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Clear Sky Psychology Privacy Policy 


Welcome to the Clear Sky Psychology privacy policy.  

Clear Sky Psychology takes the privacy rights of all its clients seriously and adopts a high standard  of compliance and confidentiality when dealing with your data. Clear Sky Psychology wants you to  understand that this is a safe place for you to discuss your feelings and concerns and Clear Sky Psychology operates in a highly confidential environment. This privacy policy sets out the details of how data is  collected and processed through the use of our website. 

  1. Important information and who we are 

Purpose of this privacy policy 

This privacy policy aims to give you information on how Clear Sky Psychology collects and  processes your personal data through your use of this website, including any data you may provide through  the action buttons. 

This website is not intended for children under 16 years, and we do not knowingly collect data relating to  children via our website. 

It is important that you read this privacy policy together with any other privacy policy or fair processing  policy we may provide on specific occasions when we are collecting or processing personal or sensitive  data about you so that you are fully aware of how and why we are using your data. This privacy policy  supplements other notices and privacy policies and is not intended to override them.  


Alice Kennedy is the data controller and we are responsible for your personal data (referred to as  “we”, “us” or “our” in this privacy notice). 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation  to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.  

Contact details 

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the  following ways: 

Full name of legal entity: Dr Alice Kennedy 

Email address: clearskypsychology@gmail.com 

Postal address: Clear Sky Psychology Ltd, Union House, 111 New Union Street, Coventry, CV1 2NT

Telephone number: 07857209781


You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK  supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. This version was last updated in January 2021.  

It is important that the personal data we hold about you is accurate and current. Please keep us informed if  your personal data changes during your relationship with us. 

Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or  enabling those connections may allow third parties to collect or share data about you. We do not control  these third-party websites and are not responsible for their privacy statements. When you leave our  website, we encourage you to read the privacy policy of every website you visit. 

  1. The data we collect about you 

Personal data, or personal information, means any information about an individual from which that person  can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped  together as follows: 

  • Identity Data includes first name, last name, username or similar identifier, marital status, title,  date of birth and gender. 
  • Contact Data includes billing address, delivery address, email address and telephone numbers. 
  • Financial Data includes bank account and payment card details. 
  • Transaction Data includes details about payments to and from you and other details of  products and services you have purchased from us. 
  • Technical Data includes internet protocol (IP) address, your login data, browser type and  version, time zone setting and location, browser plug-in types and versions, operating system  and platform, and other technology on the devices you use to access this website.  
  • Profile Data includes your username and password, purchases or orders made by you, your  interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.  
  • Marketing and Communications Data includes your preferences in receiving marketing from  us and our third parties and your communication preferences. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.  Aggregated Data could be derived from your personal data but is not considered personal data in law as  this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data  to calculate the percentage of users accessing a specific website feature. However, if we combine or  connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat  the combined data as personal data which will be used in accordance with this privacy policy. 

  • Sensitive Data includes information about your health, including information about your existing and previous medical conditions, medication details, psychiatric history and any other relevant  health information to enable us to carry out our services to you.  
  • We require your explicit consent for processing sensitive data, so when you submit your details,  we will send you a further communication asking for you to confirm your consent to this  processing. 

We do not collect any other Special Categories of Personal Data about you (this includes details about  your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade  union membership and genetic and biometric data). Nor do we collect any information about criminal  convictions and offenses. 

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you  fail to provide that data when requested, we may not be able to perform the contract we have or are trying  to enter into with you (for example, to provide you with services or goods). In this case, we may have to  cancel a service or product you have with us but we will notify you if this is the case at the time.  

  1. How is your personal data collected? 

We use different methods to collect data from and about you including through: 

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in  forms before or during an appointment, verbally during discussions at our practice, or by  corresponding with us by post, phone, email or otherwise. This includes personal data you  provide when you: 
    • apply for our services or any of our products; 
    • create an account on our website; 
    • subscribe to our service or publications;  
    • request marketing to be sent to you; 
    • enter a competition, promotion or survey; or 
    • give us feedback or contact us.  
  • Automated technologies or interactions. As you interact with our website, we will  automatically collect Technical Data about your equipment, browsing actions and patterns. We  collect this personal data by using cookies and other similar technologies. We may also receive  Technical Data about you if you visit other websites employing our cookies. Please see our  cookie policy for further details. 
  • Third parties or publicly available sources. We will receive personal data about you from  various third parties and public sources as set out below:  

Technical Data from the following parties: 

(a) analytics providers such as Google based outside the EU;  

(b) advertising networks such as Facebook based outside the EU; and

(c) search information providers such as Google based outside the EU. 

