PRIVACY POLICY
1. HOW WE USE YOUR PERSONAL DATA
We are committed to protecting your personal data. The data we collect from you is as submitted by you on the coaching agreement form, the massage consultation and treatment record form, client intake forms, session preparation forms, and through written correspondence and emails that you send to us.
We will use your sensitive personal data (that is the health, treatment, and other sensitive data you share with us within the above documents, sessions, and correspondence) for the purposes of providing our services to you or if we need to comply with a legal obligation. Our legal ground for processing this data is your explicit consent.
We will use your non-sensitive personal data to (i) register you as a new client, (ii) manage payment, (iii) collect and recover monies owed to us, (iv) manage our relationship with you, (v) send you details of our services.
Our legal grounds for processing your data in relation to points (i) to (iv) above are performance of a contract with you, and in relation to (v) above, necessary for our legitimate interests to develop our services and grow our business. We will not share your details with third parties for marketing purposes except with your express consent. In certain circumstances you can ask us to delete your data. See the section entitled "Your Legal Rights" below for more information.
We may anonymise your personal data (so that you can no longer be identified from it) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
2. DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with (i) service providers who provide IT, payment, and system administration support, including Stripe, Squarespace, and Xero, (ii) professional advisers including lawyers, accountants, and insurers, (iii) HMRC and other regulatory authorities, (iv) third parties to whom we sell, transfer, or merge parts of our business or our assets, and/or (v) to professional coaching and therapy bodies such as the ICF (International Coaching Federation) and Massage Training Institute, and to a supervisory coach or mentor, as part of professional accreditation, training, and ongoing development.
We require all of these third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. They are only permitted to process your personal data on our instructions.
In relation to a Subject Access Request, you may ask us to inform you of the data we hold about you and how we process it. We will not charge a fee for responding to this request unless it is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond.
We will, in most cases, reply within one month of the date of the request, unless your request is complex or you have made a large number of requests, in which case we will notify you of any delay and will in any event reply within three months.
If you wish to make a Subject Access Request, please email acp@orangetreeco.com or write to Alexandra Payne, Data Compliance Officer, Orange Tree Collective Ltd, 34-40 High St, Wanstead, London E11 2RJ, marked for the attention of the Data Compliance Officer.
3. INTERNATIONAL TRANSFERS
Some of our third-party providers (including Stripe and Squarespace) are businesses based outside of the UK, in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by using providers who maintain appropriate contracts, codes of conduct, or certifications, giving your personal data equivalent protection to that within the UK. Where this is not possible, we will request your explicit consent to the transfer, and you can withdraw this consent at any time.
4. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal data to those individuals and third parties who have a genuine business need to know such data. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have procedures in place to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.
5. DATA RETENTION
We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy legal, accounting, or reporting requirements — for example, we keep certain financial information for six years after you cease to be a client, for tax purposes. Massage treatment records and coaching agreements/session notes are retained in line with professional practice and accreditation requirements (MTI and ICF respectively), typically for up to seven years. You have the right to ask us to delete the personal data we hold about you in certain circumstances. See section 6 below.
6. YOUR RIGHTS
You are able to exercise certain rights in relation to your personal data that we process. These are set out in more detail at:
7. KEEPING YOUR DATA UP TO DATE
We have a duty to keep your personal data up to date and accurate, so from time to time we will contact you to confirm your personal data is still accurate and up to date. If any of your personal data changes (such as a change of address), please let us know as soon as possible by emailing the address set out in section 2 above.
8. COMPLAINTS
We are committed to protecting your personal data, but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you have a complaint, so that we can try to resolve it for you. We may change this Privacy Notice from time to time.
WEBSITE PRIVACY POLICY
1. HOW WE USE YOUR PERSONAL DATA
INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data through your use of our website(s), including our massage therapy site and our coaching site.
By providing us with your data, you warrant to us that you are over 16 years of age. Orange Tree Collective Ltd is the data controller and we are responsible for your personal data (referred to as "we", "us", or "our" in this privacy notice).
CONTACT DETAILS
Our full details are:
Full name of legal entity: Orange Tree Collective Ltd
Name of Data Protection Officer: Alexandra Payne
ICO registration number: ZC157135
Email address: acp@orangetreeco.com
Postal address: 34-40 High St, Wanstead, London E11 2RJ
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at acp@orangetreeco.com.
