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Privacy policy

Last updated: 21 September 2026

This Privacy Policy sets out the rules for storing and accessing data on the Devices of Users of the Website for the purpose of providing services by electronic means by the Administrator, as well as the rules for collecting and processing the personal data of Users which they have provided personally and voluntarily through the tools available on the Website.

§1 Definitions

  • Website – the website “Phoenix Psychotherapy” operating at https://phoenixpsychotherapywm.com/
  • External service – websites of partners, service providers or service recipients cooperating with the Administrator
  • Administrator of the Website / of the Data – the Administrator of the Website and the Administrator of the Data (hereinafter the Administrator) is “Phoenix Psychotherapy Wioleta Michalska”, operating at 7b Church Street, Dronfield, S18 1QB, United Kingdom, providing services by electronic means through the Website
  • User – a natural person for whom the Administrator provides services by electronic means through the Website.
  • Device – an electronic device together with its software, through which the User accesses the Website
  • Cookies – text data collected in the form of files placed on the User’s Device
  • Data protection law – all applicable legal provisions concerning the processing of personal data to which the Administrator is subject, in particular the UK GDPR (the United Kingdom General Data Protection Regulation) and the Data Protection Act 2018, together with national implementing provisions and regulations issued on their basis;
  • Personal data – means information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
  • Processing – means an operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • Restriction of processing – means the marking of stored personal data with the aim of limiting their processing in the future
  • Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements
  • Consent – consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them
  • Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
  • Pseudonymisation – means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
  • Anonymisation – anonymisation of data is an irreversible process of operations on data which destroys or overwrites “personal data”, making it impossible to identify or link a given record with a specific user or natural person.

§2 Data Protection Officer

The Administrator has not appointed a Data Protection Officer. For matters concerning the processing of data, including personal data, please contact the Administrator directly using the details given in §14.

§3 Types of Cookies

  • Internal cookies – files placed on and read from the User’s Device by the Website’s ICT system
  • External cookies – files placed on and read from the User’s Device by the ICT systems of External services. Scripts of External services which may place cookies on Users’ Devices have been deliberately placed on the Website through scripts and services made available and installed on the Website
  • Session cookies – files placed on and read from the User’s Device by the Website during a single session of a given Device. After the session ends, the files are removed from the User’s Device.
  • Persistent cookies – files placed on and read from the User’s Device by the Website until they are manually deleted. The files are not removed automatically after the Device session ends, unless the configuration of the User’s Device is set to delete cookie files when the Device session ends.

§4 Security of data storage

  • Mechanisms for storing and reading cookie files – the mechanisms for storing, reading and exchanging data between the Cookies saved on the User’s Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow other data to be retrieved from the User’s Device, nor data from other websites the User has visited, including personal data or confidential information. Transferring viruses, trojans and other worms onto the User’s Device is also practically impossible.
  • Internal cookies – the cookie files used by the Administrator are safe for Users’ Devices and do not contain scripts, content or information which could threaten the security of personal data or the security of the Device used by the User.
  • External cookies – the Administrator takes every possible step to verify and select the Website’s partners in the context of User safety. The Administrator selects well-known, large partners with global public trust. However, the Administrator does not have full control over the content of cookie files originating from external partners. The Administrator is not liable, to the extent permitted by law, for the security of cookie files, their content or their licensed use by scripts installed on the Website that originate from External services. A list of partners is provided further in this Privacy Policy.
  • Control of cookie files
  • Risks on the User’s side – the Administrator applies every possible technical measure to ensure the security of the data placed in cookie files. It should be noted, however, that ensuring the security of this data depends on both sides, including the User’s own actions. The Administrator is not responsible for the interception of this data, for impersonation of the User’s session or for its deletion as a result of the User’s deliberate or inadvertent actions, or of viruses, trojans and other spyware with which the User’s Device is or was infected. In order to protect themselves against these risks, Users should follow safe internet practices.
  • Storage of personal data – the Administrator confirms that every effort is made to ensure that the personal data entered voluntarily by Users is secure, that access to it is restricted and exercised in accordance with its intended purpose and the purposes of processing. The Administrator also confirms that every effort is made to protect the data held against loss, through the application of appropriate physical and organisational safeguards.

§5 Purposes for which cookie files are used

  • Improving and facilitating access to the Website
  • Personalisation of the Website for Users
  • Keeping statistics (users, number of visits, device types, connection and so on)
  • Serving multimedia services
  • Providing social media services

§6 Purposes of personal data processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

  • Provision of electronic services:
    • The Newsletter service (including sending marketing content with consent)
    • Handling messages sent through the contact form
    • Sharing information about content published on the Website on social media or other websites.
  • Communication between the Administrator and Users on matters relating to the Website and to data protection
  • Pursuing the legitimate interests of the Administrator

Data about Users collected anonymously and automatically is processed for one of the following purposes:

  • Keeping statistics
  • Pursuing the legitimate interests of the Administrator

§7 Cookie files of External services

On the Website the Administrator uses JavaScript scripts and web components of partners which may place their own cookies on the User’s Device. Please remember that in your browser settings you can decide for yourself which cookies may be used by individual websites. Below is a list of partners, or of their services, implemented on the Website which may place cookie files:

Services provided by third parties are outside the Administrator’s control. These entities may at any time change their terms of service, privacy policies, purposes of data processing and the way cookie files are used.