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery  services such as Stripe or PayPal based outside the EU. 
  • Identity and Contact Data from publicly available sources such as Companies House and the  Electoral Register based inside the EU. 
  1. How we use your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal  data in the following circumstances: 

  • Where we need to perform the contract we are about to enter into or have entered into with you. 
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests  and fundamental rights do not override those interests. 
  • Where we need to comply with a legal obligation. 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get  your consent when collecting sensitive data (such as health information) and before sending third party  direct marketing communications to you via email or text message. You have the right to withdraw consent  to marketing at any time by contacting us. 

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data,  and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are  where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific  purpose for which we are using your data. Please contact us if you need details about the specific legal  ground we are relying on to process your personal data where more than one ground has been set out in  the table below. 

Purpose/Activity  Type of data  Lawful basis for processing including  basis of legitimate interest
To register you as a new  customer (a) Identity  

(b) Contact

Performance of a contract with you
To provide our services and to  process and deliver any orders including: 

(a) provide our services to you 

(b) Manage payments, fees and  charges 

(c) Collect and recover money  owed to us

(a) Identity  

(b) Contact  

(c) Financial  

(d) Transaction  

(e) Marketing and  Communications 

(f) Sensitive Data

(a) Performance of a contract with you  

(b) Necessary for our legitimate interests  (to recover debts due to us) 

(c) Explicit consent (in the case of  Sensitive Data).

To manage our relationship with  you which will include: 

(a) Notifying you about changes 

(a) Identity  

(b) Contact 

(a) Performance of a contract with you  (b) Necessary to comply with a legal 


to our terms or privacy policy 

(b) Asking you to leave a review  or take a survey

(c) Profile  

(d) Marketing and  Communications


(c) Necessary for our legitimate interests  (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a  prize draw, competition or  complete a survey (a) Identity  

(b) Contact  

(c) Profile  

(d) Usage  

(e) Marketing and  Communications

(a) Performance of a contract with you  

(b) Necessary for our legitimate interests  (to study how customers use our  products/services, to develop them and  grow our business)

To administer and protect our  business and this website  (including troubleshooting, data  analysis, testing, system  maintenance, support, reporting  and hosting of data)  (a) Identity 

(b) Contact 

(c) Technical

(a) Necessary for our legitimate interests  (for running our business, provision of  administration and IT services, network  security, to prevent fraud and in the  context of a business reorganisation or  group restructuring exercise) 

(b) Necessary to comply with a legal  obligation

To deliver relevant website  content and advertisements to  you and measure or understand  the effectiveness of the  advertising we serve to you (a) Identity  

(b) Contact  

(c) Profile  

(d) Usage  

(e) Marketing and  Communications  

(f) Technical 

Necessary for our legitimate interests (to  study how customers use our  products/services, to develop them, to  grow our business and to inform our  marketing strategy)
To use data analytics to improve  our website, products/services,  marketing, customer relationships  and experiences (a) Technical 

(b) Usage 

Necessary for our legitimate interests (to  define types of customers for our products  and services, to keep our website updated  and relevant, to develop our business and  to inform our marketing strategy)
To make suggestions and  recommendations to you about  goods or services that may be of  interest to you (a) Identity  

(b) Contact  

(c) Technical  

(d) Usage  

(e) Profile  

(f) Marketing and  Communications

Necessary for our legitimate interests (to  develop our products/services and grow  our business)



Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).  

Under the Privacy and Electronic Communications Regulations, we may send you marketing  communications from us if (i) you made a purchase or asked for information from us about our goods or  services or (ii) you agreed to receive marketing communications and in each case you have not opted out  of receiving such communications since. Under these regulations, if you are a limited company, we may  send you marketing emails without your consent. However you can still opt out of receiving marketing  emails from us at any time.  

Promotional offers from us  

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you  may want or need, or what may be of interest to you. This is how we decide which products, services and  offers may be relevant for you (we call this marketing).  

You will receive marketing communications from us if you have requested information from us or purchased  goods or services from us and you have not opted out of receiving that marketing. 

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any third party for  marketing purposes.  

