14 October 2022
Version 1.0

This Privacy Notice complies with the EU General Data Protection Legislation. It serves as a notice for those visiting and using the website https://paths.care/. It notifies the users about the personal data that the company holds relating to their experience in the website, for what purpose it is processed and for how long it is expected to be used.

Introduction

Welcome to paths website’s privacy notice.
 
We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
 
Please also use the Glossary, at the end of this privacy notice, to understand the meaning of some of the terms used in this privacy notice.
 
 

Important information and who We are

Purpose of this privacy notice

This privacy notice aims to give you information on how paths collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, send us an email, and fill in the contact form.

If you want to learn how we process your data as a client or potential client, or when using our booking portal found in this website, please visit our Clients Privacy Notice.

This website is not intended for children and we do not knowingly collect data relating to children.

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

Controller

This privacy notice is issued on behalf of Charlene Camilleri Duca trading as paths, the controller and responsible for this website, referred to as the “Company”, “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 notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Postal address: 52, Triq Ġużè Ellul, Gwardamanġa, Malta, PTA1030
Email address: info@paths.care
Telephone number: +356 9901 3629
 
Data Protection Officer (DPO): Amira Latif
Email address: amira.l@paths.care
Telephone number: +356 9901 3629
 

Changes to the Privacy Notice and your duty to inform Us of changes

This version was last updated on 14 October 2022 and historic versions can be obtained by contacting us.

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 includes 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 notice of every website you visit.

 

The data We collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  • Identity Data includes first name and last name.
  • Contact Data includes 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 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.
  • 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 do not collect any Special Categories of Personal Data about you through the website and we ask you not to disclose any such personal data through the different forms in our site except for the Special Categories of Personal Data which you may disclose through our booking portal. Please refer to our Clients Privacy Notice for information how we process such data submitted through that portal. Nor do we collect any information about criminal convictions and offences.
 
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 information related to your query).
 
 

How is your personal data collected?

 
—- FROM HERE….
the below was kept for reference when creating a table
 
 
 
 

Your Rights

 You have the right to:

Information

We are giving you this Privacy Notice to keep you informed.

Access

Please contact our DPO if you wish to access the personal information we hold about you. 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 may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it may 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.

Rectification

Please contact our DPO if you wish to rectify your information. We will also rectify the information you have consented us to pass on to third parties, if it is the case.

Erasure

Please contact our DPO if you want us to erase all your personal data and we do not have a legal reason to continue to process and hold it.

Restrict processing

Please contact our DPO if you want us to restrict processing of your data. In this case we will restrict processing but we will still hold the data.

Data portability

Please contact our DPO if you want information on how to port your data elsewhere. This right only applies to personal data that you have provided to us as the Data Controller. The data must be held by us by consent or for the performance of a contract.

Object

You have the right to object to us processing your data even when we do so for our legitimate interests. If you wish to object please contact our DPO.

Withdraw consent

If you have given us your consent to process your data but later changed your mind, you have the right to withdraw your consent at any time. Please contact our DPO in case you wish to withdraw consent.

Complain to a Supervisory Authority

You have the right to complain to the IDPC if you feel that we have not responded to your requests to solve a problem. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner (IDPC) which is at Floor 2, Airways House, Triq il-Kbira, Sliema and can be reached on +356 2328 7100.

Changes to Our Privacy Notice

We may change this notice from time to time in the future. Changes to our privacy policy will be notified to the data subjects through the preferred means of communication.

TherapyPacks Terms and Conditions

1. TherapyPacks come in bundles of 5 or 10 sessions. Prices of bundles:

  • 5 sessions – €270 – must be utilised within 3 months from date of purchase
  • 10 sessions – €520 – must be utilised within 6 months from date of purchase

2. Bundles are not transferable. This means they cannot be used by, or gifted to, anyone else but the person whose name is listed as the TherapyPacks bundle holder.

3. Bundles which are purchased for Couples Therapy and Family Therapy can only be used by members of the couple or family with one therapist. If members of a couple or family decide to take up individual therapy with another therapist, the bundle will only apply to sessions with the therapist originally referred and cannot be also used for the individual sessions with another therapist. Exceptions will be made if the original therapist is unable to see the client or family and the couple or family are referred to another therapist. After referral, the same conditions will apply.

4. Bundles are valid for a limited time period, as listed above. This means that the bundles will expire once the respective time period has elapsed. Any sessions not utilised within this period will be lost. This means that a refund will not be given for unused sessions. Start date commences on date of purchase of bundles.

5. Bundles are only valid for full price sessions (charged at €60) and not for sessions with trainee psychotherapists, reports or assessments.

6. Full payment needs to be made on purchase, via bank transfer, cash or credit card.

7. Management reserves the right to terminate or suspend the use of the bundles. Reasons for such are at the discretion of the clinic.

8. Refunds or extensions of time period within which bundles may be used is at the discretion of management and will only be granted in exceptional circumstances.

9. Management reserves the right to modify or replace the terms and conditions. In such circumstances, clients will be given adequate notice and time to adhere to such.

10. The clinic’s cancellation policy is applicable also to bundles. Late cancellations or no shows will result in the forfeit of a session within the bundle allocation.

11. Responsibility for ensuring timely use of session bundles remains that of the TherapyPacks bundle holder or, in the case of a minor, their carer/legal guardian.