This privacy policy explains what personal data is, the types of personal data PATH Counselling collect, the purposes for which this data is collected and how it is processed, as well as what rights you have. You can be rest assured that any data we collect will be handled with care and security.

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1. What is personal data?

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This is any information relating to an individual. This includes your contact information, clinical data and any other information collected i.e from our referral form or other methods whilst you are with our service.

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2. General principles for personal data processing by pathcounselling.co.uk

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The following principles are followed when processing your data:

 

• Personal data is only collected for specified, explicit and legitimate purposes.

• Personal data beyond what is necessary will not be kept to accomplish these purposes.

• Personal data will not be used for purposes other than the reason which the data was collected, except as stated herein, or with prior informed consent

• The transfer of personal data to third parties, except as stated herein, or with prior consent.

• PATH Counselling aim to ensure that information is up to date by encouraging you to verify and update your personal data every so often.

• PATH Counselling will maintain appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing

• Except when stated herein, PATH Counselling will not store personal data longer than necessary to accomplish the purpose for which the data were collected, or for which they are processed, or as is required by law

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3. The personal data we collect and process

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The following data about you may be collected and processed.

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• Data you give us:

This is information given to us through filling in necessary documentation required by PATH Counselling, or by corresponding with us by phone, email or otherwise. This includes information you provide when you request or receive therapy and participate with our social media at your own accord. The information you give us may include your name, address, email address and phone number, financial and credit card information, personal and relevant history.

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• Data we collect about you:

With regard to each of your visits to our site we may automatically collect the following data:

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1. Technical data, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

2. Your behaviour information collected via he use of cookies and similar technologies like pixels, tags and other identifiers to remember your preferences, to understand how our website is used and to customise our marketing offerings; data about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages you viewed; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us.

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• Data we receive from other sources:

We may receive data about you from third parties we work closely with (including, without limitation, medical practitioners, payment and delivery services, analytics providers, search information providers).

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4. How do we use your personal data?

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We use the personal data held about you in the following ways:

 

• Data you give to us:

This will be used to:

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1. Carry out our obligations arising from any contracts entered into between you and us relating to therapy, and to provide you with the information and services that you request from us.

2. Process payments for our services.

3. Confirm your scheduled appointment and to send you a reminder before the start of your session.

4. Provide you with information about goods or services we feel may interest or benefit you. If you are an existing client, we will only contact you by electronic means (email or SMS) with information about services you have previously received or enquired about.

5. Notify you about changes to our service.

6. Ensure that content from our website is presented in the most effective way possible for you and your computer

7. Anonymise data which may be used for research purposes.

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• Data we collect about you:

We will use this data:

 

1. To administer our site for internal operations including troubleshooting, data analysis, testing, research statistical and any survey purposes.

2. To improve our site to ensure that content is presented most effectively for you and for your computer

3. To allow you to participate in interactive features of our service when you choose to do so.

4. As part of our efforts to keep our site safe and secure.

5. To measure or understand the effectiveness of marketing we serve to you and others, and to deliver relevant marketing to you.

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• Data we receive from other sources: 

We may combine this data with data you give to us and data we collect about you. We may use this data and the combined data for the purposes set out above.

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5. Where we store and process your personal data

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As a general principle, your personal data is stored and processed within the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff maybe engaged in, e.g the processing of your payment details and among other things. By submitting your personal data, you agree to this transfer,
storing or processing. In case of transfer of your personal data to any third countries, as defined in General Data Protection Regulation (GDPR), applicable legislation and regulations concerning such transfers are observed and relevant legal and security safeguards are ensured before such transfer. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted with the use of PayPal business (if you opt for this payment method).

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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6. Our disclosure of your personal data to third parties

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As a general principle, we collect and process data to facilitate or improve our services or offers. We do not sell your personal data or share the said data with third parties, except to the extent stated in this Privacy Policy.

We may disclose your personal data to third parties to the extent required by law, court order or a decision rendered by a competent public authority and law enforcement. We may also share your personal data with the following third parties:

 

• Medical or therapy practitioners to further a contract between us and you for the running of your therapy sessions. 

• Third-party vendors carrying out services on our behalf, including billing, sales, marketing, IT support, advertising, analytics, research, customer service, data storage, validation, security, fraud prevention, payment processing, and legal services. Such third-party vendors have access to perform these services but are prohibited from using your personal data for other purposes.

• Third parties to establish, exercise or defend legal rights of Path Counselling Ltd.

• Third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Path Counselling Ltd. assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).

• Other third parties subject to your consent.

When we disclose your personal data to a third party, we take all reasonable steps to ensure that those third parties are bound by confidentiality and privacy obligations concerning protection of your personal data. The disclosure is conducted in compliance with legal requirements, including entering into data processing agreements with the relevant third parties, to ensure that personal data is only processed in accordance with our instructions, applicable law and regulations and for the purpose specified by us and to ensure adequate security measures.

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7. Retention of your personal data

Access to our site is made available free of charge, although services are charged for and must be enquired about further to ensure it is right for you. We keep your information for no longer than necessary for the purposes for which it is collected.

 

Personal data related to our services is kept and processed for a period of seven to ten (7-10) years from the last date of service; unless such data is legitimately processed for other purposes, such as providing you with personal benefits or customised direct marketing upon your consent or for pursuing our legal claims, where maintaining such information is considered necessary.

