OpenRabbit Coaching
Client Privacy Notice
This privacy notice tells you what to expect us to do with your personal information when you use our coaching, EFT (Emotional Freedom Technique), or hypnotherapy services.
Contents:
- Contact details
- What information we collect, use, and why
- Special category data (health information)
- Lawful bases and data protection rights
- Where we get personal information from
- Third-party tools and processors
- How we keep your information secure
- How long we keep information
- How to make a data protection complaint
- How to contact the ICO
Contact details
OpenRabbit Coaching
Email: we***********@********it.com
What information we collect, use, and why
To provide and improve our coaching, EFT, and hypnotherapy services
We collect and use the following information:
- Names and contact details
- Health and mental wellbeing information shared during sessions (see Special Category Data section below)
- Session notes and progress information
For information updates and marketing purposes
We collect and use the following information:
- Names and contact details
- Email address (for newsletter and workshop communications, where you have given consent)
Special category data (health information)
Because we provide coaching, EFT, and hypnotherapy services, we process information about your health and mental wellbeing. Under UK data protection law, this is classified as special category data, which receives a higher level of protection.
This may include information about:
- Stress, burnout, or mental and emotional health
- Physical symptoms related to stress or overwork
- Personal circumstances that you share in the context of coaching or therapy sessions
We only collect this information because you choose to share it with us in the course of receiving our services. We will never ask for more than is necessary.
Our lawful basis for processing special category data:
- Explicit consent — you have given us your clear, specific consent to process this information for the purpose of delivering your coaching or therapy sessions. You have the right to withdraw this consent at any time.
We treat all health and wellbeing information with strict confidentiality, in line with our professional obligations as an ICF-accredited coach.
Lawful bases and data protection rights
Under UK data protection law (UK GDPR and the Data (Use and Access) Act 2025), we must have a lawful basis for collecting and using your personal information. You can find out more about lawful bases on the ICO’s website.
Your data protection rights are summarised below. You can find full details, including any exemptions, on the ICO’s website.
- Your right of access – You have the right to ask us for copies of your personal information, including details of where we get it from and who we share it with.
- Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
- Your right to erasure – You have the right to ask us to delete your personal information.
- Your right to restriction of processing – You have the right to ask us to limit how we use your personal information.
- Your right to object to processing – You have the right to object to the processing of your personal data.
- Your right to data portability – You have the right to ask us to transfer your personal information to another organisation, or directly to you.
- Your right to withdraw consent – Where we rely on consent, you can withdraw it at any time. This does not affect the lawfulness of processing before withdrawal.
If you make a request, we will respond without undue delay and in any event within one month. To make a request, please use the contact details at the top of this notice.
Our lawful bases for each processing activity
For providing and improving our coaching, EFT, and hypnotherapy services:
- Consent – you have given permission after receiving all relevant information. You may withdraw consent at any time.
- Contract – we need to process certain information to carry out our agreement with you.
For health and mental wellbeing information (special category data):
- Explicit consent – you have given clear, specific permission for us to process this information as part of delivering your sessions.
For information updates and marketing:
- Consent – you have given permission after receiving all relevant information. You may withdraw consent at any time.
Where we get personal information from
- Directly from you, via session enquiries, intake forms, or during sessions
- Via our booking and communication tools (see Third-Party Tools section below)
Third-party tools and processors
We use a small number of trusted third-party tools to run our practice. These tools may process your personal data on our behalf. We only use tools that meet appropriate data protection standards.
These currently include:
- TidyCal – for appointment scheduling
- MailerLite – for email communications and newsletters
- Zoom – for online sessions (US-based; data may be processed outside the UK)
- Google Meet – for online sessions (US-based; data may be processed outside the UK)
- WhatsApp – for client communications (US-based; data may be processed outside the UK)
Where tools are based in the United States, your data may be transferred to and processed in the US. The US meets the UK’s data protection test for international transfers, meaning it is considered to provide a standard of protection not materially lower than the UK. Each of these providers maintains appropriate safeguards.
We do not sell your personal data to any third party, and we do not share it for any purpose other than delivering our services to you.
How we keep your information secure
We take the security of your personal data seriously. Our measures include:
- Using password-protected and encrypted devices for all client records
- Using secure, reputable platforms for video sessions and communications
- Keeping session notes in password-protected files
- Not sharing your information with anyone outside of the third-party tools listed above
How long we keep information
We will keep your name and contact details for as long as you remain a client or subscriber, or until you withdraw your consent, whichever comes first.
Session notes and health information are kept for as long as is necessary to deliver your coaching or therapy, and for a reasonable period afterwards in line with professional practice obligations. If you would like us to delete this information sooner, please contact us.
How to make a data protection complaint
We take all concerns about your personal data seriously. If you have a concern, please contact us first using the details at the top of this notice.
What to expect when you raise a complaint with us:
- We will acknowledge your complaint within 30 days of receiving it.
- We will investigate your complaint and keep you updated on progress.
- We will communicate the outcome to you without undue delay.
Under the Data (Use and Access) Act 2025, which takes effect from 19 June 2026, individuals are required to raise complaints with us before escalating to the Information Commissioner’s Office (ICO). If you remain unhappy with our response, or if we fail to respond within a reasonable time, you may then escalate your complaint to the ICO.
How to contact the ICO
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Last updated: April 2026
This notice will be reviewed and updated as required when data protection laws change.