Privacy Policy

Version date: 27 December 2025

Data Controller

The controller of your personal data is:

SimpleCity Communications Robert Stupak
ul. Franciszka Klimczaka 8A/34
02-797 Warsaw, Poland
NIP: PL8941897340

Email: privacy@executivepsychotherapy.com
Phone: +48 782 755 330

(“Controller”, “Administrator”, “we”)

Website: https://www.executivepsychotherapy.com

Scope and Service Categories

This Privacy Policy applies to users of the website executivepsychotherapy.com and to individuals who contact us or use our services.

Service categories

We provide the following services to adults (18+):

  • Individual psychotherapy — delivered in individual sessions, in person or online.
    This includes initial consultative session(s) forming part of the psychotherapeutic process, as well as ongoing psychotherapy sessions. Psychotherapy services are provided in accordance with Polish and EU regulations. Clients are responsible for ensuring that participation in psychotherapy services is lawful in their jurisdiction.

  • Non-psychotherapy services — activities and interventions that support mental well-being, reflection, decision-making, leadership functioning, and personal development, without constituting psychotherapy, diagnosis, or treatment of mental disorders. These services may include consultative, educational, or developmental work (individual or group), focused on awareness, skills, and perspective rather than deep psychotherapeutic exploration, and do not establish a psychotherapeutic relationship. Non-psychotherapy services may be provided also to clients located outside Poland.

Important clarification:
Psychotherapy and non-psychotherapy services are distinct services with different scopes and legal frameworks. Where relevant, the applicable category of service is determined either at the time of booking or through the initial consultative session, and we will inform you accordingly.

Legal Framework

We process personal data in accordance with:

  • Regulation (EU) 2016/679 (GDPR)

  • Applicable Polish data protection regulations (commonly referred to as RODO)

  • The ePrivacy Directive and national implementing laws (where applicable)

Where UK GDPR applies, equivalent principles and rights apply.

Purposes and Legal Bases of Processing

We process personal data only to the extent necessary, for the following purposes and on the following legal bases:

Booking and handling of appointments — GDPR Art. 6(1)(b) (performance of a contract)
Including appointment dates, session format (online or in person), and organisational communication. We may use third-party booking tools (e.g. ZenCal, Acuity).

Provision of services — GDPR Art. 6(1)(b)
Including individual psychotherapy and non-psychotherapy services, as applicable.

Payments, billing, and accounting — GDPR Art. 6(1)(b) and 6(1)(c) (contract and legal obligation)
Including identification and contact data, payment amount, date, payment method, and settlement details. Services may be corporate-funded or self-funded; invoices or receipts are issued where required.

Contact and enquiries — GDPR Art. 6(1)(f) (legitimate interest)
Handling email or telephone enquiries and responding.

IT security and website administration — GDPR Art. 6(1)(f) (legitimate interest)
Including server logs, IP addresses, timestamps, and measures to prevent abuse or ensure system security.

Service-related (non-marketing) information — GDPR Art. 6(1)(f) (legitimate interest)
Sending organisational or practical information necessary to use services (e.g. session logistics).

Newsletter / educational updates (if used) — GDPR Art. 6(1)(a) (consent)
If we offer a newsletter or educational updates in the future, they will be sent only to persons who explicitly sign up. Consent is voluntary and may be withdrawn at any time.

Contact via WhatsApp — GDPR Art. 6(1)(f) and/or 6(1)(b)
If you contact us via WhatsApp, we process data to respond efficiently and arrange appointments (legitimate interest) or to perform a contract (e.g. booking confirmations).

Please do not transmit detailed health or psychotherapy information via WhatsApp. If such information is nevertheless provided, it is processed only to the minimum extent necessary and solely on the basis of your explicit consent (GDPR Art. 9(2)(a)).

Special category data (health data) in psychotherapy — GDPR Art. 9(2)(a) and/or 9(2)(h)
As a rule, health data is processed with your explicit consent. Where justified, we may rely on the provision of health-related services by a professional bound by confidentiality. Processing is always limited to what is strictly necessary.

