PRIVACY POLICY

Last updated: 14 October 2026

This Privacy Policy explains how I collect, use and protect personal information when you visit my website, contact me, book or purchase a service, work with me as a client, join a programme or event, or subscribe to my emails.

I am committed to handling your information respectfully and in accordance with UK data protection law, including the UK GDPR and the Data Protection Act 2018.

1. WHO I AM

I am Sophie Roe, Somatic Trauma Recovery Coach & Hypnotherapist.

For data protection purposes, I am the data controller for the personal information I collect and use through my business.

You can contact me at:

Email: sophie@sophiebroe.com
Telephone: 07903 273735
Website: www.sophiebroe.com

1. WHAT INFORMATION I COLLECT

Depending on how you interact with me, I may collect:

• your name, email address and telephone number
• information you provide when making an enquiry or booking a service
• booking and appointment information
• payment and transaction information
• information provided through intake forms or questionnaires
• coaching notes and information you choose to share during or between sessions
• communications between us, including email and WhatsApp messages
• your preferences for receiving marketing communications
• technical information about how you use my website, such as IP address, device information and website analytics

Because of the nature of my work, you may sometimes choose to share sensitive information about your health, wellbeing or personal experiences. I only record or use information that is reasonably relevant to the work we are doing together.

1. HOW I COLLECT YOUR INFORMATION

I may collect information:

• directly from you when you contact me
• when you complete a form or questionnaire
• when you book or purchase a service
• during coaching, hypnotherapy, TRE® or somatic sessions
• through email, telephone or WhatsApp
• through my website
• through booking, payment or client management systems
• through cookies and website analytics

1. HOW I USE YOUR INFORMATION

I may use your information to:

• respond to enquiries
• arrange and manage appointments
• provide coaching, hypnotherapy, TRE® and other agreed services
• maintain appropriate client notes and records
• communicate with you before, during and after our work together
• provide resources and between-session support where this is included
• process payments and maintain financial records
• manage and improve my business and services
• maintain the security of my website and systems
• meet legal, accounting or insurance requirements
• send marketing communications where you have chosen to receive them

1. MY LAWFUL BASIS FOR USING YOUR INFORMATION

I only use personal information where I have a lawful reason to do so.

This will usually be one or more of the following:

Contract

Where information is necessary to respond to your request, arrange a service or provide a service you have booked.

Consent

Where you have actively chosen to receive marketing communications or where consent is otherwise appropriate.

Legal obligation

Where I am required to keep or disclose information in order to comply with the law.

Legitimate interests

Where reasonably necessary to operate and protect my business, maintain appropriate records, improve my services or deal with complaints or legal matters, provided those interests do not override your rights.

Some information you voluntarily share may be considered special category personal data under UK data protection law, for example information relating to physical or mental health.

Where this applies, I will only process this information where there is an appropriate lawful basis and an additional condition for processing special category information, including explicit consent where required.

1. AI-ASSISTED TOOLS

I sometimes use secure digital and AI-assisted tools to support administrative aspects of my work.

This may include helping me to:

• organise or summarise my own notes
• transcribe dictated notes
• prepare client resources or worksheets
• draft follow-up material
• support general business administration

AI-assisted tools support my work rather than replace my judgement or my relationship with clients.

I take reasonable steps to minimise the identifying information used and will not intentionally include personal information that is unnecessary for the task.

I do not use AI to make automated decisions about whether I will work with you, your progress or your access to services.

You can choose not to have information relating to you processed using AI-assisted tools.

You can opt out when completing your coaching agreement or at any later time by contacting me.

Choosing to opt out will not affect your ability to work with me or the service you receive.

If you opt out, I will use alternative administrative methods for future processing relating to you.

1. RECORDING AND TRANSCRIPTION

I do not routinely audio or video record client sessions.

If I wish to record a session or create a transcript directly from a recording, I will tell you beforehand and obtain appropriate permission before recording begins.

You can decline recording or direct session transcription without losing access to the service itself.

1. THIRD-PARTY SERVICE PROVIDERS

I use trusted third-party systems to help operate my business.

