PRIVACY POLICY
Last updated: January 5, 2025
1. Introduction
This Privacy Policy explains how Cyclical Awakening ApS ("we," "us," "our") collects, uses, stores, and protects your personal information in accordance with the EU General Data Protection Regulation (GDPR) and Danish data protection laws.
We take your privacy seriously, especially given the sensitive nature of the services we provide.
2. Data Controller
Business Name: Cyclical Awakening ApS
CVR Number: 44924595
Address: Constantin Hansens Gade 7, 1799 Copenhagen, Denmark
Email: wholewomanhood@gmail.com
Phone: +45 40403489
As the data controller, we are responsible for ensuring your personal data is processed lawfully, fairly, and transparently.
3. What Information We Collect and From What Sources
We collect personal information from the following sources:
3.1 Application Form for Mentorship
When you apply for mentorship services, we collect:
Full name
Email address
Phone number (if provided)
Location/address (city/region)
Date of birth
Information about your background, experience, and goals
Trauma history (if relevant and you choose to share)
Health information relevant to mentorship
Any other information you provide in your application
3.2 Application Form for Bodywork Services
When you apply for bodywork services, we collect:
Full name
Email address
Phone number
Date of birth
Location/address (city/region)
Medical history and current health conditions
Medications and allergies
Trauma history
Physical symptoms, pain, or areas of sensitivity
Previous injuries or surgeries
Mental health information (if relevant)
Emergency contact information
Any other information you provide in your application
3.3 General Email Inquiries
When you contact us via email, we collect:
Name (if you provide it)
Email address
Phone number (if you provide it)
Content of your inquiry or correspondence
Any information you choose to share in your communication
3.4 Newsletter Subscription
When you subscribe to our newsletter, we collect:
Email address
Name (if you provide it)
Subscription date and time
Email engagement data (opens, clicks)
3.5 Website Cookies and Technical Information
When you visit our website, we automatically collect:
IP address
Browser type and version
Device information
Pages visited and time spent
Referring website
Cookie data (see Cookie Policy section below)
3.6 Booking and Payment Information
When you book and pay for services:
Booking details (service type, date, time, location preference)
Payment information (processed through secure payment providers)
Invoices and payment receipts
3.7 Session Notes and Records
During and after sessions, we create:
Session notes and observations
Progress tracking
Treatment plans
Follow-up notes
Summary: Sources of Personal Data
We collect personal data from:
Application form for mentorship
Application form for bodywork services
General email inquiries
Newsletter subscription forms
Website cookies
Booking and payment systems
Information you provide during sessions
4. Categories of Personal Data
4.1 Contact Information
Full name
Email address
Phone number (if provided)
Location/address (city/region)
4.2 Personal Details
Date of birth
Gender (if relevant for services)
4.3 Sensitive Personal Data (Special Categories)
Under GDPR Article 9, we collect sensitive personal data including:
Trauma history
Health information relevant to bodywork services
Physical or mental health details you share during intake and sessions
Information about past experiences relevant to somatic therapy
Medical conditions, medications, allergies
Physical symptoms, pain, injuries
4.4 Technical Information
IP address
Browser type and version
Cookies (see Cookie Policy below)
Website usage data (via analytics)
4.5 Communication Records
Email correspondence
Session notes and records
Intake forms and questionnaires
Application forms
5. Legal Basis for Processing Your Data
We process your personal data based on the following legal grounds:
5.1 Explicit Consent (GDPR Article 9)
For sensitive personal data (trauma history, health information), we rely on your explicit, informed consent, which you provide by:
Completing application forms for mentorship or bodywork
Agreeing to our Terms & Conditions (which includes consent provisions)
Verbally confirming during sessions
You have the right to withdraw consent at any time.
5.2 Contractual Necessity
We need your contact information and basic details to:
Provide somatic therapy, coaching, and mentorship services
Schedule and confirm appointments
Process payments
Fulfill our service agreement with you
5.3 Legitimate Interests
We may process certain data for legitimate business interests, such as:
Sending newsletters (with your consent)
Improving our services
Maintaining business records
Responding to general inquiries
5.4 Legal Obligations
We may need to retain certain records to comply with Danish bookkeeping laws and professional requirements.
6. How We Use Your Information
We use your personal information for the following purposes:
6.1 Service Delivery
Providing trauma-informed bodywork, somatic therapy, coaching, and mentorship
Creating and maintaining client records
Tailoring services to your needs
Tracking progress and session history
Assessing suitability for services via application forms
6.2 Communication
Responding to email inquiries
Confirming appointments and bookings
Sending service-related information
Responding to questions
Sending newsletters (only with your consent)
6.3 Business Operations
Processing payments and invoicing
Maintaining business records
Improving our services
Compliance with legal obligations
Website functionality and analytics
6.4 Marketing (Optional)
Sending newsletters and updates (only if you opt in)
Sharing relevant content about bodywork and somatic practices
You can unsubscribe from marketing emails at any time using the link in each email.
7. How Long We Keep Your Data
We retain your personal data only for as long as necessary:
Contact information (active clients) is kept for the duration of service plus 1 year, based on contractual necessity.
Trauma/health history (active clients) is retained for the duration of service plus 5 years, based on consent and legal obligations.
Session notes are kept for 5 years after the last session, in accordance with professional standards and legal obligations.
Financial records (invoices, payments) are retained for 5 years, as required by the Danish Bookkeeping Act.
Newsletter subscribers data is kept until you unsubscribe, based on consent.
Email inquiries are retained for 2 years after last correspondence, based on legitimate interest.
Application forms (rejected/withdrawn) are kept for 1 year, based on legitimate interest.
Website cookies retention varies (see Cookie Policy), based on consent and legitimate interest.