Opting out 


You can ask us or third parties to stop sending you marketing messages at any time by contacting us. 


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or  access cookies. If you disable or refuse cookies, please note that some parts of this website may become  inaccessible or not function properly. For more information about the cookies we use, please see our  Cookie Policy. 

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably  consider that we need to use it for another reason and that reason is compatible with the original purpose.  If you wish to get an explanation as to how the processing for the new purpose is compatible with the  original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the  legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance  with the above rules, where this is required or permitted by law. 

  1. Disclosures of your personal data 

We may share your personal data with the parties set out below for the purposes set out in the table  ‘Purposes for which we will use your personal data’ above. 

  • Service providers, acting as processors who provide IT and system administration services.
  • Professional advisers, acting as processors or joint controllers, including healthcare  professionals, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal,  insurance and accounting services. 
  • HM Revenue & Customs, regulators and other authorities, acting as processors or joint  controllers, based who require reporting of processing activities in certain circumstances. 
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our  assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change  happens to our business, then the new owners may use your personal data in the same way as  set out in this privacy policy.  

We require all third parties to respect the security of your personal data and to treat it in accordance with  the law. We do not allow our third-party service providers to use your personal data for their own purposes  and only permit them to process your personal data for specified purposes and in accordance with our  instructions. 

  1. International transfers 

We may transfer your data outside the European Economic Area (EEA). 

Many of our external third parties are based outside the EEA so their processing of your personal data will  involve a transfer of data outside the EEA. 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is  afforded to it by ensuring at least one of the following safeguards is implemented:  

  • We will only transfer your personal data to countries that have been deemed to provide an  adequate level of protection for personal data by the European Commission. For further details,  see European Commission: Adequacy of the protection of personal data in non-EU countries. 
  • Where we use certain service providers, we may use specific contracts approved by the  European Commission which give personal data the same protection it has in Europe.  

Please contact us if you want further information on the specific mechanism used by us when transferring  your personal data out of the EEA.  

Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally  lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your  personal data to those employees, agents, contractors and other third parties who have a business need to  know. They will only process your personal data on our instructions and they are subject to a duty of  confidentiality.  

We have put in place procedures to deal with any suspected personal data breach and will notify you and  any applicable regulator of a breach where we are legally required to do so. 

  1. Data retention 

How long will you use my personal data for? 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we  collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting 

requirements. We may retain your personal data for a longer period in the event of a complaint or if we  reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and  sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your  personal data, the purposes for which we process your personal data and whether we can achieve those  purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and  Transaction Data) for six years after they cease being customers for tax purposes. 

In some circumstances you can ask us to delete your data: see your legal rights below for further  information. 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with  you) for research or statistical purposes, in which case we may use this information indefinitely without  further notice to you.  

  1. Your legal rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  You have the right to: 

Request access to your personal data (commonly known as a “data subject access request”). This  enables you to receive a copy of the personal data we hold about you and to check that we are lawfully  processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete  or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data  you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data  where there is no good reason for us continuing to process it. You also have the right to ask us to delete or  remove your personal data where you have successfully exercised your right to object to processing (see  below), where we may have processed your information unlawfully or where we are required to erase your  personal data to comply with local law. Note, however, that we may not always be able to comply with your  request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your  request.  

Object to processing of your personal data where we are relying on a legitimate interest (or those of a  third party) and there is something about your particular situation which makes you want to object to  processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have  the right to object where we are processing your personal data for direct marketing purposes. In some  cases, we may demonstrate that we have compelling legitimate grounds to process your information which  override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the  processing of your personal data in the following scenarios:  

  • If you want us to establish the data’s accuracy. 
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish,  exercise or defend legal claims.  
  • You have objected to our use of your data but we need to verify whether we have overriding  legitimate grounds to use it.  

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party  you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that  this right only applies to automated information which you initially provided consent for us to use or where  we used the information to perform a contract with you.  

Withdraw consent at any time where we are relying on consent to process your personal data. However,  this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you  withdraw your consent, we may not be able to provide certain products or services to you. We will advise  you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us.  

No fee usually required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we could refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right  to access your personal data (or to exercise any of your other rights). This is a security measure to ensure  that personal data is not disclosed to any person who has no right to receive it. We may also contact you to  ask you for further information in relation to your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a  month if your request is particularly complex or you have made a number of requests. In this case, we will  notify you and keep you updated.