THE EMPOWERMENT GROUP
Privacy policy
Last Updated: [January] 2024
Welcome to The Empowerment Group’s Privacy Policy.
What does this Privacy Policy Cover?
The Empowerment Group respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our website (“Site”) and tell you about your privacy rights and how the law protects you.
With that in mind, this Privacy Policy is designed to describe:
· Who we are and how to contact us.
· Your rights relating to your Personal Data.
· Marketing communications preferences.
· What Personal Data we collect.
· How we use your Personal Data and why.
· What happens when you do not provide necessary Personal Data?
· Personal Data from Third Party Sources.
· How we use cookies and other tracking or profiling technologies.
· Who we share your Personal Data with.
· How we keep your Personal Data secure.
· How long we store your Personal Data.
· Our policy on children.
· Third party links.
This Privacy Policy aims to give you information on how The Empowerment Group collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.
The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.
We will post any modifications or changes to this Privacy Policy on this page.
Who we are and how to contact us.
Who we are.
The Empowerment Group is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “The Empowerment Group”, “we”, “us” or “our” in this Privacy Policy).
Our address is: 3rd floor, 86-90 Paul Street, London EC2A 4NE.
How to contact us.
You can contact us by emailing: hello@theempowermentgroup.co.uk.
Your rights relating to your Personal Data.
Your rights in connection with Personal Data
Under certain circumstances, by law you have the right to:
· Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
· Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
· Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
· Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
· Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
· Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown here: https://www.theempowermentgroup.co.uk/
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, 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. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: hello@theempowermentgroup.co.uk
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing communications preferences.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time using the contact details shown here [LINK TO “Who We Are and How to Contact Us”].
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails exchanged for the purpose of managing your session appointments with therapists.
What Personal Data we collect.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Category of Personal Data collected
What this means
Identity Data
First name, surname, marital status, title, current employment status, date of birth, gender, ethnicity, sexual orientation and religion.
Contact Data
Your area of residence, billing address, email address and telephone numbers.
Financial Data
Your bank account and payment card details
Transaction Data
Any details about payments to and from you and other details of subscriptions and services you have purchased from us.
Marketing and Communications Data
Your preferences in receiving marketing from us and our third parties and your communication preferences.
Technical Data
Internet protocol (IP) address, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.
Health and Medical Data
Information about the reason why you are seeking to obtain counselling/therapy (e.g. because you suffer from anxiety, stress or depression, OCD, etc.), and whether you received professional counselling in the past.
Biometric Data
Photographic ID (e.g.passport, drivers licence), and photographs or video footage of you at our in-person events (where applicable).
Aggregated Data
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
How we use your Personal Data and why.
We will only use your Personal Data for the purposes for which we collected it as listed below, 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 your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
· Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
· Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
· Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
· Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally, we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications, or to process ‘Special Category Data’.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
Purpose
Category(ies) of Personal Data involved
Why do we do this
Our legal basis for this use of data
Profile Creation
· Identity Data
· Contact Data
· Health and Medical Data
· Biometric Data
To register you as a new patient and enable you to book sessions with a therapist.
Contractual Necessity.
With respect to any Personal Data which amounts to ‘Special Category Data’, we also process such data on the basis of your Consent (under Article 9(2)(a) of the UK GDPR).
To process payments for bundles of sessions with a therapist
· Identity Data
· Contact Data
· Finance Data
· Transaction Data
To process and deliver your order including manage payments, fees and charges.
Contractual Necessity.
Fraud Prevention
· Identity Data
· Contact Data
· Biometric Data
To keep our website, our services and associated systems operational and secure.
Legitimate Interests.
We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
We also need to confirm that the individual registering for therapy is the person in question working with the therapist.
Troubleshooting
Technical Data
To track issues that might be occurring on our systems.
Legitimate Interests.
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.
Marketing
· Identity Data
· Contact Data
· Marketing and Communications Data
To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
Legitimate Interests.
We have a legitimate interest in providing you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us.
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site, such as enabling you to book a therapy session).
In this case, we may have to stop you using our Site but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
Third party data source
Publicly available?
Category(ies) or other types of personal data received.
Credit Reference agencies
No
· Identity Data
· Contact Data
· Transaction Data
Social Media sites
Yes
· Identity Data
· Contact Data
Analytics Providers
No
· Behavioural Data
· Technical Data
Advertisers
No
· Behavioural Data
· Technical Data
How we use cookies & other tracking or profiling technologies.
Cookies.
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies:
· first party cookies, served directly by us to your computer or mobile device; and
· third party cookies, which are served by our partners or service providers on our Site.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
Type of cookie
Purpose
Essential Cookies
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies
These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
Disabling cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Who we share your Personal Data with.
We may share your Personal Data with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Service providers. Third parties that provide services on our behalf or help us operate the Site or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, payment processors and website analytics).
Third parties designated by you. We may share your Personal Data with third parties where you have instructed us or provided your consent to do so. For example, we may share your Personal Data with therapists to offer you services.
Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for compliance and protection purposes.
Some of our external third parties may be based outside the United Kingdom (UK) so their processing of your Personal Data may involve a transfer of data to countries based outside of the UK.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented
· We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK Government.
· Where we use service providers outside the UK, we may use specific contracts approved by the UK’s Information Commissioner’s Office, which give Personal Data the same protection it has in the UK. For further details, see Information Commissioner’s Office: International data transfer agreement and guidance.
How we keep your Personal Data secure.
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.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data.
We retain Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.
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 unauthorized 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.
When we no longer require the Personal Data, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible. If we anonymise your Personal Data (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Our policy on children.
This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.
Third party links.
This Site 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 your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.
The Empowerment Group, 2024