Latest revision April 8, 2018 (Previously Revised: March 4, 2018 & Feb 14, 2015)
Thank you for visiting the Secret Garden website, herein known as “this web site”.
We are, and have always been, committed to be as clear and transparent as possible in all our communications and activities.
Data Protection Register
Secret Garden is registered with the Information Commissioners Office or ICO with Registration Reference A8255131
Note the company name under which Secret Garden is registered is Joy Hicklin-Bailey Limited
GDPR and Commitment to Data Security
Our communications and services allow you to stay informed about news, live and online events, products and ideas regarding topics you care about and receive support services from us. All information collected from you is stored in a technically and physically secure environment. We use SSL encryption to protect sensitive information online, and we do everything we can to protect user information offline. Unfortunately, no transmission over the Internet can be guaranteed to be 100% secure. We regularly monitor our systems for possible vulnerabilities and attacks and try to prevent security breaches. We implement security safeguards designed to protect your data, such as HTTPS. However, there is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. As a result, while we take reasonable measures to protect your information, we cannot ensure or warrant the security of the information that you transmit to us, and you do so at your own risk. We will never pass on or sell your data, unless we are required to do so by law (see below)
Data Controller: Secret Garden is the Data Controller for your personal information once you opt -in. Secret Garden then passes information to our email service provider -currently Mailchimp (NB you will also be asked, once you opt-in, to confirm your signup by replying to a confirmation email). Mailchimp acts as a Data Processor, in order to send you our occasional emails. If you pay via a website link to Stripe or Paypal in order to process a card payment, where you choose that option, your details would be passed to them. These organisations have been chosen as ‘best of breed’ leading organisations with excellent processes in place to protect your data. In the highly unlikely event your data were breached from a 3rd party processor they would inform us and we would then inform you.
Your Right to be Forgotten: You can unsubscribe from our newsletters and emails at any time. If in addition to this you would like us to remove your name from any lists we hold, please write to us and we will do so. (We currently hold records of people that have unsubscribed for 1 year as a record to ensure we know the history of a recent clients and since it is not uncommon for people to re-subscribe.
See the last section “Telling us when things change…” for more detail on this and other GDPR Related aspects
Notification of Data Breach: In the unlikely event our systems are compromised and there is a risk your data has been exposed, we will contact you within 72 hours
Information We Collect
1. Personally Identifiable Information
In order to serve you as our customer, we collect personally identifiable information, like names, addresses, products, phone numbers, email addresses, and sometimes credit card or bank information, when such information is voluntarily submitted, for example, when you fill out our online forms, subscribe to one of our sign up offers, respond to one of our promotions, or enquire about our products and services. We will only use your personal information for the following purposes, using formats such as printed fliers, email, phone, forum, website & text messages: (1) to deliver the products, courses &/or services to you that you have requested; (2) to validate your compliance with the terms & conditions; (3) for course and written content improvement & feedback purposes; & (4) to reach you, when necessary, regarding your use of the web site or product(s) or service(s).
We may rarely disclose personally identifiable information collected if we have received your permission beforehand (such as to fulfil a third party’s order) or in very special circumstances, such as when we believe that such disclosure is required by law or for other special cases described below.
We may also periodically conduct voluntary surveys of our subscribers & customers from time to time so we can improve on the products and services that we provide. Responses will remain confidential unless you have given permission for disclosure.
By permitting us to collect this information, you will be able to receive information on products & services that may be of interest to you, including (very rarely) related third party offers that we may send to you. You also enable us to personalise your experience with us so that we can provide you with the highest quality of service. We may also use this information to contact you about joint venture opportunities if it appears that you would be a suitable joint venture partner with us.
If you have consented to receive a newsletter, free video training or special offer or free report, you may opt out at any time by following the unsubscribe link in the newsletter or information email or by visiting the email provider directly.By submitting your email address in this way, you will receive email newsletters from us. You can cancel your participation in any of these email lists at any time by clicking the opt-out link or other unsubscribe option that is included in all emails. We only send emails to people who have authorised us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do! By submitting your email address, you also agree to allow us to use your email address for audience targeting on sites like Facebook, (where we occasionally display custom advertising to people who are interested in certain subjects). However, whether you respond to this is a matter of your own choice.
Any information about yourself or others that you submit on social media sites, including chat rooms, event invitations, and facebook forums, may be viewed by other people. As such, this personal data may be viewed, collected and used by third parties, including search engines, over which we have no control. We are not responsible for either the information you submit/post or otherwise make available in such public areas or any use that may be made of such information by any third party.
In addition, you agree that by submitting your telephone contact information on this web site and/or registering to receive the product and/or service offered herein, such act constitutes a purchase, an inquiry, we retain the right to contact you via telephone in accordance with the applicable UK regulations.
