Privacy Policy

Sep 23, 2026

Who we are

This Privacy Policy explains how Wholeness with Willene Ltd (“we”, “us”, “our”), a counselling and coaching practice registered in Ireland and operated by Willene Freddy, collects, uses, and protects your personal data when you visit our website, book a session, or work with us as a client.

For the purposes of GDPR, Wholeness with Willene Ltd is the Data Controller of your personal data.

Contact: [email protected]. Registered office: 61 Belmont Green, Newbridge, W12 W110, Kildare, Ireland. Company registration number: 691425 (registered 29 March 2021). VAT registration number: IE3751461IH.

What personal data we collect

• Contact details: name, email address, phone number, and, where relevant, postal address
• Appointment and booking information, collected via Calendly
• Payment information, processed via SumUp (we do not store your card details ourselves)
• Information you share during sessions, including sensitive health and personal information relevant to counselling or coaching (see Special category data, below)
• Session recordings and transcripts, where you have separately consented to this via Quill Meet
• Website usage data, such as pages visited (see Cookies, below)

Special category (health) data

As a counsellor and coach, information you share with us in sessions, including anything relating to your mental health, physical health, or personal history, is “special category data” under GDPR (Article 9). We only process this data with your explicit consent, given when you agree to our Client Contract and begin working with us.

We keep session notes securely and confidentially, in line with BACP’s ethical framework.

Legal basis for processing

We process your personal data on the following bases:

• Consent: for special category (health) data shared in sessions, and for optional things like session recording
• Contract: to provide the counselling or coaching service you have booked, under our Client Contract
• Legitimate interests: for basic administrative tasks, such as sending appointment reminders
• Legal obligation: where we are required to keep or disclose records by law

Who we share your data with

We use the following processors to run our practice. Each is bound by a data processing agreement:

• Microsoft 365 (via GoDaddy as reseller): email and file storage
• Zoom: online sessions
• Calendly: booking and scheduling
• Adobe Sign: signing contracts and consent forms
• SumUp: payment processing
• OneDrive: file storage
• Quill Meet: session transcription, only where you have separately consented

We do not sell your personal data, and we do not share it with anyone else except where required by law or to protect someone’s safety (see Confidentiality and its limits, below).

Continuity of care

If Willene Freddy dies or becomes incapacitated, a named executor will contact and support existing clients to help ensure continuity of care.

International transfers

We work with clients based in Ireland, the UK, Europe, and South Africa. Where personal data is transferred outside Ireland, including to or from South Africa, we take appropriate steps to protect it. For South African clients, this processing is also subject to South Africa’s Protection of Personal Information Act 4 of 2013 (POPIA), and is carried out on the basis of your consent and to perform our contract with you. South African clients have the right to lodge a complaint with the Information Regulator of South Africa at www.justice.gov.za/inforeg.

How long we keep your data

We keep your personal data, including session notes, for around 7 years after our last contact with you, in line with common practice among counselling and coaching practices in Ireland and the UK.

Outside of this, we will keep your personal data only for as long as necessary for the purposes set out in this policy, and to meet our professional and legal obligations.

Your rights

Under GDPR, you have the right to:

• Access the personal data we hold about you
• Ask us to correct inaccurate data
• Ask us to delete your data, where we are not required to keep it
• Object to how we use your data
• Ask us to restrict how we use your data
• Withdraw consent at any time, where consent is our basis for processing

To exercise any of these rights, contact [email protected]. You also have the right to complain to the Data Protection Commission, Ireland’s supervisory authority for data protection, at www.dataprotection.ie.

Cookies

Our website uses cookies to help it function and to understand how visitors use it.

Cookie	Provider	Category	Purpose	Duration
fazcookie-consent	This website	Strictly necessary	Stores the cookie consent preferences set by the visitor.	6 months
_ga	Google Analytics	Analytics	Used to distinguish unique visitors to the website.	2 years
_ga_<ID>	Google Analytics 4	Analytics	Used to maintain session state and collect statistics on how visitors use the website.	2 years
__cf_bm	Cloudflare	Strictly necessary	Helps to distinguish between humans and bots, protecting the website from malicious traffic.	30 minutes
cf_clearance	Cloudflare	Strictly necessary	Records that a visitor has passed a security check, so they are not asked to complete it again. Only set if a challenge is triggered.	Up to 1 year
et-editor-available-post-*	Divi (Elegant Themes)	Functional	Used internally by the website’s page builder, normally only for logged-in administrators.	Session

Confidentiality and its limits

What you share with us in sessions is treated as confidential, in line with the BACP Ethical Framework. There are limited circumstances where we may need to break confidentiality, including where:

• We believe you or someone else is at serious risk of harm
• We are required to disclose information by law or court order
• We are required to do so under our professional or clinical supervision arrangements (in anonymised form, for the purpose of ensuring good practice)

Where possible, we will discuss this with you before any disclosure is made.

Children’s privacy, changes to this policy, and contact

Our services and this website are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18.

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated “last updated” date.

If you have any questions about this policy, or wish to exercise your rights, contact us at [email protected]. You can also complain to the Data Protection Commission at www.dataprotection.ie.