Privacy Policy
Please take the time to read through carefully.
Scope
This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. Guernsey’s equivalent, The Data Protection (Bailiwick of Guernsey) Law, 2017, came into force on 25 May 2018. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
This Privacy Policy is for Wild Wolf Wellbeing Limited, based at Lindfield House, Rue Maze, St Martins, Guernsey, GY4 6LJ, which hereafter for the purposes of this Privacy Notice will be referred to as Wild Wolf Wellbeing, is pleased to provide the following information:
1. who we are
Wild Wolf Wellbeing – we are a wellbeing business which includes a team of specialised professionals and administration staff. We offer a variety of services which are to expand to cover all areas of wellbeing, all of which are carried out in accordance with each professional’s respective accreditations. The services Wild Wolf Wellbeing currently provide include: Counseling, Psychotherapy and Coaching. Additional services will be offered to clients from time to time, and these will be clearly made visible on our website and online booking system.
2. Personal Data
a) At Wild Wolf Wellbeing, we may need detailed medical information to provide you with the best treatment possible. We’ll only collect what’s necessary and hold it securely on a cloud-based system. This information won’t be shared with anyone not involved in your treatment unless required by law. We may also use your contact details to remind you of appointments and provide updates on your treatment.
b) We may use your contact details to respond to your inquiries and send marketing materials that we believe may interest you. You can opt in to receive these materials when booking your appointment and can change your preference at any time through the online portal.
c) We’ll maintain a marketing dialogue with you until you opt out, which you can do at any time. We won’t sell or broker your data to third parties.
d) We collect basic personal data from marketing forms, surveys, correspondence, phone calls, and website visits, including IP addresses.
e) Our website uses cookies to help us identify and track visitors. If you don’t want cookies on your computer, you can set your browser to refuse them.
f) We only collect information needed to provide you with our services.
3. Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.
4. Legitimate interests pursued by Wild Wolf Wellbeing
To promote services for clients with all types of health problems indicated for the services provided at Wild Wolf Wellbeing.
5. Consent
Through agreeing to this Privacy Policy you are consenting to Wild Wolf Wellbeing processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Policy.
6. Disclosure
At Wild Wolf Wellbeing, we take the security of your personal information seriously. Your therapist and essential administrative staff will have access to your data for treatment and administration purposes only. We keep all patient data confidential and will only disclose it when legally required. We also enforce our terms and conditions to protect our staff and prevent fraud or security issues.
7. how long we retain your data
Wild Wolf Wellbeing will process personal data during the duration of any treatment and will continue to store only the personal data needed for a minimum period of three years. Records concerning minors who have received treatment will be retained at least until the child has reached the age of 25.
8. Data storage
We use a cloud based booking software called SimplyBook.me Ltd. (“Simply Book”) to store all our client records. Simply Book are GDPR compliant with hosting centers meeting the R82 and R81 APSAD standards and working according to ISO 27001 standards.
9. Data Processors
Wild Wolf Wellbeing uses data processors to perform certain tasks essential in the running of the business. The data processors may change from time to time, but any changes will be updated in this notice.
These include:
- SimplyBook.me Ltd. – Our online booking system is supplied by (“SimplyBook.me”), a company registered in Cyprus, who acts as a data processor on behalf of Wild Wolf Wellbeing.
- Google Workspace – We utilise the Google suite including Gmail, Google Docs, Google Drive and other related applications in the suite for the management and administration of our business. These are used to respond to clients emails and requests, as well as saving and storing any letter related correspondence. These are managed under the strict controls of google and all data is stored in their European data centres only.
Any other data processors will be updated and listed in our data notice as and when they are utilised under strict confidentiality agreement with Wild Wolf Wellbeing.
10. Your rights as a data subject
At any point whilst Wild Wolf Wellbeing are in possession of, or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Wild Wolf Wellbeing refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge the refusal. At your request Wild Wolf Wellbeing can confirm what information it holds about you and how it is processed.
11. You can request the following information:
- Identity and the contact details of the person or organisation (Wild Wolf Wellbeing) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Wild Wolf Wellbeing and information about these interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erasure, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority The office of the Data Protection Commissioner (ODPC).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12. To access what personal data is held, identification will be required
Wild Wolf Wellbeing will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Wild Wolf Wellbeing is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to tim@wildwolfwellbeing.com or by writing to us at the address further below.
13. Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Wild Wolf Wellbeing, you have the right to complain to us. If you do not get a response within 30 days, you can raise your complaint to the ODPC.
The details for each of these contacts are:
The person responsible for data protection at Wild Wolf Wellbeing:
Tim Rowe – Director
Telephone: +44 (0) 7781 133300
or email: tim@wildwolfwellbeing.com
The office of the Data Protection Commissioner (ODPC)
Data Protection Office, Guernsey Information Centre, North Esplanade, St. Peter Port, Guernsey, GY1 2LQ
Telephone: +44 (0) 1481 742074
Email: enquiries@dataci.org