Privacy Policy

1. Information I May Collect

The personal information I collect depends on how you interact with me and the services you choose to use.

Information you provide directly

This may include:

• your name;
• email address;
• telephone or WhatsApp number;
• country or location;
• booking and appointment information;
• information submitted through website contact forms;
• information provided during a discovery call;
• billing and transaction information;
• correspondence between us;
• testimonials, feedback or reviews you choose to provide; and
• any other information you voluntarily provide.

Client and intake information

If you choose to work with me, I may also collect information through intake forms, consultations and sessions. This may include information about:

• your reasons for seeking support;
• your goals and desired outcomes;
• personal history and significant life experiences;
• relationships and family circumstances;
• emotional wellbeing;
• behaviours, beliefs and patterns you wish to address;
• relevant physical or mental health information that you voluntarily disclose;
• medications or treatment information where relevant to determining whether a service is appropriate for you;
• session notes; and
• information you share verbally or in writing before, during or after our work together.

Some of this information may be considered sensitive or special-category personal information. I only collect information of this nature where it is relevant to providing my services and where there is an appropriate legal basis for doing so.

You are not required to provide information that is unrelated to the work we are undertaking together.

Information collected automatically

When you visit my website, certain technical information may be collected automatically, such as:

• IP address;
• browser and device information;
• pages visited;
• date and time of visits;
• referring website;
• approximate location derived from your IP address; and
• cookie or analytics information.

This information helps me understand how the website is being used and improve its functionality and user experience.

2. Why I Collect Your Information

I collect and process personal information only where there is a legitimate and appropriate reason to do so.

This may include:

• responding to enquiries;
• arranging discovery calls and appointments;
• determining whether my services are suitable for you;
• preparing for and delivering RTT®, coaching, sound or related services;
• personalising your sessions and supporting your agreed goals;
• creating personalised recordings or materials where this forms part of your service;
• communicating with you before and after sessions;
• providing client support and follow-up;
• processing payments and maintaining financial records;
• managing bookings, cancellations and administrative matters;
• maintaining appropriate client and business records;
• improving my services and website;
• meeting professional, insurance, legal, regulatory or safeguarding obligations;
• protecting my legal rights or responding to legal claims; and
• sending marketing communications where you have chosen to receive them.

I will not use information you provide during private client work for unrelated marketing purposes.

3. Legal Bases for Processing

Depending on the circumstances, I may process your personal information because:

• it is necessary to provide a service you have requested or to take steps before entering into an agreement with you;
• you have given your consent;
• processing is necessary to comply with a legal or regulatory obligation;
• I have a legitimate business interest in processing the information, provided that interest does not override your rights and interests; or
• processing is otherwise permitted or required by applicable law.

Where your explicit consent is relied upon, including where appropriate for sensitive personal information, you may withdraw that consent at any time. Withdrawal of consent does not affect processing that lawfully took place before consent was withdrawn.

4. Confidentiality of Client Information

Information shared with me in connection with your sessions is treated as private and confidential.

I do not sell client information, and I do not disclose the content of sessions to family members, employers, partners or other third parties simply because they have paid for, referred or arranged a session.

There are limited circumstances in which confidentiality may need to be restricted or information disclosed. These may include where:

• you have expressly authorised me to share information;
• disclosure is required by law, regulation or court order;
• I reasonably believe disclosure is necessary to address a serious and imminent risk of harm;
• safeguarding obligations arise;
• information must be shared with an insurer, professional adviser or legal adviser in connection with a complaint or legal claim; or
• a professional service provider requires limited access to information in order to operate systems used in my practice.

Where reasonably possible and lawful, I will seek to discuss such a disclosure with you before it is made.

5. Session Recordings and Personalised Audio

Where a personalised transformational or therapeutic audio recording is created for you as part of your service, it may include your first name, agreed goals, themes discussed during your session, and personalised suggestions.

These recordings are created solely for the client for whom they are intended.

6. Payments

Payments may be processed through a secure third-party payment provider.

I do not ordinarily receive or store your full payment-card details. Payment providers process such information in accordance with their own privacy and security policies.

I may retain records relating to payments, invoices, refunds and transactions where required for accounting, tax, legal and business purposes.

7. How Your Information Is Stored and Protected

I take reasonable organisational and technical measures to protect personal information from:

• unauthorised access;
• loss;
• misuse;
• alteration;
• accidental disclosure; and
• destruction.

Depending on the service involved, information may be stored using password-protected devices, secure email accounts, encrypted or access-controlled cloud storage, booking systems, payment platforms and other professional technology providers.

Access to client information is limited to those who genuinely require access for the purposes described in this Privacy Policy.

While I take reasonable precautions to safeguard information, no electronic transmission or storage system can be guaranteed to be completely secure.

