Privacy Notice

This privacy notice applies to information that we (INTRAEGO d.o.o.) collect about:

People who contact us, including people who fill out the forms on our websites, and subscribe to our newsletters or other updates.
People who use our psychotherapy, counselling, supervision, training, consultancy, coaching, or any other services, or are in any other capacity involved with our business (Clients).

The purposes of processing

Personal data is collected for us to provide our services to our clients (e.g., psychotherapy, counselling, supervision, training/teaching, coaching, consultancy), as well as for the following purposes: contacting people based on their enquiries, sending out an occasional newsletter/update, managing contacts, sending emails/messages, running websites.

Cookies

Like many websites, our websites also use cookies. Cookies contain information that is transferred to your device and record information about your online preferences.

Cookies are used to help us provide you with a good experience when browsing the websites and allow the websites to be improved.

You may restrict or block the cookies which are set by our websites through your browser settings.

Our websites run on a third-party provider platform, so the cookies used are largely determined by the platform provider. The cookies used to support Google Analytics are also used. You can find more information about which cookies are used and how here.

People who contact us

Contacting us may include emailing us, texting us, calling us, filling out contact forms or any other form on our websites. The information you enter into website contact forms and the emails you send may be used for future correspondence, entering into a contract with you, and the provision of services you might request.

Any email sent to us, including any attachments, may be monitored and used by us for reasons of security. Email monitoring or blocking software may also be used.

People who subscribe to our newsletters

By filling out forms on our websites, you may subscribe to our newsletters. You can also subscribe through other platforms or means, such as when registering for our training/educational or other events.

Clients

Clients are considered all individuals that are users of our psychotherapy, counselling, supervision, training/teaching/education, consultancy, coaching or any other services unless specifically stated otherwise. Psychotherapy and counselling may also be referred to under a common term of ‘therapy’.

Personal information that we obtain

Personal information means any information about an individual from which that individual can be identified. We may obtain, use, store and transfer different kinds of personal information about you.

Identity and contact information includes your name, title, address, email address, telephone numbers, etc.
Additional specific information needed if you are our psychotherapy, counselling, or coaching client. This comprises information in relation to the provision of our services, including information such a marital status, date of birth, gender, relatives, qualification, other information if it is needed for your treatment or for any other provision of our services.
If relevant, we may also obtain special category data about you. Special category data includes personal data which reveals racial or ethnic origin, religious or philosophical beliefs, trade union membership, data concerning health and data concerning a person’s sex life or sexual orientation.
Additional specific information needed if you are our supervision client (i.e. supervisee). This may include your registration with relevant regulatory bodies, professional memberships, details about your supervisors, trainers, tutors, indemnity insurance, etc.

How we use your personal information

We use your personal information for the following purposes:

For the purposes of conducting our services.
For the purpose of accounting and invoicing. We may use professional cloud-based systems for accounting, invoicing, etc. We will use minimum possible personal information when using such systems (e.g., your name, email, postal address, country of residence, etc.).
We normally use outsourced professional contractual accountants that may have access to any needed personal information intended for accounting purposes, which may include your personal data, however, who also abide to the usual degree of confidentiality generally appropriate for accounting services.
For the purpose of meeting our professionals’/employees’ professional, regulatory, and legal obligations, including with respect to their clinical or any other supervision or professional consultation.
For the purposes of regulatory or legal proceedings.
Where we believe you or others are at risk of harm and for the purposes of safeguarding you or others against such harm.

The basis upon which we process personal information

We will only use and hold your personal information (including special category information) where there is a lawful basis for us to do so. Some of the relevant lawful bases are:

Where it is necessary for our legitimate interests (for instance, in providing therapy, supervision, training/teaching, coaching, consultancy and/or any other services to you and meeting our professionals’/employees’ own professional obligations to be supervised with respect to their professional role of a therapist, supervisor, trainer/teacher, coach), which do not override your interests and fundamental rights.
Where it is necessary to comply with legal obligations.

How long we keep personal information

Personal information shall be processed and stored for as long as required by the purpose it has been collected for.

Generally, we will hold your personal information gathered for the purpose of providing therapy services for a period of seven years after the conclusion of the service, unless it is necessary to retain your personal information for longer, for example, because:

There is an ongoing possibility of regulatory or legal proceedings.
We are subject to an ongoing legal obligation.

Who we share personal information with

When providing therapy, supervision, or training services, we will only share your personal information, where it is necessary for the purposes of conducting our services, with the following:

Our professionals/employees may share your personal information with their professional/clinical supervisors for the purposes of their own professional obligations to be supervised with respect to their professional role. In such case, they will always aim to maintain your anonymity.
In training, teaching, presenting, and other services that we may conduct or our professionals’/employees’ publications, such as peer-reviewed journals, book chapters, books etc. This may include short case excerpts or descriptions and will be in anonymised format. Should such case descriptions be more substantial, we will contact you for specific consent to them.
Professional regulators and organisations where it is necessary to report potential breaches of ethical principles or codes of professional conduct.
Relevant bodies or organisations where we may be legally or otherwise obliged to do so.
Cloud tools that enable communications, storage, and analysis.
Professional outsourced accountants that are authorised to perform accountancy services for our business.
Banks in the case of conducting regulatory checks (e.g., ani-money laundering, etc.).

International transfer of personal information

We do not transfer your personal information outside of the European Economic Area except where I am using a cloud service that makes this inevitable. In such cases, these services use a valid transfer mechanism such as Standard Contractual Clauses or EU-US Data Privacy Framework.

Your rights

You have the following rights:

Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your personal data.
Request access to your personal information (commonly known as a “data subject access request”). You can request a copy of your personal information that we hold and check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to request for any incomplete or inaccurate data that we hold about you corrected.
Request erasure of your personal information. You can ask us to delete or remove personal information 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, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Object to processing of personal information where we are relying on our legitimate interests (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.
Request restriction of processing of your personal information. You can ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; or (c) you have objected to our use of your information but we need to verify whether we have overriding legitimate interest to use it.
Request the porting of your data to another provider, subject to limitations stated by the GDPR.

These rights are subject to various legal exceptions. If you make any of the requests above, we may explain to you in our response if we have relied upon any of these exceptions.

You have the right to make a complaint at any time to the Information Commissioner of the Republic of Slovenia (ICRS). Full details can be found on the ICRS’s website https://www.ip-rs.si. However, if you have any concerns, we would be grateful for a chance to deal with these before you approach the ICRS.

This privacy notice is applicable to INTRAEGO d.o.o., Rožna dolina, cesta V 14, 1000 Ljubljana, Slovenia (Company number 9718672000).

Changes to this privacy notice

We keep this privacy notice under regular review with the aim to reflect changes in law and practice.

Date: August 2024