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Privacy Policy

Privacy Policy (GDPR-Compliant)
Effective Date: 7 April 2025
Last Updated: 7 April 2025
 

Dr BL Ciccarelli Coaching and Consulting Services (“we”, “us”, “our”) is committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR). This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website [www.dare2be2happy.com] and services.
 

1. Who We Are

Data Controller:
[Dr BL Ciccarelli Coaching and Consulting Services]
[barbara@dare2be2happy.com]
 

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us at the details above.
 

2. What Data We Collect

We may collect the following types of personal data:

a. Information You Provide Voluntarily

  • Full name

  • Email address

  • Phone number

  • Payment and billing details

  • Coaching session notes (if applicable)

  • Any other data you voluntarily submit through contact forms, email, or booking tools

b. Automatically Collected Information

  • IP address

  • Browser type

  • Device data

  • Usage statistics (e.g., pages visited, session duration)

  • Cookies and similar technologies
     

3. Legal Basis for Processing

Under the GDPR, we process your personal data based on the following legal grounds:

  • Consent – when you voluntarily submit your information

  • Contractual necessity – to deliver coaching services or fulfill agreements

  • Legal obligation – to comply with tax, regulatory, or legal requirements

  • Legitimate interest – to improve our services, ensure website security, and grow our business (balanced with your rights)
     

4. How We Use Your Data

We use your personal data to:

  • Provide and manage coaching services

  • Communicate with you (e.g., appointment confirmations, responses to inquiries)

  • Send newsletters or updates (only if you opt in)

  • Improve our website and user experience

  • Comply with legal obligations

  • Maintain financial and administrative records
     

5. Data Retention

We retain your personal data only as long as necessary for the purposes outlined above, or as required by law (e.g., financial records kept for 7 years). Coaching session notes, if kept, will be retained no longer than necessary and securely destroyed thereafter.
 

6. International Data Transfers

If your data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

  • Transfers to countries with an adequacy decision by the European Commission

  • Use of Standard Contractual Clauses (SCCs)

  • Transfers to US-based service providers certified under the EU-U.S. Data Privacy Framework (where applicable)
     

7. Your Data Protection Rights

As an EU data subject, you have the following rights:

  • Access – You can request a copy of your personal data

  • Rectification – You can request correction of inaccurate or incomplete data

  • Erasure (“right to be forgotten”) – You can request deletion of your data

  • Restriction – You can request we limit processing of your data

  • Objection – You can object to data processing based on legitimate interest

  • Data portability – You can request your data be transferred to another service provider

  • Withdraw consent – You may withdraw your consent at any time (e.g., email marketing)

To exercise your rights, please contact us at [barbara@start-where-you-are.com].

You also have the right to lodge a complaint with your local Data Protection Authority.
 

8. How We Share Your Data

We do not sell your data. We may share your information with:

  • Trusted third-party service providers (e.g., scheduling tools, payment processors)

  • Legal or regulatory authorities, if required

  • Others, only with your explicit consent

All processors are contractually obligated to comply with GDPR.
 

9. Cookies

We use cookies to improve your experience, analyze usage, and personalize content. You can manage cookie preferences through your browser settings. 
 

10. Security Measures

We take reasonable steps to protect your data, including:

  • Encrypted storage

  • Secure SSL protocol

However, no system is 100% secure, and we cannot guarantee absolute security.
 

11. Links to Other Websites

Our website may include links to third-party websites. We are not responsible for their privacy policies or practices.
 

12. Updates to This Policy

We may update this policy to reflect changes in regulations or our business practices. You will be notified of significant changes via email or website notice.
 

13. Contact Us

If you have any questions about this Privacy Policy or your personal data:

Dr BL Ciccarelli Coaching and Consulting Services
barbara@dare2be2happy.com
 

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