We retain your personal data while your account is in existence or as needed to provide the Services you have requested. See also ‘Telling us when things change, your access and control’, below.
We record details of all financial transactions between us.
See also other information we keep and privacy policies in the sections below on Client Notes, Film, photography and audio and Online forums and Live Events. We also encourage you to read our Terms and Conditions – a link is below.
If I work with anyone under the age of 16 I will communicate through their parent/guardian unless specifically requested or it has been specifically agreed to contact the client directly through email or phone. We take Children’s Privacy very seriously. Our Terms & Conditions only allow this web site to be accessed by, and purchases and bookings to be made by, persons eighteen (18) years or older. Due to the age restrictions of this web site, none of the information obtained by this web site applies to children. However, if your minor child has provided us with personally identifiable information, you may contact us at the phone number or mailing address listed in Section 7 herein if you want this information deleted from our records. We will then make reasonable efforts to remove your child’s information from the database that stores the information. The GDPR sets the age when someone can give their own consent to data processing at 16 (although this may be lowered to a minimum of 13 in the UK).
2. Non-Personally Identifiable Information
We also may collect various types of non-personally identifiable information to help us make your experience more enjoyable, measure site activity to identify future improvements that should be made, and compile aggregate data that does not identify you to help serve site clients better. For example, we may use such data to tailor our advertisements, develop survey questions and record statistics, for customer information or education, to improve our business, etc.
Like cookies we may use session and persistent “cookies,” session logs, web beacons, GIF/pixel tags, banner ads, third-party click tracking analytics tools (such as Google Analytics), third party retargeting networks that may display our advertisements to you on other sites that you visit to remind you about us, and third party networks that serve user-requested emails (e.g., for a refer-a-friend email) to collect non-personally identifiable or other aggregated information about site visitors.
Emails or newsletters that we send electronically may at times use tools to gather email metrics and information to improve your reader’s experience, such as the number of emails that are opened, whether they were forwarded or printed, the type of device from which they were opened, and the location (e.g. city and county) associated with the applicable IP address.
If you visit this site with an open ID (such as Facebook), you may also be sharing and integrating data with third-party social media sites. We may track aggregate, not personally identifiable, data about the number of visits to this site with an open ID, or items on this site that you choose to share with a third-party social media site. Analytics companies may also be collecting information about your online activity across various websites over time. The information collected by those third parties may include identifiers that allow those third parties to tailor the ads that they serve to your computer or other device.
Please note that you do have the option to configure most web browsers to NOT accept cookies. However, be aware that disabling cookies may keep you from having access to some functions or services on our web site or the web-hosted software that runs on our web site.
This website may at times contain links to other websites. When you follow such links to other websites you should read their own privacy policies as we are not responsible for any interactions between you and other people or organisations.
How we may use your information
The legal basis we rely on to process your data will fall into one of these categories
- Where you have given us your data in order that we may contact you – normally by email, to send newsletters and information about courses, products and services we provide
- Where processing is needed as a result of delivery or servicing of a purchase by you of a course, session or product
- For supporting you as a customer – to fix bugs, to help you and resolve service issues
- Where processing is needed for us to comply with the law. This may where necessary include an obligation to comply with legal requirements and requests from e.g. Police or HMRC. We may also disclose your personal information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, for example fraud.
- If you post or send offensive or objectionable content anywhere on or to any of our websites or apps, or otherwise engage in any disruptive behaviour at a live event, on any of our websites or forums, we may use the information that is available to us about you to stop such behaviour. This may involve informing relevant third parties such as law enforcement agencies about the content and your behaviour.
- We will not pass on your information to any other organisation for them to use for their own marketing activities. We may occasionally send you opportunities to connect with our joint venture colleagues if you so desire and sometimes third parties may join us at a Live Event. We are not responsible for ensuing communications between you and them in any way. (see also Third Party Web Sites and Third Party Actions)
Third Party Actions
We pride ourselves in working with quality companies & individuals, but have no control over the actions of those third parties. While we are not liable for any of the actions of those third parties, you should feel free to give us feedback from time to time on your experiences with any third parties to whom we work with so that we may enhance our future service to all customers. We do not control and are not liable for the actions of any third parties or joint venture colleagues who we may promote.
Third Party Web Sites
This web site, some email communication from us and/or the products and/or services offered herein may direct you to web sites that are owned and/or controlled by third parties. We have no control over those third parties and are not responsible for the content or the privacy practices of those sites or companies.
We may use your IP address to help prevent fraud, to help diagnose problems with our server, to gather broad demographic information, and to offer you products and services.
