Privacy Policy

Effective Date: 25th March 2025

This Privacy Policy explains how Andrew T. Austin and The Fresh Brain Company Ltd (“we”, “our”, or “us”) collect, use, protect, and handle your personal information in accordance with the General Data Protection Regulation (GDPR) and other applicable UK data protection laws.

1. Who We Are

This website is operated by Andrew T. Austin and The Fresh Brain Company Ltd, based in the United Kingdom. We offer coaching, therapy, training, and educational services both online and in person.

2. Information We Collect

We may collect the following types of personal data when you use our services or visit our website:

Name
Email address
Phone number (if provided)
Postal address (if relevant for billing or correspondence)
Details you provide through contact forms or session notes
Payment information (processed securely through third-party providers)
Website usage data (IP address, browser, referral source, etc.)

3. How We Use Your Information

We use your information to:

Respond to your enquiries and provide services
Manage bookings and sessions
Send relevant communications you have opted into
Process payments and issue invoices
Maintain secure internal records (e.g. for insurance, clinical, or tax purposes)
Improve the quality and functionality of our website

4. Confidentiality and Data Sharing

All client communications and personal data are treated with the highest level of confidentiality. No confidential or identifying data is ever shared with other health professionals, organisations, or peers unless we have your clear, informed, and written consent.

There are rare exceptions where we may be legally required to disclose information without consent, such as if:

There is a risk of serious harm to you or others
A child or vulnerable adult is at risk of harm
We are required to comply with a legal obligation or court order

5. Lawful Basis for Processing

We rely on the following lawful bases under GDPR:

Consent – for optional communications or marketing
Contract – when providing services to you
Legal obligation – to meet compliance requirements
Legitimate interests – to operate and grow our business appropriately

6. Data Storage and Security

Your personal data is stored securely using encrypted digital systems and secure servers. We take all reasonable steps to ensure your data is protected from loss, misuse, unauthorised access, or disclosure.

7. Data Retention

We retain your personal data only as long as necessary for the purposes it was collected. In most cases, session records and communications are kept for up to 7 years to comply with professional and insurance requirements, after which they are securely deleted.

8. Your Rights

You have the right to:

Access your personal data
Request correction of inaccurate data
Request deletion (where legally permissible)
Restrict or object to processing
Withdraw consent (where consent is the lawful basis)
Lodge a complaint with the Information Commissioner’s Office (ICO)

9. Cookies

This site uses cookies to enhance your experience and gather basic analytics data. You can accept or decline cookies via your browser settings or via the cookie banner when you first visit the site.

10. Third-Party Services

We may use trusted third-party services to help us operate this website and deliver services. These may include:

Email newsletter providers (e.g. Mailchimp)
Payment processors (e.g. PayPal, Stripe)
Booking and scheduling software
Analytics tools (e.g. Google Analytics)

These providers are GDPR-compliant and only process your data as necessary to support our services.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect legal changes or improvements to our practices. The latest version will always be available on this page with an updated date.

12. Contact

If you have any questions about this Privacy Policy or how your data is handled, please contact us via freshnewbrain@gmail.com