may use personal data and the legal grounds on which we will process such data.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.

DELIVERY SERVICES
To process and deliver our services including managing payments for the purpose of performance of a contract.
To manage our relationship with you which may include notifying you about changes to our terms or privacy policy or asking you to leave a review (identity;  contact;  marketing and communications) for the purpose of performance of a contract with you, to comply with a legal obligation, or for our legitimate interests to keep our records updated and to study how customers use our products/services.
To administer and protect our business and our site including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, (identity;  contact;  technical) for the purpose of our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and to comply with a legal obligation.
To deliver relevant content to you. 
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (technical; usage) for the purpose of  our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy.
To make suggestions and recommendations to you about goods or services that may be of interest to you (identity; contact; technical; usage; profile) for the purpose of our legitimate interests to develop our products/services and grow our business.
MARKETING COMMUNICATIONS
You may receive marketing communications from us if you have:

Purchased goods or services from us; or
provided us with your details when you registered for a free resources; and
in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by using our unsubscribe links on any marketing message sent to you or replying to any email we send.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a providing a service to you as a client/customer.

CHANGE OF PURPOSE
We will only use personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

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

DISCLOSURES OF PERSONAL DATA
We may have to share personal data with the parties set out below for the purposes set out in how we use your personal data:

Service providers who provide IT and system administration services.
Professional advisers including lawyers, accountants and insurers who provide services to us.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We require all 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. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS
Some of our third parties service providers are based outside the European Economic Area so their processing of personal data will involve a transfer of data outside the EEA.

Whenever we transfer personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Where we use certain service providers, 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 Europe; or
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time

DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.

There is no charge 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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month.

THIRD PARTY LINKS
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.

WEBSITE COOKIES
Please see our Cookie Policy here.