Consent for Film, Photography and Audio
Secret Garden & Joy Hicklin-Bailey may make audio recordings & video recordings & take photographs. Accepting this is part of the Terms and Conditions required to book any Secret Garden event or course. Filming and photography and audio recordings will be appropriate to the territory we share & always respectful. Any request for full confidentiality with regard to film & photography & audio recordings must be made very clearly by you at the beginning of the course to the main assistant, in writing – this will be respected & we will do our very best to maintain it. You are solely responsible for staying out of camera and video range. You may review & change your choice anytime, but must inform us verbally and in writing of any change immediately. Any photographs you submit to Secret Garden Forums (via wordpress.org) will not be used by us elsewhere, regardless of what type of forum it is.
Secret Garden Online Forums and Live Events
If you register to use an online forum, or participate in a live or Online event, please check via the Forum guidelines given that you understand whether your participation is confidential or ‘open to the public’ at the time or at a later stage. During your participation in a live event, check that you have read and listened to guidance given in joining instructions and at the opening of the course, and that you understand how to properly participate, including all matters related to privacy and confidentiality. Check also that you understand the boundaries for the whole event and for specific structures. If it is a confidential forum or live event, by participating you and all involved are agreeing to maintain in all circumstances the confidentiality and privacy of all those others who participate in the Forum or live event by keeping their email and online communications private both verbally and by keeping such messages inaccessible to other people who may use your computer.
In website forums, we enable communications between Members and we offer setting options for you to control what messages you receive. In a forum, your written messages will be seen by some or all other members. If we withdraw a product or service, such as an online forum, we will archive the information you have provided to and for it. By participating in a Secret Garden forum, or Live Event, you are agreeing to comply with all guidelines given with regard to manner of use, disclaimers, safety and boundaries. We also encourage you to read our Terms and Conditions – a link is below.
Client notes from one to one or couple sessions in person or via skype, phone or zoom are fully confidential. The only exceptions to this are if we are required by law to share the details with eg police or if we consider that emergency services or your GP should be informed because you are likely to harm yourself or someone else, or if you breach Joy’s confidence and steps need to be taken to resolve matters. Of course, however, in contracting to receive Secret Garden services you are in agreement that you are solely responsible for your own safety and well being and that of all others you come into contact with via Secret Garden. See Terms and Conditions -link below.
The notes may be handwritten or digital and are filed for reference and will be kept even if your private session work has ended. I keep information from previous sessions and email correspondence to help me provide the best service for you. Often clients return for further exploration after a gap. I have had clients who have come back to see me several years after a first series of sessions, and it helps me to have some background information and also know what we addressed at that time. I also use my notes to help me learn from what I have done in the past and to confidentially support research and writing. Notes might also be used to refer to in disputes. The notes will be destroyed following your request to be forgotten or after 7 years of inactivity . We also encourage you to read our Terms and Conditions – a link is below.
Private Session recordings
These are automatically made when skype is used. Recordings may be made of live private sessions, but this is not always the case. The recordings can be available for purchase if arranged -please do this at the beginning of the session. Recordings are sometimes deleted immediately the session ends, and sometimes will be kept until a situation is resolved. Please ask Joy at your session or before booking your first session if you need to know whether your session recording will be kept or not, or wish to purchase it (email after the event could be too late).
We only use client feedback in our marketing if permission has been given to do so. Testimonials via writing or film you have generously given for our published use online and elsewhere can be withdrawn if you deem it necessary, or you can change your identification preferences for whether we specify name/initial/anon etc but the original information may still be visible via search engines etc until the user concerned refreshes their cache.
Telling us when things change, your access and control
Right to change or correct data
Please ensure you update your personal information or tell us if it changes or is inaccurate.
You can update your details, for example your email address, password or name, title & address through “My Account” on our website if you have purchased from us and have an account with us. You can also change your email address for marketing by opting in at a sign up point on the website with the new address and deleting the old details or by writing to us to make the change for you.
You can unsubscribe from our newsletters at any time within the newsletter at the Unsubscribe live link there. If for any reason you continue to receive unwanted communications from us, please understand this will be a technical issue, not something we would want, so please contact us directly to make us aware so we can fix the problem for you.
Right to delete data
If you wish us to remove all record of your name from our system and close your website account, you can write to us requesting this and we will comply within a reasonable time frame, subject to any applicable terms and conditions relating to your account. There may be technical, legal obligations, including law enforcement requests, regulatory requirements, HMRC requirements, security maintenance, fraud and abuse prevention and contractual enforcements which can constrain this. We will tell you when your request has been fulfilled. We will consider and respond to all requests in accordance with applicable law. We will retain your information for as long as necessary but only for the uses set out in this Policy.
You should not, but conceivably may, owing to a technical hitch we do not know about, still receive communications from us until the unsubscribe has been effected on our systems, which will happen within a reasonable time frame. Please contact us directly if you have unsubscribed but still receive communication, as we do wish to comply with your wishes.
Right to access your data
You may request a copy of your personal information, client notes and financial transactions which we may hold about you (for which we charge an appropriate processing fee).
To view Terms and Conditions go here: Terms and Conditions