1. Who is responsible for your information
Victoria E Armstrong, trading as Inner Mind Centre, is the data controller for the personal information processed to operate our website, practitioner directory, membership administration and our own services.
Address: Plaza el Molar 3, La Marina, Alicante, 03194, Spain
For privacy enquiries or to exercise your rights, use our contact page. You may also write to our business address.
This policy explains our processing. Independent practitioners are normally responsible for the information they process for their own client relationships and sessions. Their privacy notices apply to that processing.
2. Information we collect
Depending on how you use our services, we may collect:
- Names and contact details supplied in forms, enquiries or membership applications
- Practitioner biographies, business details, photographs, service descriptions, qualifications, insurance evidence and links to external channels
- Account details, membership status and communications with our team
- Enquiry details and the practitioner you choose to contact
- Billing details, invoices, transaction references and payment status for services purchased from Inner Mind Centre
- Event registrations and participation information
- Newsletter subscriptions and records of consent or withdrawal
- Technical information such as IP address, browser details, access logs and cookie preferences, where generated by the services you use
- Messages sent through a chatbot or WhatsApp service, where that feature is offered
- Image, voice and contributions where a recording or promotional activity has been separately agreed
Information comes principally from you, your use of the site and payment providers reporting transactions for our own services. Where another person supplies your details, we will provide the required information about that processing.
We do not collect session payments on behalf of practitioners. Their payment arrangements are separate.
3. Why we use information and our legal bases
| Purpose | Legal basis |
|---|---|
| Respond to a request about purchasing our services | Steps requested before entering a contract |
| Answer general enquiries and route a requested message to a practitioner | Our legitimate interest in responding to enquiries and facilitating the contact requested by the visitor |
| Assess and process practitioner applications, including reviewing professional details, qualifications and suitability for the Centre | Steps requested before entering a contract, and our legitimate interests in maintaining quality and trust standards for customers and members |
| Create and administer practitioner memberships and agreed profiles | Performance of our agreement with the practitioner |
| Deliver our own technical, promotional or event services | Performance of a contract or requested steps before a contract |
| Maintain invoices and other legally required records | Compliance with legal obligations |
| Protect accounts, prevent misuse and handle complaints or legal claims | Our legitimate interests in security, fair platform operation and protecting legal rights |
| Send an optional newsletter | Consent |
| Use optional cookies or advertising technologies requiring consent | Consent |
| Publish agreed podcast or promotional recordings | The legal basis identified in the separate participation and publicity notice |
| Operate an optional networking group | Consent to optional participation, with the group information provided before joining |
Where we rely on legitimate interests, we consider the effect on your rights and limit processing to what is reasonably necessary. You may object to this processing.
Optional marketing consent is not a condition of practitioner enquiries or membership. You can unsubscribe using the link in a newsletter or contact us through our contact page.
4. Required and optional information
Forms identify any information needed to deal with your request or provide a service. Without required contact, account or billing information, we may be unable to respond, establish membership or deliver the requested service.
Optional profile content and optional marketing subscriptions are your choice. Private administrative information, such as insurance evidence and billing records, is not intended for publication in a practitioner profile.
5. Public profiles and enquiries to practitioners
Practitioner profiles are public. Publish only information you intend to share publicly, including photographs, qualifications, business contact details and links.
Public information may be viewed or indexed by search engines and copied by others. Removing a profile from our site does not guarantee immediate removal from search results or third party copies.
When you choose to contact a practitioner through a form, the contact information and enquiry needed to respond will be passed to that practitioner. The form will identify the intended recipient.
Inner Mind Centre may retain the enquiry for routing, support and complaint handling. The practitioner is responsible for their subsequent client communications and independent services.
We do not authorise practitioners to add enquirers to unrelated marketing lists without the necessary permission.
6. Health and other sensitive information
Our general forms and service navigation are not intended to collect medical histories, symptoms, diagnoses or other sensitive information.
Please discuss any information needed for a session directly with the practitioner through their appropriate arrangements. Do not put sensitive information into a public profile, networking group or general website chatbot.
If sensitive information is received unintentionally, we will restrict its use and take appropriate steps to remove it or otherwise handle it lawfully. It will not automatically be used to personalise recommendations or advertising.
Any future feature intended to collect or analyse health information will require a separate privacy assessment, an appropriate legal basis and a clear notice before use.