§8 Types of data collected

The Website collects data about Users. Some of the data is collected automatically and anonymously, and some of it is personal data provided voluntarily by Users when signing up for the individual services offered by the Website.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Subpages of the website opened
  • Time spent on a given subpage of the website
  • Operating system type
  • Address of the previous subpage
  • Address of the referring page
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected through the contact form:

  • Name
  • Email address
  • Message content
  • IP address (collected automatically)

Data collected when signing up for the Newsletter service:

  • Email address
  • IP address (collected automatically)

Some of the data (excluding identifying data) may be stored in cookie files. Some of the data (excluding identifying data) may be passed to the provider of statistical services.

§9 Access to personal data by third parties

As a rule, the only recipient of the personal data provided by Users is the Administrator. Data collected as part of the services provided is neither passed on nor sold to third parties.

Access to the data (most often on the basis of a data processing agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the website, that is:

  • Hosting companies providing hosting or related services to the Administrator
  • Companies through which the Newsletter service is provided

Entrusting the processing of personal data – Newsletter

In order to provide the Newsletter service, the Administrator uses the services of a third party – MailerLite. The data entered in the newsletter sign-up form is transferred to, stored and processed in that provider’s external service.

Please note that the named partner may modify its privacy policy without the Administrator’s consent.

Entrusting the processing of personal data – Hosting, VPS or Dedicated Server services

In order to run the website, the Administrator uses the services of an external provider of hosting, VPS or Dedicated Servers. All data collected and processed on the website is stored and processed within that provider’s infrastructure. Access to this data may occur as a result of maintenance work carried out by the provider’s personnel. Access to this data is governed by the agreement concluded between the Administrator and the Provider.

§10 Manner of processing personal data

Personal data provided voluntarily by Users:

  • Personal data may be transferred outside the United Kingdom.
    Such transfers result from the use of services of entities located outside the United Kingdom.
    Where personal data is transferred or entrusted for processing outside the United Kingdom, that data is processed on the basis of an agreement concluded between the Administrator and the Provider, supported by appropriate safeguards required by data protection law.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be sold to third parties.

Anonymous data (excluding personal data) collected automatically:

  • Anonymous data (excluding personal data) may be transferred outside the United Kingdom.
  • Anonymous data (excluding personal data) will not be used for automated decision-making (profiling).
  • Anonymous data (excluding personal data) will not be sold to third parties.

§11 Copyright

All content, materials and graphic elements placed on this website are the property of “Phoenix Psychotherapy Wioleta Michalska” and are protected by copyright vested in the Administrator.

The website as a whole constitutes a work protected under the Copyright, Designs and Patents Act 1988, to which the Administrator is subject. No part of it may be distributed or copied in any way (electronic, mechanical or otherwise) without the written consent of “Phoenix Psychotherapy Wioleta Michalska”.

Please note that the content published on the pages of this website is for information purposes only and does not constitute an offer within the meaning of contract law.

§12 Period of personal data processing

Personal data provided voluntarily by Users:

As a rule, the personal data indicated is stored only for the period during which the Administrator provides the Service as part of the Website. It is deleted or anonymised within 30 days of the end of the provision of services (for example unsubscribing from the Newsletter list).

An exception applies where it is necessary to secure the legitimate purposes of further processing of that data by the Administrator. In such a case the Administrator will store the data indicated, from the time the User requests its deletion, for no longer than 3 years.

Anonymous data (excluding personal data) collected automatically:

Anonymous statistical data which does not constitute personal data is stored by the Administrator for the purpose of keeping website statistics for an indefinite period.

§13 Users’ rights in connection with the processing of personal data

In connection with the processing of personal data, Users have the following rights:

  • Right of access to personal data
    Users have the right to obtain access to their personal data, exercised upon a request made to the Administrator
  • Right to rectification of personal data
    Users have the right to request from the Administrator the immediate rectification of personal data which is inaccurate and/or the completion of incomplete personal data, exercised upon a request made to the Administrator
  • Right to erasure of personal data
    Users have the right to request from the Administrator the immediate erasure of personal data, exercised upon a request made to the Administrator. The Administrator reserves the right to withhold the fulfilment of a request for erasure to the extent necessary to protect the legitimate interests of the Administrator, in particular where the data is necessary for the establishment, exercise or defence of legal claims.
    In the case of the Newsletter service, the User can remove their personal data themselves using the link included in every email sent.
  • Right to restriction of processing of personal data
    Users have the right to restrict the processing of personal data, among other things by contesting the accuracy of the personal data, exercised upon a request made to the Administrator
  • Right to data portability
    Users have the right to receive from the Administrator the personal data concerning them in a structured, commonly used, machine-readable format, exercised upon a request made to the Administrator
  • Right to object to the processing of personal data
    Users have the right to object to the processing of their personal data, exercised upon a request made to the Administrator
  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data. The authority competent for the Administrator is the UK Information Commissioner’s Office (ICO), ico.org.uk.

§14 Contacting the Administrator

The Administrator can be contacted in one of the following ways:

§15 Website requirements

  • Restricting the saving of and access to cookie files on the User’s Device may cause some functions of the Website to work incorrectly.
  • The Administrator accepts no liability for functions of the Website working incorrectly where the User restricts in any way the ability to save and read cookie files.

§16 External links

The Website may contain links to external sites with which the owner of the website does not cooperate. These links, and the pages or files they point to, may be dangerous for your Device or may pose a risk to the security of your data. The Administrator is not responsible for content found outside the Website.