Privacy & Cookie Policy

We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of our clients and of everyone who visits our website, innerexpansionagency.com (Our Site). We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy & Cookie Policy carefully and ensure that you understand it.

In this Policy the following terms shall have the following meanings:

Client - means a client who engages our individual or group therapy services or who purchases an online course or digital download from us;

Cookie - means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 15, below;

Cookie Law - means the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2003 (SI 2003/2426) (as amended) and the relevant parts of the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR); and

Data Protection Legislation - means all applicable data protection and privacy legislation in force from time to time in the UK including the UK GDPR; the Data Protection Act 2018 (DPA 2018) (and regulations made thereunder); the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including the privacy of electronic communications).

LGL Therapy Limited, referred to as “we” or “us” in this Privacy & Cookie Policy, is a limited company incorporated in England & Wales with company number 11101594, whose registered office address is at Collingham House 10-12 Gladstone Road, Wimbledon, London, England, SW19 1QT. LGL Therapy Limited is the controller and responsible for your personal data. Our Data Protection Officer is responsible for overseeing any requests relating to this Privacy Policy, and for dealing with any requests relating to your data protection rights. They can be contacted by email at info@lucindagordonlennox.co.uk.

Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymous data).

a) The right to be informed about our collection and use of your personal data. This Privacy & Cookie Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 16.
b) The right to access the personal data we hold about you. Part 14 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 16 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 16 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 16.It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please let us know.

Our ‘Work With Me’ form and website booking form on Our Site and any communications you may have with us including electronic communications.Depending upon whether you are simply browsing Our Site or are a Client, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Please also see Part 15 for more information about our use of Cookies and similar technologies. With the exception of information relating to your mental and physical health, background, sexual orientation, gender identity and / or religious beliefs referred to below, we do not collect any ‘special category’ or ‘sensitive’ personal data or data relating to criminal convictions and/or offences. Whilst we do not provide our services to children, we may collect personal data relating to children if you are a Client receiving therapy services and disclose personal data relating to your family members during the course of our sessions. We do not collect any other personal data relating to children.

Where we need to collect personal data by law, or under 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 our services). In this case, we may have to cancel a product or service contract you have with us but we will notify you if this is the case at the time.

Other people’s personal data, including next of kin and/ or emergency contact name and contact details and names of individuals in your support network.

DATA COLLECTED	HOW WE COLLECT THE DATA
Identity Information including name, age and date of birth.	Our ‘Work With Me’ form and website booking form on Our Site and any communications you may have with us including electronic communications.
Contact information including address, email address, telephone number and emergency contact number.	Our ‘Work With Me’ form and website booking form on Our Site and any communications we may have with you including electronic communications.
Your current physical and mental health and past physical and mental medical history.	Our ‘Work With Me’ form, any consultations we may conduct with you, any information provided to us by other medical or healthcare professionals at your request, together with any oral or written communications you may have with us including electronic communications.
Your sexual orientation and gender identity, and information relating to your sex life, to the extent relevant to the services we provide.	Our ‘Work With Me’ form, any consultations we may conduct with you, together with any oral or written communications you may have with us including electronic communications.
Your personal background including family and other relationships.	Our ‘Work With Me’ form, any consultations we may conduct with you, together with any oral or written communications you may have with us including electronic communications.
Your GP’s name and contact details.	Any consultations we may conduct together, together with any oral or written communications you may have with us including electronic communications.
Payment information including your purchase history from us.	Our billing process.
User profile information including your interests and your marketing and communications preferences	Our GDPR consent form, ‘Work With Me’ form and any written communications you may send to us including electronic communications.
Technical information including your IP address, login details, details about your browser, operating system, length of visit to pages on Our Site, page views and navigation paths, the number of times you use Our Site, time zones and other technology on the devices you use to access Our Site.	Analytics systems provided by Google or similar services, our security software and any written communications you may send to us including electronic communications.

Other people’s personal data, including next of kin and/ or emergency contact name and contact details and names of individuals in your support network.

Our ‘Work With Me’ form, any consultations we may conduct together and any oral or written or communications you may have with us including electronic communications.

Under the Data Protection Legislation, we must always have a lawful basis for using personal data.

Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you and/ or provide our services to you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Where you have consented to us using or processing your personal data, either by completing our GDPR consent form or by consenting to receiving direct marketing communications from us. You have the right to withdraw consent at any time by contacting us.

The following table describes how we may use your personal data, and our lawful bases for doing so:

WHAT WE DO	WHAT DATA WE USE (AS SET OUT ABOVE)	OUR LAWFUL BASIS
Processing communication data	Identity and contact information supplied by you	Our legitimate interest in communicating with you, keeping records and pursuing or defending legal claims.
Providing and managing your access to Our Site.	Identity and contact information supplied by you, your user profile and technical information.	Our legitimate interests in properly administering Our Site and our business, defining our client base and ensuring relevant content is provided to you, to keep Our Site updated and relevant and ensuring the security of Our Site; to maintain back-ups of Our Site and/ or databases and to enable publication and administration of Our Site.
Administering our business	Identity and contact information supplied by you, your payment information and technical data.	Our legitimate interest in properly administering our business and performing our contracts, including developing our business and informing our marketing strategy, troubleshooting, data analysis, testing, systems maintenance and reporting.
Supplying our services to you, including managing appointments, providing therapy services, providing course and membership programme content and (where relevant) liaising with other medical providers and/ or insurers with your consent	Identity and contact information for you, your next of kin or support network, information regarding your medical condition and history and/ or information relating to your background, family and relationships, information relating to your sex life, sexual orientation and gender identity, information regarding your preferences, information regarding billing and payment, user preferences.	Our legitimate interest in entering into and performing our contract to provide you with access to therapy services and/ or our membership programme; including processing the data to enter into the contract and supply the services you have purchased under that contract, and keeping records of those transactions. In the case of information regarding your special category or sensitive personal data, we also collect, use and process this information with your consent, which is given when you give your consent on entering into the contract with us and/ or sign our GDPR consent form, in order to provide your care and to comply with our professional obligations.
Managing payments for our services.	Identity, contact and billing information.	Our legitimate interests in collecting payment for the services we supply and thereby protecting and growing our business.
To handle your queries and obtain your feedback	Depending on the nature of your query or feedback, we may use your identity, contact, payment, and/or special category data to respond or investigate.	Our legitimate interests in managing our business, performing the contract between us, and/or provision of our services.
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity and contact information and information regarding your purchase history and preferences	Our legitimate interests in developing our products and services and growing our business.

We may use your identity, contact, technical, user and profile 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 products, services and offers may be relevant for you (we refer to this as marketing).

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/ or services. We collect, store and use this information this using Flodesk, a third-party marketing service provider. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and Cookie Law, and you will always have the opportunity to opt-out. We will obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

You can ask us or third parties 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.

We do not carry out automated decision making or any type of automated profiling.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected (including for the purposes of providing our services to you, or of satisfying any legal, professional or regulatory, accounting or reporting requirements).

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means, and the legal and regulatory requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

For tax purposes, the law requires us to keep basic information about our clients (including identity, contact and payment information as well as information on the contracts we enter into with our clients) for six years after they stop being clients.

In some circumstances, we may anonymise your personal data for research of statistical purposes in which case we may use this information indefinitely without further notice to you.

The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:

personal data entered by you on Our Site is secured by SSL (secure socket layer) technology in transit and at rest to improve security. SSL secures connections and prevents impersonation or stealing of visitors’ information;
the Stripe payment processor integration on Our Site is compliant with PCI-DSS. Sensitive card data is never handled by us. It goes directly to the payment processor’s servers and we do not have access to this information;
we have put in place appropriate technical and organisational measures against unauthorised or unlawful access to or processing of personal data and against accidental loss, destruction or damage of that data;
access to your personal data is limited to those employees, agents, contractors, and other third parties with a legitimate need to know and they are subject to duties of confidentiality; and
we have in place procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the relevant authorities where we are legally required to do so.

We may use external third parties to provide systems, technology or support which involves them processing personal data, necessitating a transfer of that personal data. For example, we use Learnworlds to provide our client relationship management platform. Learnworlds’ Privacy Policy and Data Security Policy, which sets out how it processes and protects personal data, is available here: Privacy Policy and Data Security Policy. Some external third parties, including LearnWorlds, use physical or cloud storage which is based outside the United Kingdom. By providing any information, including personal data to us, you consent to such transfer, storage and processing.

