Privacy and Cookie Policy

Last updated: [PUBLICATION DATE]

1. Data Controller

The controller of your personal data is:

[FULL LEGAL BUSINESS NAME]
operated by Sylwia Angerman
address: [BUSINESS ADDRESS]
Tax ID / NIP: [NIP]
email: [EMAIL IN YOUR DOMAIN]

referred to below as the "Controller."

This Policy applies to the website available at [FINAL DOMAIN] and to the services provided by the Controller.

For questions relating to privacy or personal data, you can contact me at [EMAIL IN YOUR DOMAIN].

2. What data I may process

Depending on how you use the website and my services, I may process:

your name,
your email address,
your telephone number, if you choose to provide it,
information needed to schedule a meeting,
information included in correspondence,
information needed to process payments and accounting,
information about how you use the website if you consent to analytics,
information provided during our direct work together if it is necessary to organize and provide the service.

I do not ask you to submit detailed health information, diagnoses, or medical test results through the general contact form or Calendly.

If, during our direct work together, you voluntarily provide health information or other special-category personal data, it will be processed only when there is an appropriate legal basis and only to the extent necessary for the agreed purpose.

3. Contact

If you contact me through the form or by email, I process the information you provide in order to respond to you and manage our correspondence.

The legal basis may be taking steps at your request before entering into a contract, performance of a contract if we are already working together, or my legitimate interest in managing correspondence.

4. Calendly

Calendly is used to schedule introductory calls.

When you make a booking, information needed to arrange and manage the appointment may be processed, including your name, email address, preferred language, and a short description of the purpose of the call.

Calendly processes some data on my behalf and, in certain circumstances, may act as an independent controller in accordance with its own privacy terms.

5. Providing services

If we begin working together, I process information needed to organize and provide the selected service, communicate with you, manage our arrangements, and handle payment and accounting.

The legal basis for processing ordinary personal data is primarily entering into and performing a contract.

6. Health data

Health information is a special category of personal data.

I do not ask you to provide it through the general contact form or Calendly.

If certain information is necessary to assess whether a particular form of work is appropriate or safe, we discuss it directly.

If processing that information requires your explicit consent, that consent will be collected separately.

Withdrawing consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

7. Stripe

Payments for services may be processed through Stripe.

Stripe processes information required to complete the transaction in accordance with its own privacy terms.

I do not receive your full payment card details.

8. Zoom

Introductory calls and online sessions may take place through Zoom.

When a meeting is organized, Zoom may process identifying information, technical information relating to the device and connection, and information related to participation in the meeting.

9. WhatsApp

For selected processes, communication through WhatsApp may be available.

Using WhatsApp is optional.

If you do not want to use WhatsApp, we can communicate by email.

10. Email

I use email operating through my own domain for communication.

Information contained in email messages may be processed by the email infrastructure provider to the extent necessary to provide that service.

11. Netlify

The website is hosted using Netlify infrastructure.

When you use the website, Netlify may process certain technical information necessary to deliver, operate, and secure the site.

12. Google Analytics

With your consent, I use Google Analytics to create statistics about how the website is used.

Analytics information helps me understand which pages visitors use and how people move through the website.

For users in the European Economic Area, consent choices are communicated to Google through an appropriately configured Consent Mode implementation.

You can change or withdraw your analytics consent at any time through Cookie Settings.

13. Meta Pixel

As of the date of this Policy, Meta Pixel is not used on this website.

If it is introduced in the future, the consent mechanism and this Policy will be updated before Meta Pixel is used for marketing purposes.

14. Session recordings

Sessions are not recorded automatically.

If a particular session is to be recorded for supervision, training, or accreditation purposes, I will inform you in advance and ask for your separate, explicit consent.

Before you consent, you will receive information about the purpose of the recording, who may have access to it, how it will be protected, and how long it is expected to be stored.

The recording will be retained only for as long as necessary for the stated purpose and for no longer than [MAXIMUM RETENTION PERIOD], after which it will be deleted unless applicable law requires longer retention.

If a case is discussed in supervision without sharing a recording, the information disclosed is limited to what is necessary for the purpose of supervision.

Where possible, information that directly identifies the client is not shared.

15. Recipients of personal data

Personal data may be shared with service providers where necessary for the website to operate or for me to provide my services.

These may include:

Netlify,
Calendly,
Stripe,
Zoom,
WhatsApp, if you choose to use that channel,
Google in connection with Google Analytics following your consent choice,
my email service provider,
accounting, legal, and technical service providers where access to personal data is necessary for them to perform their work.

16. Transfers outside the European Economic Area

Some of the service providers I use are connected with entities operating outside the European Economic Area.

Where personal data is transferred outside the EEA, the transfer is carried out using mechanisms permitted by applicable data protection law, depending on the provider and the processing involved.

These mechanisms may include adequacy decisions, the EU-U.S. Data Privacy Framework, or Standard Contractual Clauses approved by the European Commission.

17. Data retention

Information related to correspondence is retained for as long as needed to manage the contact and then for the period necessary to protect against potential claims.

Information related to the performance of a contract is retained for the duration of our work together and then for the period required by law or needed to protect against potential claims.

Accounting records are retained for the period required by tax and accounting regulations.

Information processed on the basis of consent is retained until consent is withdrawn or until the purpose of processing no longer exists.

Google Analytics user data retention should be configured for no longer than 14 months.

18. Your rights

Depending on the legal basis and nature of the processing, you may have the right to:

access your personal data,
receive a copy of your data,
correct your data,
request deletion,
request restriction of processing,
request data portability,
object to processing,
withdraw consent.

If you believe your personal data is being processed unlawfully, you have the right to lodge a complaint with the President of the Polish Personal Data Protection Office, the UODO.

19. Cookies

The website uses cookies and similar technologies.

Essential cookies are used to support the proper operation and security of the website.

Analytics cookies or similar technologies connected with Google Analytics are used according to the consent choice made by the visitor.

You do not need to consent to analytics in order to use the website or book an introductory call.

20. Managing cookies

During your first visit, you can:

accept all available categories,
keep only essential cookies,
choose your own settings.

You can later change your choice through the Cookie Settings link in the footer.

21. Automated decision-making

I do not make decisions about you that have legal or similarly significant effects solely through automated processing.

22. Security

I use organizational and technical measures designed to reduce the risk of unauthorized access to personal data, loss, alteration, or disclosure.

23. Minors

My services are intended for adults.

The website does not accept bookings for sessions for people under the age of 18.

24. Changes to this Policy

This Policy may be updated if the way the website operates, the tools I use, or applicable law changes.

The current version will always be available at:

[FINAL DOMAIN]/en/privacy-policy

25. Contact

For questions about privacy or the processing of personal data, contact:

[EMAIL IN YOUR DOMAIN]