The therapist (here, Xzarina Nicholson) collects Personal Data from her Client/s.

OWNERS & DATA CONTROLLER/S

Xzarina Nicholson (contact email: xzarinanicholson@gmail.com)

TYPES OF DATA COLLECTED

Among the types of Personal Data collected are name, date of birth, address, contact details, significant medical history, and third party emergency contact details. In addition, and as part of the Service provided by the therapist through Client engagement, additional personal information is routinely gathered and may form part of a client-specific record.


Unless specified otherwise, all Data requested by the therapist is mandatory. Failure to provide this Data may make it unfeasible to provide the contracted Service. In cases where we specifically state that some Data is not mandatory and therefore optional, the Client is free not to provide this Data without consequences to the availability or the functioning of the Service. A Client who is uncertain about which Personal Data is mandatory and what the purpose for the collection of that data is can seek clarification from the Therapist.


The Client is responsible for any third-party Personal Data obtained and he/she confirms that they have the third party's consent to provide the Data to the Owner.

MODE/PLACE OF DATA PROCESSING DATA & METHODS OF PROCESSING

The Therapist takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
 Data processing is carried out using paper copy, computers and/or IT enabled tools, in accordance with organisational procedures and modes strictly related to the purposes indicated.

In addition to the Therapist, in some cases, the Data may be accessible to other persons involved in the day-to-day administration or system administration of the Service or external parties (such as third-party technical service providers, accountants, mail carriers, hosting providers, IT companies). If required and necessary, these parties may act as Data Processors on behalf of the Therapist. Strict measures will be taken to ensure that only information relevant to that function is shared, to ensure that confidentiality is not breached and data is processed securely.

LEGAL BASIS OF PROCESSING

The Therapist may process Personal Data if one of the following applies:

the Client has given their consent for one or more specific purposes. (*NB: Under some legislations, the Therapist may be allowed to process Personal Data until the Client objects to such processing (“opt-out”); (

ii) provision is necessary for the performance of an agreement with the Client and/or for any pre-contractual obligations thereof;

(iii) processing of Data is necessary for compliance with a legal obligation to which the Therapist is subject;

(iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owners; and

(v) processing is necessary for the purposes of legitimate interests pursued by the Therapist or a third party.

In any case, the Therapist will clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

PLACE

The Data is processed at the Therapist’s business/operating address and in any other places where the parties involved in the processing are located. 

Depending on the Client's location, data transfers may involve transferring the Client's Data to a country other than their own.

A Client is entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, a Client can request more information from the Therapist.

DATA RETENTION TIME

Personal Data shall be processed and stored for 7 years for the purpose they have been collected for and will be destroyed when this period has lapsed. Therefore:

Personal Data collected for purposes related to the performance of a contract between the Therapist and the Client shall be retained until such contract has been fully performed and for a period of 7 years thereafter.

Personal Data collected for the purposes of the Therapist’s legitimate interests shall be retained as long as needed to fulfil such purposes. The Client may find specific information regarding the legitimate interests pursued by contacting the Therapist.

The Therapist may be allowed to retain Personal Data for a longer period whenever the Client has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Therapist may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.


Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

THE PURPOSES OF PROCESSING

The Data concerning the Client is collected to allow the Therapist to provide her Services. The data held is for the Therapist's use only and will not be shared with another party without consent from the Client.

The Client can request further detailed information about such purposes of processing and about the specific Personal Data used for each purpose.

CLIENT RIGHTS

The Client may exercise certain rights regarding their Data processed by the Therapist. In particular, the Client has the right to do the following: (i) Withdraw their consent at any time -- the Client has the right to withdraw consent where they have previously given their consent to the processing of their Personal Data; (ii) Object to processing of their Data -- the Client has the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent; (iii) Access their Data -- the Client has the right to learn if Data is being processed by the Therapist, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing; (iv) Verify and seek rectification -- the Client has the right to verify the accuracy of their Data and ask for it to be updated or corrected; (v) Restrict the processing of their Data -- the Client has the right, under certain circumstances, to restrict the processing of their Data. In this case, the Therapist will not process their Data for any purpose other than storing it; (vi) Have their Personal Data deleted or otherwise removed -- the Client has the right, under certain circumstances, to obtain the erasure of their Data from the Owners; (vii) Receive their Data and have it transferred to another controller -- the Client has the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the Client's consent, on a contract which the Client is part of or on pre-contractual obligations thereof; (viii) Lodge a complaint -- the Client has the right to bring a claim before their competent data protection authority.

DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Therapist or for the purposes of the legitimate interests pursued by the Therapist, a Client may object to such processing by providing a ground related to their particular situation to justify the objection. The Client must know that, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.

HOW TO EXERCISE THESE RIGHTS

Any requests to exercise a Client’s rights can be directed to the Therapist through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Therapist as early as possible and within one month.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING LEGAL ACTION

The Client's Personal Data may be used for legal purposes by the Therapist in Court or in the stages leading to possible legal action arising from improper use of the related Services. The Client declares to be aware that the Therapist may be required to reveal personal data upon request from public authorities. 

ADDITIONAL INFORMATION ABOUT CLIENT PERSONAL DATA

In addition to the information contained in this privacy policy, the Therapist may provide the Client with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request. 

INFORMATION NOT CONTAINED IN THIS POLICY

More details concerning the collection or processing of Personal Data may be requested from the Therapist at any time. Please see the contact information elsewhere in this document. 

CHANGES TO THIS PRIVACY POLICY

The Therapist reserves the right to make changes to this privacy policy at any time by giving notice to the Client and within this Service and/or - as far as technically and legally feasible - sending a notice to a Client via any contact information available to the Therapist. Should the changes affect processing activities performed on the basis of the Client ’s consent, the Therapist shall collect new consent from the Client, where required. 

DEFINITIONS AND LEGAL REFERENCES 

'Personal Data' or 'Data': Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

'Client': The individual using this Service who, unless otherwise specified, coincides with the Data Subject.

'Data Subject': The natural person to whom the Personal Data refers.

'Data Processor' or 'Data Supervisor': The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller [or Owner], as described in this privacy policy.

'Data Controller' (or 'Therapist'): The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Service. The Data Controller, unless otherwise specified, is the Owner of this Service (i.e. the Therapist).

'Service': The service provided by the Therapist, as described in the terms agreed with the Client.

'European Union' (or 'EU'): Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area. 

'Legal information': This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Service, if not stated otherwise within this document.