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Privacy Policy

Last updated: 10/6/2025

This Privacy Policy governs the manner in which I collect, use, maintain and disclose your information as a user of the www.penafiel.co.uk website (“site”) or in connection with my services. Please read this Privacy Policy in conjunction with my Terms of Service and Practice Standards.

1. Personal identification information

I may collect personal identification information from you in a variety of ways, including, but not limited to, when you visit my site, contact me, book a session, fill out a form, or interact with other activities, services, features, or resources. You may be asked for, as appropriate, a name, an email address, a WhatsApp number, and your GP’s contact details. You may, however, visit the site anonymously. I will collect personal identification information only if you voluntarily submit such information to me. You can always refuse to supply personal identification information; however, this will prevent you from engaging with my services.

If, during sessions, you disclose information that falls under special category data, such information will be processed on the basis that it is necessary for the provision of health or social care or treatment. This includes maintaining appropriate session records to support your wellbeing. You are not required to disclose any such information, and anything you share remains subject to confidentiality as outlined in the Terms of Service.

For your information, “special category data”, under current UK legislation, includes: physical and mental health, ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, sexual orientation and sex life

2. Non-personal identification information

I may collect non-personal identification information about you whenever you interact with my site. This information may include your browser name, the type of computer you use, and technical information about your means of connection to the site, such as your operating system and internet service provider, as well as other similar information.

3. Online Interactions and Additional Privacy Considerations

3.1 Social Media

You may follow my LinkedIn account; however, please note that I do not engage in private messaging or respond to comments, as this platform is not intended for client communication or support.

3.2 Search Engines

I do not conduct online searches about clients, except in urgent circumstances where immediate safety concerns may arise and where doing so is necessary and proportionate.

3.3. Location Services

I do not collect or use location data. If you access my site or services through location-based tools, please manage your device and software privacy settings accordingly. I am not responsible for any assumptions made by third parties based on such data.

3.4. To send emails

We may use the email address to respond to Users’ inquiries, questions, and/or other requests.

4. How I Use Collected Information

I may collect and use your personal information for the following purposes:

4.1. To Improve Customer Service

Information you provide helps me respond to customer service requests and support needs more efficiently.

4.2. To Improve the Site

I may use feedback you provide to improve my products and services.

4.3. To Process Payments

I may use the information you provide when contracting my services to fulfil that contract. I do not share this information with outside parties except to the extent necessary to provide the services.

5. Legal Basis for Processing

The bases on which I keep and process your data are Consent, Contract, Legal Obligation, Vital Interests and Legitimate Interests.

6. How I Protect Your Information

I adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorised access, alteration, disclosure, or destruction of your personal information.

7. Data Retention

I retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, including legal, accounting, or reporting obligations. In most cases, I retain information for up to six years from the date of your last interaction, unless a longer retention period is required or permitted by law.

8. Sharing Personal Information

I do not sell, trade, or rent your personal identification information to others. I may share it with trusted third-party service providers only to the extent necessary to operate my business and deliver the services you have requested, in accordance with this Privacy Policy.

9. Amendments

I may update this Privacy Policy from time to time to reflect changes to my practices, legal obligations, or other operational reasons. When I make material changes, I will take appropriate steps to inform you. I will assess materiality based on the nature and impact of the change, in accordance with applicable data protection law. This page will always indicate when it was last revised, and you are encouraged to review it periodically to stay informed.

10. Your Rights

If you are a European or UK resident, you have the right to access personal information I hold about you and to ask that your personal information be corrected, updated, deleted, that its processing be restricted, that it be transferred to another party (data portability), or to object to its processing. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your rights have been infringed.

Additionally, if you are a European or UK resident, note that I am processing your information in order to fulfil contracts I might have with you, or otherwise to pursue my legitimate business interests listed above. Furthermore, please note that your information may in select cases be transferred outside of the UK, including to Canada and the United States. Where such transfers occur, they are made in compliance with UK data protection law, such as using countries with adequacy decisions or standard contractual clauses approved by the UK government or other appropriate safeguards.

11. Acceptance of These Terms

By using this site or engaging with my services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please discontinue use of the site. Continued use of the site after changes are posted indicates that you have been informed of those changes, where applicable.

12. Contact

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, or my services, please contact me.