8. Third-Party Service Providers

I may use trusted third-party providers to support the operation of my practice and website.

These may include providers of:

• website hosting;
• appointment scheduling;
• online forms;
• email;
• cloud document storage;
• video conferencing;
• electronic communications;
• payment processing;
• accounting;
• analytics; and
• business administration.

These providers may process limited personal information on my behalf or as independent data controllers.

Where appropriate, I take reasonable steps to use reputable providers with appropriate privacy and security measures.

Their own privacy policies may also apply to information they process through their services.

9. WhatsApp and Electronic Communications

If you choose to communicate with me through WhatsApp, email, video conferencing or another electronic platform, information will also be processed by the provider of that service in accordance with its own privacy practices.

Please avoid sending particularly sensitive information through informal messaging services unless necessary.

WhatsApp or other messaging support offered as part of a service is intended for appropriate client communication and does not replace emergency, medical or crisis support.

10. International Transfers

Some technology providers I use may store or process information in countries outside the United Arab Emirates.

Where personal information is transferred internationally, I take reasonable steps to ensure that appropriate safeguards are in place where required by applicable data protection law.

By choosing to use certain third-party platforms to communicate or work with me, your information may also be processed according to the location and infrastructure of those providers.

11. Cookies and Website Analytics

My website may use cookies and similar technologies.

Cookies are small files placed on your device that may help the website operate correctly, remember preferences, understand website traffic or improve your experience.

Some cookies may be essential for the functioning of the website, while others may be used for analytics or similar purposes.

Where required, you will be given the opportunity to manage non-essential cookie preferences.

You can also restrict or delete cookies using your browser settings, although doing so may affect certain website functions.

12. Marketing Communications

I will only send promotional or marketing communications where I have an appropriate basis to do so.

Where you have subscribed to receive emails or other marketing communications, you may unsubscribe at any time by using the unsubscribe option provided or contacting me directly.

Choosing not to receive marketing communications will not affect essential communications relating to a service you have booked.

13. Testimonials

I may request a testimonial upon conclusion of my service. It is entirely at your discretion whether you provide one and how you wish to be identified.

Your decision regarding a testimonial will not affect the services you receive.

14. How Long I Keep Your Information

I retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable professional, legal, tax, insurance and regulatory requirements.

As a general practice:

• general enquiries that do not become client relationships may ordinarily be retained for up to 24 months;
• client intake forms, relevant correspondence and session records may ordinarily be retained for up to 7 years following the end of our work together, unless a longer or shorter period is appropriate or required by law, insurance or professional obligations;
• financial and transaction records may be retained for the period required by applicable accounting, tax and legal obligations;
• marketing information may be retained until you unsubscribe or withdraw your consent; and
• information connected with an actual or potential legal dispute may be retained for as long as reasonably necessary to establish, exercise or defend legal rights.

At the end of the applicable retention period, information will be securely deleted, anonymised or otherwise disposed of where reasonably practicable.

15. Your Rights

Depending on the law applicable to you and your circumstances, you may have rights in relation to your personal information, including the right to:

• be informed about how your personal information is used;
• request access to personal information held about you;
• request correction of inaccurate or incomplete information;
• request deletion of your information in certain circumstances;
• request restriction of certain processing;
• object to certain uses of your information;
• withdraw consent where processing is based on consent;
• request transfer or portability of your information where applicable;
• object to direct marketing; and
• raise a complaint with the relevant data protection authority.

Some rights are subject to legal exceptions. For example, I may need to retain certain records despite a deletion request where retention is required by law, professional obligations, insurance requirements or for the establishment or defence of legal claims.

To exercise any of these rights, please contact: hello@nyamburamarincowitz.com

I may need to verify your identity before responding to a request involving personal information.

16. Children

My website and services are not directed towards children unless a specific service has expressly been agreed for a minor and the appropriate parent or legal guardian involvement and consent arrangements are in place.

I do not knowingly collect children's personal information through this website for general marketing purposes.

17. External Websites

My website may contain links to websites or services operated by third parties.

I am not responsible for the privacy, security or content practices of external websites. I encourage you to review the privacy policy of any external website or service before providing personal information.

18. Data Breaches

If I become aware of a personal data breach affecting information for which I am responsible, I will take reasonable steps to contain and assess the breach and will make any notifications required under applicable law.

19. Changes to This Privacy Policy

I may update this Privacy Policy periodically to reflect changes to my services, technology, business practices or legal requirements.

The most recent version will be published on this website together with the date on which it was last updated.

Where a change materially affects how I process existing client information, I will take reasonable steps to bring that change to the attention of affected individuals where appropriate.

20. Contact

If you have a question about this Privacy Policy, would like to exercise a privacy right, or have concerns about how your personal information has been handled, please contact:

Nyambura Marincowitz
Email: hello@nyamburamarincowitz.com