Confidentiality of Psychotherapy Data

Information shared in the context of psychotherapy services is treated as confidential and protected in accordance with professional ethical standards and applicable law.

Confidentiality applies with the following limited exceptions:

  • Elements of the therapeutic work may be discussed within professional supervision. Supervision is a standard component of psychotherapeutic practice and is conducted with respect for client anonymity. Supervisors are bound by the same professional confidentiality obligations.

  • Confidentiality may be limited where disclosure is required by applicable law.

Legitimate interest balancing test
Where processing is based on legitimate interest, we have assessed and balanced our interests against your fundamental rights and freedoms.

Categories and Source of Personal Data

Depending on the context, we may process:

  • identification and contact data (name, email, phone number),

  • booking and scheduling data,

  • billing data (including company details for corporate clients, if provided),

  • psychotherapy-related data shared during sessions (confidential),

  • correspondence content (email, phone, WhatsApp),

  • technical data (IP address, timestamps, device/browser information),

  • cookies and similar technologies (see Cookie Policy).

We do not store full payment card details.

Source of data:
As a rule, we collect personal data directly from you. We do not obtain personal data from third parties unless explicitly stated.

Data Recipients

Personal data may be disclosed, where necessary, to:

  • booking providers such as ZenCal or Acuity Scheduling,

  • payment operators such as Stripe and PayPal (and banks for bank transfers),

  • hosting, IT, email, backup, and security service providers,

  • public authorities, where required by law.

If you use WhatsApp, WhatsApp (Meta Platforms) processes data within its platform as a separate controller, in accordance with its own privacy policy.

Where processors are used, we conclude data processing agreements in accordance with GDPR Art. 28.

Transfers Outside the EEA

We aim to process data within the EEA. Where data is transferred outside the EEA (e.g. through analytics tools, payment providers, or WhatsApp), appropriate safeguards are applied, such as Standard Contractual Clauses or other GDPR-recognised mechanisms. Details are available upon request.

Data Retention

Personal data is retained only as long as necessary:

  • accounting and settlement data — as required by tax and accounting law,

  • psychotherapy process notes (if kept) — generally up to 5 years after the end of cooperation, unless longer retention is required to establish, exercise, or defend legal claims,

  • organisational correspondence — up to 24 months after the matter is closed, unless law requires longer,

  • newsletter data (if used) — until consent is withdrawn.

Cookies and Similar Technologies

The website uses cookies and similar technologies to ensure proper functioning, security, and statistical analysis.

Necessary cookies are required for the website to function and do not require consent.

Analytics and other non-essential cookies are used only after you provide consent via the cookie banner, in accordance with the ePrivacy Directive and GDPR.

Detailed information is available in the Cookie Policy on the website. You may withdraw consent at any time via the cookie banner or Cookie Preferences available in the website footer.

Automated Decision-Making

We do not use automated decision-making or profiling within the meaning of GDPR Art. 22.

Your Rights

You have the right to:

  • access your personal data,

  • rectification,

  • erasure,

  • restriction of processing,

  • data portability (where applicable),

  • object to processing based on legitimate interest,

  • withdraw consent at any time (without affecting prior lawful processing).

Where data is processed by WhatsApp as a separate controller, rights relating to that processing should be exercised directly with WhatsApp.

Complaints:
You may lodge a complaint with the Polish supervisory authority:

President of the Personal Data Protection Office (UODO)
ul. Stanisława Moniuszki 1A
00-014 Warsaw, Poland

Requests may be sent to: privacy@executivepsychotherapy.com

Voluntary Provision of Data

Providing personal data is voluntary but necessary to conclude and perform a contract, arrange appointments, deliver services, and handle payments. Failure to provide required data may prevent service delivery. WhatsApp is optional; alternative contact channels are always available.

Minors

Our services are intended exclusively for adults (18+). We do not knowingly process personal data of minors.

Changes to This Policy

We may update this Privacy Policy due to changes in law or our processes. The current version is always available on the website and applies from the publication date.