Depending on the service you use, these may include:

• HighLevel / CoachFunnel for forms, client administration, bookings, email and communications
• Google Workspace and Google Drive for documents, email and business administration
• Zoom for online sessions
• WhatsApp / Meta for communication
• Stripe or other payment providers for payments
• OpenAI or other approved AI-assisted services for administrative support where you have not opted out
• website hosting, analytics and other technical service providers

These providers may process personal information on my behalf or, in some cases, act as independent data controllers.

I only share information that is reasonably necessary for the relevant purpose.

I do not sell your personal information.

1. INTERNATIONAL DATA TRANSFERS

Some of the service providers I use operate internationally and may process information outside the UK.

Where this happens, I take reasonable steps to ensure that appropriate safeguards are in place in accordance with UK data protection law.

1. HOW LONG I KEEP YOUR INFORMATION

I do not keep personal information for longer than reasonably necessary.

As a general guide:

• enquiry information will normally be kept for up to 12 months where you do not go on to work with me
• core client records and session notes will normally be kept for up to three years following the end of our work together
• financial and transaction records will be kept for the period required for tax and accounting purposes
• marketing information will normally be kept until you unsubscribe or ask me to stop contacting you

Information may occasionally need to be kept for longer where there is a legal, insurance, safeguarding or other legitimate reason to do so.

I periodically review the information I hold and delete or anonymise information that is no longer needed.

1. HOW I PROTECT YOUR INFORMATION

I take reasonable steps to keep personal information secure.

These may include:

• password-protected accounts
• secure cloud-based systems
• device security
• multi-factor authentication where available
• limiting access to information
• using reputable service providers

No electronic system can be guaranteed to be completely secure, but I take the confidentiality of client information seriously.

1. WORKING WITH PEOPLE UNDER 18

I may work with people under 18 where this is appropriate.

Where I do, I may collect information relating to both the young person and their parent or guardian.

I will take account of the young person’s age and understanding when explaining how their information is used.

Where parental or guardian consent or involvement is appropriate, this will form part of the booking and intake process.

Confidentiality and any limits to confidentiality, including safeguarding concerns, will also be explained appropriately.

1. MARKETING COMMUNICATIONS

I will only send marketing communications where I have an appropriate lawful basis to do so.

Where you have consented to receive emails or text messages about my services, programmes, events or resources, you can unsubscribe at any time.

You can use the unsubscribe link in an email or contact me directly at:

sophie@sophiebroe.com

Service-related communications, such as appointment information or information about something you have purchased, are not marketing communications.

1. YOUR DATA PROTECTION RIGHTS

Depending on the circumstances, you may have the right to:

• ask what personal information I hold about you
• request a copy of your information
• ask me to correct inaccurate information
• ask me to delete information in certain circumstances
• ask me to restrict how information is used
• object to certain types of processing
• withdraw consent where I am relying on consent
• request transfer of certain information

These rights are not absolute and may depend on the reason the information is being processed.

To exercise any of these rights, contact:

sophie@sophiebroe.com

1. COMPLAINTS

If you have concerns about how I have handled your personal information, please contact me in the first instance so I can try to resolve the issue.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator responsible for data protection.

1. COOKIES

My website uses cookies and similar technologies.

Some cookies are necessary for the website to work.

Where consent is required for non-essential cookies, such as certain analytics or marketing cookies, you will be given the option to accept or reject them.

Further information is available in my Cookie Policy.

1. LINKS TO OTHER WEBSITES

My website may contain links to websites operated by other organisations.

I am not responsible for the privacy practices of third-party websites and recommend that you review their privacy information separately.

1. CHANGES TO THIS PRIVACY POLICY

I may update this Privacy Policy from time to time as my business, services or systems change.

The latest version will be made available through my website.

Where a significant change affects how existing client information is used, I will take reasonable steps to make affected clients aware.

1. CONTACT

If you have any questions about this Privacy Policy or how your information is handled, please contact:

Sophie Roe
Somatic Trauma Recovery Coach & Hypnotherapist

Email: sophie@sophiebroe.com
Telephone: 07903 273735
Website: www.sophiebroe.com