1.       Introduction

1.1     We are committed to safeguarding the privacy of our website visitors and clients; in this policy we explain how we will handle your personal data.

1.2     We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

2.       Credit

2.1     This document was created using a template from SEQ Legal (https://www.seqlegal.com).

3.       How we use your personal data

3.1     In this Section 3 we have set out:

(a)     the general categories of personal data that we may process;

(b)     the purposes for which we may process personal data; and

(c)     the legal bases of the processing.

3.2     We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system and Facebook Pixels. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3     We may process "account data". The account data may include your name and email address. The source of the account data is you or your legal guardian if under 18 years of age. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.4     We may process your information included in your personal profile on our website "profile data". The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

3.5     We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include medical information, information and notes about you relating to any therapy sessions you might attend, attendance records and information and notes about you relating to any course or programme you attend. The source of the service data is you or your employer, or legal guardian if under the age of 18 years. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.6     We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.7     We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.

3.8     We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data").The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.9     We may process information that you provide to us for the purpose of subscribing to our email notifications and newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. You can unsubscribe from our direct marketing communications at any time.

3.10   We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.11   We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12   In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.13   Please do not supply any other person's personal data to us, unless we prompt you to do so.

4.       Providing your personal data to others

4.1     We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes set out in this policy.

4.2     We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

4.4     Financial transactions relating to our services may be handled by our payment services providers, including PayPal and  Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

4.6     In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5.       International transfers of your personal data

5.1     In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2     We and our other group companies have offices and facilities in the UK. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of this country. 

5.3     The hosting facilities for our website are situated in the UK. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of this country.

5.5     You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.       Retaining and deleting personal data

6.1     This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2     Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3     We will retain and delete your personal data as follows:

Account data and Service data, will be retained indefinitely. unless otherwise indicated by you, in which case it will be deleted from our systems.

6.5     Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.       Amendments

7.1     We may update this policy from time to time by publishing a new version on our website.

7.2     You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3     We may notify you of changes to this policy, for example, by email or through the private messaging system on our website.

8.       Your rights

8.1     You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)     the payment of a fee (currently fixed at GBP 10); and

(b)     the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2     We may withhold personal information that you request to the extent permitted by law.

8.3     You may instruct us at any time not to process your personal information for marketing purposes.

8.4     In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9.       About cookies

9.1     A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2     Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3     Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10.     Cookies that we use

10.1   We use cookies for the following purposes:

(a)     authentication - we use cookies to identify you when you visit our website and as you navigate our website.

(b)     status - we use cookies to help us to determine if you are logged into our website.

(c)     personalisation - we use cookies to store information about your preferences and to personalise the website for you.

(d)     security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.

(e)     advertising - we use cookies to help us to display advertisements that will be relevant to you.

(f)      analysis - we use cookies [to help us to analyse the use and performance of our website and services.

(g)     cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

11.     Cookies used by our service providers

11.1   Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2   We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available on their website.

11.3   We may publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies.

11.4   You can view, delete or add interest categories associated with your browser. You can also opt out of the AdSense partner network cookie by using the Network Advertising Initiative's multi-cookie opt-out. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser, your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using Google browser plug-ins.

12.     Managing cookies

12.1   Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Up-to-date information about blocking and deleting cookies will be available in your browser.

12.2   Blocking all cookies will have a negative impact upon the usability of many websites.

12.3   If you block cookies, you will not be able to use all the features on our website.

13.     Our details

13.1   This website is owned and operated by Sounds Positive Ltd.

13.2   We are registered in England and Wales under registration number 5249134, and our registered office is at 23 Holyrood Close Caversham RG4 6PZ

13.3   You can contact us:

(a)     by post, using the postal address Lysette Offley, c/o Centrilogic, 5 Arlington Square, Bracknell, Berkshire, RG12 1WA

(b)     using our website contact form:

• https://genius-material.com/contact/
• https://soundspositive.com/contact/
• https://www.genius-material.com/contact/
• https://GeniusPrinciples/contact/

14.     Data protection officer

14.1   Our data protection officer's contact details are:

Lysette Offley. Contact details as above.