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE, AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:
- Communication Data — any communication you send to us, whether through a contact form on our website, email, text, or social media messaging. We process this data to communicate with you, to keep records, and to establish, pursue, or defend legal claims where necessary. Our lawful ground for this processing is our legitimate interests, namely replying to enquiries and keeping accurate records.
- User Data — data about how you use our website and any data you post for publication on it. We process this data to operate our website, ensure relevant content is provided to you, maintain the security of our website, and enable its administration. Our lawful ground for this processing is our legitimate interests in properly administering our website and business.
- Technical Data — data about your use of our website, such as your IP address, browser details, length of visit, page views, and navigation paths, collected via Squarespace's built-in website analytics. We process this data to understand how our website is used and to improve it. Our lawful ground for this processing is our legitimate interests in properly administering our website and business. We do not currently use third-party advertising or analytics tools such as Google Analytics or Facebook/Meta Pixel.
- Booking and Payment Data — collected when you book and pay for a massage session via Stripe, our payment processor. We do not store your full card details ourselves; these are processed directly by Stripe.
Sensitive Data
Where you become a client, we collect Sensitive Data relevant to the service you have engaged us for. For massage therapy, this includes relevant health history and treatment information, collected as part of a consultation and treatment record form, in line with MTI professional practice standards. For coaching, this may include information you choose to share during sessions relating to your wellbeing or personal circumstances, where relevant to the coaching engagement. Sensitive Data refers to information about health, race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, and genetic or biometric data. We require your explicit consent to process this data, and will seek this consent clearly before or at the point of collection. We do not collect any information about criminal convictions or offences.
Where we are required to collect personal data by law, or under the terms of a contract between us, and you do not provide that data when requested, we may not be able to provide our services to you. If this is the case, we will let you know at the time.
We will only use your personal data for the purpose it was collected for, or a reasonably compatible purpose if necessary. For more information, please email us at acp@orangetreeco.com. We do not carry out automated decision-making or any type of automated profiling.
HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you when you provide it to us directly — for example, by filling in forms on our site, completing a coaching agreement or treatment record, or sending us emails. We automatically collect certain data as you use our website through Squarespace's built-in analytics.
MARKETING COMMUNICATIONS
Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if (i) you made a purchase or asked for information about our services, or (ii) you agreed to receive marketing communications, and in each case you have not since opted out. You can ask us to stop sending marketing messages at any time by emailing acp@orangetreeco.com.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
- Service providers who support our IT, payments, and business administration, including Stripe, Squarespace, and Xero
- Professional advisers, including accountants and insurers
- Government bodies that require us to report processing activities, including HMRC
- Professional bodies including the ICF and MTI, and a supervisory coach or mentor, for accreditation and professional development purposes
- Third parties to whom we sell, transfer, or merge parts of our business or assets
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
Some of our third-party providers, including Stripe and Squarespace, may process data outside the UK. Where this occurs, we ensure appropriate safeguards are in place to protect your personal data to a standard equivalent to that within the UK.
DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We limit access to your personal data to those individuals who have a genuine business need to know it. Any such individuals will only process your personal data on our instructions and must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to do so.
DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.
When deciding how long to keep data, we consider its amount, nature, and sensitivity, the potential risk of harm from unauthorised use or disclosure, the purposes of processing, whether these can be achieved by other means, and any legal requirements.
For tax purposes, the law requires us to keep basic information about our clients (including contact, identity, and transaction data) for six years after they stop being a client. Massage treatment records and coaching session records are retained in line with professional practice and accreditation requirements, typically for up to seven years.
In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under data protection law you have rights in relation to your personal data, including the right to request access, correction, erasure, restriction, transfer, to object to processing, and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at acp@orangetreeco.com.
You will not have to pay a fee to access your personal data or to exercise any of your other rights, unless your request is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to comply.
We may need to request specific information from you to confirm your identity before responding to a request. This is a security measure to ensure personal data is not disclosed to anyone who has no right to receive it.
We try to respond to all legitimate requests within one month. Occasionally it may take longer if your request is particularly complex, in which case we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first so that we can try to resolve it for you.
THIRD-PARTY LINKS
Our website(s) may include links to third-party websites, plug-ins, and applications, such as our booking and payment providers. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
COOKIES
Our website uses essential cookies necessary for the site to function, including secure checkout via Stripe, and analytics cookies via Squarespace's built-in analytics to help us understand how the website is used. We do not currently use third-party advertising or marketing cookies. You can manage or delete cookies at any time through your browser settings.