Definitions
Personal data is defined within the legislation as “any information relating to an identified or identifiable natural person” whereby the person can be identified directly or indirectly.
Data controller, A person or organisation who determines the purpose for which and the manner in which personal data are processed.
1. Introduction
1.1 Your privacy is important to us and we are committed to safeguarding the privacy of The Counselling Vine website visitors and service users for all our products and services. This privacy policy explains the personal data The Counselling Vine processes, how The Counselling Vine processes it and for what purposes.
The Counselling Vine offers 121 counselling on a face to face, online and walk and talk basis. We rely upon a variety of legal reasons and permissions (legal bases) to process data, including: sensitive content, legitimate interests, necessity to enter into and perform contracts and compliance with legal obligations detailed below:
1.2 This policy applies where we are acting as a data controller and data processor with respect to the personal data of The Counselling Vine website visitors and clients; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 The Counselling Vine asks you to consent to our use of cookies by using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.4 In this policy, “we”, “us” and “our” refer to The Counselling Vine. For more information about us, see Section 12.
2. How we use your personal data
2.1 In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 Usage data. Interactions within the services you use, including how they perform. 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 Google 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.
2.3 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.
2.4 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 consent
2.5 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.
The data we collect depends on the products, services and features you use. The detailed data we collect can include the following:
Name and contact data. Your first and surname, email address, postal address, phone number and other similar information.
Error reports and performance data. Data about the performance of our products and services and any problems you may experience, including error notifications.
Location data. Data entered regarding locations and inferred from a device’s IP address.
Images. Images and related information, such a picture metadata.
Social data. Information relating to your interactions between other people and organisations, including messages.
Content. Content of files and communications you input, upload, receive, create and control.
Feedback and ratings. Information you provide us such as feedback, survey data and product and service reviews.
2.6 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your “correspondence data” to a third party of customer relationship systems known as Zoohoo. The profile data collected may include your name, company/personal address and email.
3.2 We may disclose your personal contact 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.
4. International transfers of your personal data
4.1 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.
5. Retaining and deleting personal data
5.1 This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 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.
5.3 We will retain your personal data as follows:
Where you have given us consent, we will retain your information until you advise us that you no longer wish to receive information (which you can do at any time) or until we determine there is no further requirement to process your information or provide you with information.
Where we have a contract, we will retain your information until termination of that contract plus 6 months to allow us to close the contract effectively. You can ask us to remove your information earlier.
Where there is a public task, we will hold that information for as long as necessary to execute that task.
Where there is a necessary, legitimate interest we will retain and process your information for as long as necessary to safeguard our or a third party’s interests, accepting your individual rights may override this.
5.4 Notwithstanding the other provisions of this section, 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.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email.
7. Security
Data that is transferred between your browser and our servers is encrypted using SSL. We use strong encryption and will drop support for old browsers that do not comply with strong encryption standards.
8. Who can access my data?
Our clients data will not be publicly available.
In order to provide the service, we do have authorised operations staff with access to the underlying infrastructure and therefore the underlying data in raw form. However, we never access specific client data unless we are working with the client to investigate a problem. Such access is strictly limited through authentication and restriction to specific premises.
You may wish to audit your information locally. We can provide your data securely in alternative formats if required – such as CSV.
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) that is sent by a web server to a web browser and is stored by the 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 either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 The Counselling Vine uses the following cookies on this website, for the following purposes:
· Strictly necessary cookies
· Performance cookies
· Functionality cookies
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.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. Information on the relevant cookies can be found here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.
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:
https://support.google.com/chrome/answer/95647?hl=en (Chrome);
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
http://www.opera.com/help/tutorials/security/cookies/ (Opera);
https://support.apple.com/kb/PH21411 (Safari); and
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
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 The Counselling Vine.
13.2 We are registered in Scotland, our registered address is 26 Headline rise IV30 5HA
13.3 You can contact us:
(a) by post, to the postal address given above
(b) by telephone, on the contact number published on our website
(d) by email, using the email address published on our website
14. Data protection officer
Our data protection officer contact details are:
Samantha Hill
The Counselling Vine 