1. Introduction and Data Controller

Welcome to Jaroanser. We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect, use, and look after your information when you visit our Wix website, book a workshop, or book a one-to-one session.

For the purposes of the UK General Data Protection Regulation (UK GDPR), the Data Controller is David Richmond trading as Jaroanser.

If you have any questions about this policy or wish to exercise your data rights, please contact us at: jaroanser@gmail.com

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2. Information We Collect

We collect and process different types of information depending on how you interact with us:

• Identity and Contact Data: Name, email address, phone number, and billing address.

• Special Category Data: Health or spiritual information relevant to your session. We also create written consultation notes based on your in-person discussions and our observations.

• Technical and Usage Data: IP address, login details, and session information (page response times, length of visits, etc.) collected automatically by the Wix platform via cookies.

• Media Data: Photographs or videos taken at our events or workshops.

3. Legal Basis for Processing

We only use your data when the law allows us to. We rely on the following lawful bases under Article 6 of the UK GDPR:

• Contract: To fulfill your booking and provide our services.

• Legitimate Interests: To manage our business, keep transaction histories, and communicate with you.

• Legal Obligation: To maintain proper tax, accounting, and insurance records.

• Consent: For sending newsletters and marketing materials.

Special Category Data Condition: Because health and spiritual data are sensitive, we process this information under Article 9(2)(a) of the UK GDPR based on your explicit, written consent, which you provide before or during your initial booking.

4. How We Collect Information

We collect data through the following methods:

• Direct Interaction: When you complete a booking, fill out an inquiry form, or attend a session.

• Automated Technologies: When you browse our website via Wix cookies.

• In-Person: Written notes taken during your consultation or session.

• Event Capture: Photos or videos, strictly via an explicit "opt-in" at the start of a workshop.

5. Why We Collect Information

We use your data to:

• Provide, operate, and maintain our services.

• Send session confirmations, reminders, and updates via email or WhatsApp.

• Comply with UK tax, legal, and insurance obligations.

6. Data Sharing and International Transfers

We do not sell your data. We only share your data with trusted third-party service providers to run our business:

• Wix.com: Hosts our website and stores data on secure servers.

• WhatsApp: Used for sending session updates and reminders.

• Email: Used for sending session updates and reminders.

Because Wix and WhatsApp operate globally, your data may be transferred outside of the UK to countries like the United States. We ensure these transfers are secure and legal by verifying that these providers use approved safeguarding mechanisms, such as Standard Contractual Clauses (SCCs).

7. Data Retention

We only keep your personal data for as long as necessary to fulfil the purposes we collected it for.

• Financial and Tax Records: Kept for 6 years following the end of the tax year to meet UK tax laws.

• Insurance Records: Consultation notes and client history are kept for 7 years to meet insurance requirements.

• Marketing Data: Kept until you withdraw your consent or unsubscribe.

8. Your Data Protection Rights

Under the UK GDPR, you have the following rights regarding your data:

• Access: The right to request copies of your personal data.

• Rectification: The right to ask us to correct inaccurate information.

• Erasure: The right to request that we erase your data under certain conditions.

• Restriction: The right to request that we limit how we process your data.

• Object: The right to object to our processing of your data.

• Withdraw Consent: The right to withdraw consent at any time where we rely on consent to process your data (e.g., marketing or photos).

9. How to Complain

If you have any concerns about our use of your personal data, you can make a complaint directly to us using the contact details in Section 1.

You also have the right to complain to the UK supervisory authority, the Information Commissioner’s Office (ICO):

• Website: ico.org.uk

• Helpline: 0303 123 1113