7. Service providers and recipients
We share information only where necessary for the purposes described here. Recipients may include:
- The practitioner you ask to contact
- GoHighLevel and its relevant service providers for website, forms, communications, membership and related platform functions
- Where our chatbot is enabled, the AI model providers that power it through GoHighLevel, such as OpenAI
- Stripe, PayPal or another identified payment provider for payments for our own services
- Technical support providers working under appropriate confidentiality and data protection arrangements
- Professional advisers, public authorities or others where disclosure is legally required or necessary to establish, exercise or defend legal claims
Payment providers may process some information as independent controllers under their own privacy notices.
Where WhatsApp or YouTube is used, the relevant platform also processes information under its own arrangements. An optional group or a public video is not a private communication with Inner Mind Centre alone.
We do not sell personal contact information. Public profile publication and your requested disclosure to a practitioner are described above.
8. Processing outside the European Economic Area
Some service providers, including HighLevel and providers supporting payment, communication or AI services, may process information outside the European Economic Area, including in the United States.
Where a transfer is subject to GDPR restrictions, an appropriate transfer mechanism must apply, such as an applicable adequacy decision or European Commission Standard Contractual Clauses, together with additional safeguards where necessary.
You may request information about the safeguards and how to obtain a copy through our contact page, subject to necessary protection of confidential information.
9. Chatbots and automated processing
Where enabled, our AI chatbot, provided through GoHighLevel’s Conversation AI feature, may process the messages you submit to provide general website assistance. Conversation AI is powered by large language models supplied by third party AI providers, such as OpenAI, which process your messages to generate responses. Messages may also be accessible to our team for follow up, support and quality review.
The chatbot is not intended to make decisions producing legal or similarly significant effects, diagnose conditions or determine eligibility for treatment.
You can use our contact page to request human assistance.
10. WhatsApp, newsletters and publicity
Joining an optional practitioner WhatsApp group is voluntary. In an ordinary group, other members may see your telephone number, profile details and messages. We will explain the visibility arrangements before inviting you to join.
Group participation does not authorise publication of group discussions or enrolment in unrelated marketing.
You can leave a group or withdraw optional marketing consent. This does not undo processing that was lawful before withdrawal or remove copies of messages already received by other members.
Podcast, event recording and promotional participation will be covered by a separate notice explaining the intended publication, platforms, permissions and applicable retention.
11. How long we keep information
We apply retention according to the purpose and legal requirements:
- Enquiries are kept for 12 months after our last contact with you, then deleted or anonymised unless there is a justified continuing need
- Applications from people we do not accept are kept for 12 months after our decision, then deleted
- Membership, billing and tax records are kept for the duration of the membership plus six years, to meet legal, accounting and tax obligations and to deal with any reasonably anticipated claims
- Public profiles are taken off the website within 30 days of a practitioner leaving or asking us to remove them, or sooner where we remove a profile ourselves. Where a practitioner asks us to delete their information permanently, we will do so, except for records we are legally required to keep
- Marketing details are kept until you withdraw consent. If you unsubscribe, we keep a minimal suppression record so that your choice is honoured
- Chatbot messages are kept for 90 days
- Security logs and cookie records are kept only for as long as their purpose requires
- Agreed published recordings may remain available for the period described in the relevant participation notice
We consider the nature of the information, completion of the service, applicable statutory periods and any unresolved complaint or claim. Where records must be retained, access will be limited appropriately.
12. Security
We use reasonable technical and organisational measures appropriate to the information and the risks, including restricted access and appropriate service provider arrangements.
No online system can guarantee complete security. Please keep account credentials secure and report suspected misuse through our contact page.
13. Your rights
Subject to the conditions in data protection law, you may request access, correction, erasure, restriction of processing or data portability. You may object to processing based on legitimate interests and withdraw consent where processing relies on it.
For direct marketing, you may object at any time.
To exercise your rights, use our contact page or write to our business address. We may request proportionate information to verify your identity when necessary. We normally respond within one month; any lawful extension will be explained.
You may complain to the Spanish Data Protection Agency, Agencia Española de Protección de Datos, at aepd.es, or to another competent supervisory authority.
14. Age restriction and policy changes
Our accounts and booking features are intended for adults aged 18 or over. If you believe we have received information from a child through these features, please contact us.
We will update this policy when processing changes. Significant new purposes will be explained before the relevant information is used, with fresh consent obtained where required.