“Third countries” outside the EEA may not have data protection laws that are as strong as those in the UK. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation. We do this by selecting only external third parties that require the same levels of personal data protection that would apply under the Data Protection Legislation, and ensuring these levels of protection are contained in the external third parties’ privacy policies. Further details of the third-party providers we use are set out below.When you purchase products and/or services from us via Our Site, we use third-party services for payment processing. We will not store or collect your payment card details. If you pay with a credit card the payment information that you provide is encrypted and transmitted directly to Stripe. We do not store your payment information and do not control and are not responsible for Stripe or its collection or use of your information. The information you input is processed by Stripe in accordance with its Privacy Statement.

Learnworlds to host our online platform including our group membership programme, our online courses and digital downloads. This Privacy Policy and Data Security Policy describe how Learnworlds processes personal data.We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

We may have to share your personal data with service providers who provide IT and system administration services. For example, we use:

Flodesk to create, manage and send marketing emails to clients and other persons who have opted to receive them. This Privacy Policy describes how Flodesk processes these individuals’ data.
Circle to provide a community platform for some of our clients who decide to opt into the community platform through Our Site. This Privacy Policy describes how Circle processes personal data.
Learnworlds to host our online platform including our group membership programme, our online courses and digital downloads. This Privacy Policy and Data Security Policy describe how Learnworlds processes personal data.
Calendly to enable clients to schedule calls or meetings with us. For more details on how Calendly stores and processes personal data, please see its Privacy Policy.

We may also share your personal data with your referrer, your GP or other independent healthcare professionals if you specifically request this and have consented to it.
We may be required to share personal data (for example with your GP or with the emergency services) if we consider that there is a real risk of harm to you or to others.
On occasion we may also share your personal data with our professional advisers such as lawyers, bankers, auditors and insurers.
We may need to share your personal data with HM Revenue & Customs, regulators and other authorities based in the United Kingdom if they request this.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy & Cookie Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if:

we are involved in legal proceedings
we are complying with legal obligations, for example as regards our safeguarding obligations, or our obligations in relation to terrorism, money laundering or drug trafficking
we are complying with a court order
we are complying with the instructions of a government authority
we are required to do so by a regulatory body, for example in relation to a client complaint or regulatory breach or investigation.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 10.

If any personal data is transferred outside of the United Kingdom, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the United Kingdom and under the Data Protection Legislation, as explained above in Part 10.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown in Part 16.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up asking you to give your consent to set those Cookies. You will be able to choose whether to consent only to necessary cookies and/ or to non-essential Cookies. Necessary cookies help make Our Site more useable for users by enabling basic functions like page navigation and access to secure areas of Our Site. Our Site cannot function properly without these Cookies.

By consenting to the placing of Cookies you are enabling us to provide the best possible experience and service to you. However, the non-essential third-party Cookies on Our Site are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

Our Site uses Google Analytics to provide website analytics services. Website analytics refers to a set of tools used to collect and analyse usage information, enabling us to better understand how Our Site is used and how best to target potential customers. This, in turn, enables us to improve Our Site and the services offered through it.

Our Site also uses third party cookies from social media sites such as Facebook, which allow us to measure the effectiveness of our social media advertising campaigns by tagging social media users when they visit Our Site, and to re-target our advertising.

These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

The above services used by Our Site use third-party Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

You may opt out of Google Analytics’ services using the Opt-Out feature on their website. The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool.

In addition to the controls that Google and we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device or follow the relevant link(s) below:

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.

We may change this Privacy & Cookie Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy & Cookie Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy & Cookie Policy was last updated on 26 May 2022.

Privacy & cookie policy

LUCINDA GORDON LENNOX - THE INNER EXPANSION AGENCY

background

1. Definitions and Interpretation

2. information about us

3. third party links

4. what is personal data?

5. what are my rights?

6.

7. what data do you collect and how?

8. How Do You Use My Personal Data?

9. HOW LONG WILL YOU KEEP MY PERSONAL DATA?

10. HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?

11. do you share my personal data?

12. how can i control my personal data?

13. can i withhold information?

14. how can i access my personal data?

15. how do you use cookies?

16. how do i contact you?

17. changes to this privacy policy