 

Personal data related to our provision of direct marketing to you is kept and processed for a period of five (5) years from the date you last have been active in opening our marketing communication or otherwise showing interest in such communication.

 

Personal data related to your use of our site or our apps is kept and processed for a period of five (5) years from the date you last have been active in using our site.

 

Relevant personal information will be deleted after expiry of the above-mentioned periods unless such data legitimately can be kept and processed for other processing purposes which we have a legal basis for.

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8. Cookies

We use cookies and similar technologies like pixels, tags and other identifiers to remember your preferences, to understand how our site and our apps are used and to customise our marketing offerings.

A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (1) recognise your computer; (2) store your preferences and settings; (3) understand the web pages of www.pathcounselling.co.uk; (4) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (5) perform searches and analytics; (6) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are
stored with your Adobe Flash Player files. Pixels are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to; (1) collect usage information like ad impressions or clicks and e-mail open rates; (2) measure the popularity of advertising; and (3) access user cookies.

As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. You can also manage the use of Flash technologies, including Flash cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings on our site or our apps. For example, to complete a purchase on our site, you will need to accept cookies sent by our site.

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YOUR RIGHTS

9. Access to your personal data and data portability

You have the right to access the personal data concerning you which you have provided to PATH Counselling Ltd. in a structured, commonly used and machine-readable format and have the right to transmit those data to any third party you should choose to.

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10. Updating and/or deleting your personal data

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We encourage you to update your personal data provided to PATH Counselling Ltd. any time there are changes in your personal data. Your personal data can be deleted from our servers unless we are entitled or obliged by applicable law and regulations to keep and process such information regardless of the withdrawal of your consent. Following your request for deletion of your personal data, these will be deleted from our servers without undue delay; please note it may take a period of up to two (2) months to ensure complete deletion of any information stored in our back-up. You may also contact us to review, update or delete personal data stored about you. Please note that before accessing and requesting changes to your data, we will need to verify your identity properly.

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12. Right to withdraw your consent

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Some of our processing activities may be based on your consent. In these situations, you will have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of processing conducted prior to the withdrawal.
If you withdraw your consent, PATH Counselling Ltd. and third parties involved in personal data processing will cease to process your personal data, unless and to the extent the continued processing or storage is permitted or required according to the applicable personal data legislation or other applicable laws and regulations. Please note that as a consequence of your
withdrawal of your consent, PATH Counselling Ltd. may not be able to meet your requests or provide you with our services.

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13. Right to restriction of processing and right to object

You have the right to restrict processing of your personal data if the personal data is not correct, or if the processing is unlawful if you oppose the erasure of your personal data if we no longer need your personal data for processing but storing such data is requested by you for the establishment, exercise or defence of legal claims, or if you have objected to processing and verification and a decision about whether PATH Counselling Ltd. still has a legitimate interest in the given personal data is pending. At any time you have the right to object to the processing of your personal data that has been collected and processed for legitimate interests pursued by PATH Counselling Ltd., for instance when we provide you with relevant therapy materials, provide you with session reminders, or when we conduct analytics and statistics on your use of our therapy services.

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14. Right to complain

If you want to complain via post about a privacy breach, please contact Capital Office Ltd., Kemp House, 152-160 City Road, London, EC1V 2NX, United Kingdom or by sending an e-mail to info@pathcounselling.co.uk. We will acknowledge receipt of your complaint as soon as possible. We will do our best to resolve it as quickly as possible and within one (1) month from the date of complaint. In which case a response would require longer than one (1) month, we will let you know and inform you of the relevant reason(s).

 

If you are not satisfied with the outcome of your complaint or with our handling of your complaint by PATH Counselling Ltd, you may refer your complaint to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

 

MISCELLANEOUS

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15. Third-party websites, plug-ins and services

Website of PATH Counselling Ltd. may contain links to third party websites and plug-ins, for instance a social media plug-in. If you choose to use these websites, plug-ins or services you may disclose your information to those third parties. PATH Counselling Ltd. is not responsible for the content or practices of those websites, plug-ins or services. The collection, use, and disclosure of your personal data will be subject to the privacy policies of these third parties and not this Privacy Policy. We urge you to read the privacy and security policies of the relevant third parties.

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16. Use by children

PATH Counselling does not target and is not intended to attract children below the age of 16. Accordingly, our online services that collect personal data are not directed at and should not be accessed by individuals under the age of sixteen (16) years, and we request that such individuals do not provide any personal data to PATH Counselling Ltd. Minors must obtain express consent from parents or legal guardians before accessing or providing any personal data. If notified by a parent or guardian, or discovered by other means, that a child under the age of sixteen has provided his or her personal data to PATH Counselling we will delete the child’s personal data that is in our possession.

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17. Changes to our Privacy Policy

PATH Counselling Ltd. may modify or update this Privacy Policy when necessary to reflect changes in our services, changes in applicable legislation, regulations or practice and to address customer feedback. Accordingly, please review it periodically. Date of the latest update is always provided on the top of the document. If there are material changes to this Privacy Policy, we will notify you either by posting a notice or by sending you a notification.

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18. Contact details

If you have questions about this Privacy Policy or the processing of your personal data, please write to us via post or send us an email:

Capital Office Ltd., Kemp House, 152-160 City Road, London, EC1V 2NX

Info@pathcounselling.co.uk

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