Privacy Policy
How your personal information is collected, used and protected.
Last updated: [DD Month 2026]
1. Who I am
This website is run by Jonavel Asuncion, trading as Growth & Grounding Counselling Service (“I”, “me”). I am the data controller for the personal information collected through this website.
- Email: growthgrounding79@gmail.com
- Phone: +44 7446 913517
- ICO registration number: [ZA000000]
2. What information I collect
I only collect the information you choose to send me through this website:
- Enquiry form: your name, email address and message.
- Booking form: your name, email address, phone number (optional), the service you are interested in, and your preferred date and time.
- Emails and phone calls: any details you share when you contact me directly.
You do not need to share sensitive details through the website. If you choose to include information about your health or wellbeing, this is “special category” data under UK GDPR and is handled with extra care, as explained below.
3. How and why I use your information
- To reply to your enquiry or booking request and arrange an initial conversation or session.
- To keep the website secure and protect it from misuse.
I will never sell your information or use it for marketing without your permission.
4. My lawful basis
- Steps before a contract (Article 6(1)(b)): to respond to your enquiry or booking request at your request.
- Explicit consent (Article 9(2)(a)): for any health or wellbeing information you choose to share. You give this by ticking the consent box on the form, and you can withdraw it at any time.
- Legitimate interests (Article 6(1)(f)): to keep this website secure, for example through basic technical logs kept by the website host.
5. How your information is sent and stored
The forms on this website do not store your information on the website. When you submit a form, your details are sent over an encrypted connection and delivered to my email inbox. They are not kept in a website database.
I use the following trusted service providers, who process data on my behalf under data protection agreements:
- Vercel Inc. – website hosting and form delivery. Vercel may keep short-term technical logs (such as IP addresses) for security.
- [Google (Gmail)] – email.
- Zoom / Google Meet – only if we go on to work together and you choose a video session.
Some of these providers may process data outside the UK. Where this happens, it is protected by appropriate safeguards recognised under UK law, such as the UK International Data Transfer Addendum or the UK–US Data Bridge.
6. How long I keep your information
- Enquiries that do not lead to counselling: deleted within [3 months].
- Client records (if we go on to work together): kept for [X years] after our work ends, in line with my professional body’s guidance, and then securely deleted. Full details are given in my counselling agreement.
7. Confidentiality
Everything you share with me is treated as confidential. There are professional and legal limits to confidentiality, for example where there is a serious risk of harm to you or others, or a safeguarding concern. These limits will be explained before we begin working together.
8. Your rights
Under UK GDPR you have the right to:
- access the personal information I hold about you;
- ask me to correct information that is wrong or incomplete;
- ask me to delete your information;
- ask me to restrict or stop using your information;
- receive your information in a portable format;
- withdraw your consent at any time.
To use any of these rights, email growthgrounding79@gmail.com. I will respond within one month.
9. Cookies and tracking
This website does not use cookies, analytics or tracking tools, and it does not load fonts or scripts from third parties. No cookie banner is needed because nothing is stored on your device.
10. Keeping your information safe
The website uses an encrypted (HTTPS) connection, security protections against misuse and spam, and does not store form submissions. Access to my email and website accounts is protected by strong passwords and two-factor authentication.
11. Making a complaint
If you have a concern about how your information is handled, please contact me first so I can try to put it right. You also have the right to complain to the Information Commissioner’s Office (ICO):
- Website: ico.org.uk/make-a-complaint
- Helpline: 0303 123 1113
12. Changes to this policy
I may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.