Inactive client data is deleted after 5 years of inactivity, in accordance with the GDPR minimization principle.
Note: You can request deletion of your data at any time (see Your Rights below), subject to our legal obligations to retain certain records.
8. Who We Share Your Data With
We do not sell or rent your personal information to third parties.
We may share your data with:
8.1 Service Providers
Email service provider (e.g., Gmail, Mailchimp, ConvertKit) for newsletters and email communication
Payment processors (e.g., MobilePay, bank transfers)
Website hosting provider
Booking/scheduling software (if applicable)
Analytics providers (e.g., Google Analytics)
All third-party providers are GDPR-compliant and process data only according to our instructions.
8.2 Legal Obligations
We may disclose your information if required by:
Danish law enforcement or authorities
Court orders
Legal proceedings
8.3 Professional Supervision (If Applicable)
With your explicit consent, we may share anonymized case information with professional supervisors or peer consultation groups for quality assurance. No identifying information is shared without your permission.
9. Data Security
We implement appropriate technical and organizational measures to protect your personal data:
Security Measures:
Encrypted email communication (where possible)
Secure password-protected storage
Limited access (only authorized personnel)
Regular backups
Physical security of paper records (locked storage)
Secure destruction of data when no longer needed
Client Records:
Session notes and trauma history are stored securely
Paper records are kept in locked cabinets
Digital records are password-protected and encrypted
Despite our best efforts, no data transmission over the internet is 100% secure. We cannot guarantee absolute security but take all reasonable precautions.
10. International Data Transfers
Your data is primarily stored and processed within the European Economic Area (EEA).
If we use service providers outside the EEA (e.g., US-based email services), we ensure:
They are GDPR-compliant
Adequate safeguards are in place (e.g., Standard Contractual Clauses, EU-US Data Privacy Framework)
Your data is protected to EU standards
11. Your Rights Under GDPR
You have the following rights regarding your personal data:
11.1 Right of Access (Article 15)
You can request a copy of all personal data we hold about you.
11.2 Right to Rectification (Article 16)
You can request corrections to inaccurate or incomplete data.*
11.3 Right to Erasure / "Right to be Forgotten" (Article 17)
You can request deletion of your data, unless we have legal obligations to retain it (e.g., financial records).
11.4 Right to Restrict Processing (Article 18)
You can request we limit how we use your data.
11.5 Right to Data Portability (Article 20)
You can request your data in a structured, machine-readable format.
11.6 Right to Object (Article 21)
You can object to processing based on legitimate interests or for marketing purposes.
11.7 Right to Withdraw Consent (Article 7)
You can withdraw consent for processing sensitive data at any time. Note: This may affect our ability to provide services.
11.8 Right to Lodge a Complaint
You can file a complaint with the Danish Data Protection Agency (Datatilsynet):
Website: www.datatilsynet.dk
Email: dt@datatilsynet.dk
Phone: +45 33 19 32 00
12. How to Exercise Your Rights
To exercise any of your rights, please contact us:
Email: natalya.skjelmose@gmail.com
Phone: +45 40403489
Mail: Constantin Hansens Gade 7, 1799 Copenhagen, Denmark
We will respond within one month of receiving your request (may be extended by two months for complex requests).
13. Cookies and Tracking
What Are Cookies?
Cookies are small text files stored on your device when you visit our website.
Cookies We Use:
Essential Cookies are used for website functionality and session management. These cookies last for the duration of your session or up to 1 year and are not shared with third parties.
Analytics Cookies use Google Analytics to help us understand website usage. These cookies last for 2 years and are provided by a third party (Google).
Marketing Cookies (Optional) track conversions and social media pixels. The duration of these cookies varies, and they may be provided by third parties if applicable.Managing Cookies:
You can control cookies through your browser settings:
Chrome: Settings → Privacy and Security → Cookies
Firefox: Settings → Privacy & Security → Cookies
Safari: Preferences → Privacy → Cookies
Note: Disabling cookies may affect website functionality.
Google Analytics:
We use Google Analytics to understand how visitors use our website. Google Analytics collects information anonymously and reports website trends.
Opt out: Install the Google Analytics Opt-out Browser Add-on
14. Newsletter and Marketing Communications
14.1 Newsletter Subscription
When you subscribe to our newsletter, we collect:
Email address
Name (optional)
Subscription date
Legal basis: Your explicit consent (GDPR Article 6(1)(a))
How we use it: Sending updates, articles, and information about bodywork and somatic practices.
Unsubscribe: Click the "unsubscribe" link in any email or contact us directly.
14.2 Client Communications
If you are a current or past client, we may send you service-related information (appointment reminders, policy updates). This is based on our legitimate interest in maintaining client relationships.
15. Children's Privacy
Our services are intended for adults (18+). We do not knowingly collect data from individuals under 18 without parental consent.
If you are under 18 and interested in services, please have a parent/guardian contact us.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect:
Changes in law
Changes in our practices
New services or features
When updated:
We will post the new policy on our website
The "Last updated" date will be revised
For significant changes, we will notify you via email
Your continued use of our services after changes constitutes acceptance of the updated policy.
17. Contact Us
If you have questions about this Privacy Policy or how we handle your data:
Cyclical Awakening ApS
Email: wholewomanhood@gmail.com
Phone: +45 40403489
Address: Constantin Hansens Gade 7, 1799 Copenhagen, Denmark
CVR: 44924595
18. Supervisory Authority
Danish Data Protection Agency (Datatilsynet)
Address: Borgergade 28, 5., 1300 Copenhagen K
Email: dt@datatilsynet.dk
Phone: +45 33 19 32 00
Website: www.datatilsynet.dk
By using our services, you acknowledge that you have read and understood this Privacy Policy.
END OF PRIVACY POLICY