Privacy Policy

Effective Date: April 2026

1. Who I am

This policy explains how I, Jaime M Dennis, trading as Jaime Dennis, collect and use your personal information when you visit www.jaime-dennis.com or use my services. I'm the data controller for your information.

Address: Dar Tan-Ne, 59 Triq Il-Madonna Tac-Cicri, Żebbuġ ZBB 1309, Malta
Email: coaching@jaime-dennis.com

I follow the EU General Data Protection Regulation (GDPR) and, for UK clients, the UK GDPR. My services are for adults aged 18 and over.

2. What I collect

Contact and booking details: your name, email address, phone or WhatsApp number, and the booking answers you give through Calendly, such as what you'd like to talk about and how you heard about me.

Information about your wellbeing: anything you choose to share about your stress, health or experiences, in booking forms, messages or sessions, and my session notes. This is health information, which the law treats as special category data.

HRV readings: if you choose to use heart rate variability (HRV) monitoring, your readings and any notes you add in the Elite HRV app, shared with me through Elite HRV's Team Dashboard. This is also health information.

AI session notes: if you agree, a transcript and summary of a video session, created by an AI note-taking tool.

Payment details: records of what you've paid and when. I never see or store your full card or bank details; payments are handled by Stripe and Revolut.

Website data: your IP address, browser and device type, and how you use the website, collected through cookies if you agree to them.

3. How and why I use it

To arrange and deliver sessions, including bookings, reminders, video links and messages. Legal basis: to perform our contract.
To understand your needs and work with you safely, using the wellbeing information, HRV readings and AI session notes you agree to. Legal basis: your explicit consent.
To take and track payments. Legal basis: to perform our contract.
To keep accounting and tax records. Legal basis: legal obligation.
To see which referrers send people to me, from the "how did you hear about me?" question. Legal basis: my legitimate interest in running my practice.
To understand and improve the website. Legal basis: your consent, given through the cookie banner.

I don't use your information for automated decision-making or profiling, and I never sell it.

4. HRV monitoring

HRV monitoring is always optional. If you choose to use it, you'll download the Elite HRV app and create your own account with Elite HRV, Inc. You then choose what to share with me through my Team Dashboard.

I use your readings only to support your sessions. You can stop sharing, or leave my team, at any time through the app. I keep any readings I've exported for 3 years after our last session, and if you ask me to delete them sooner I'll do so within 30 days.

Your Elite HRV account is also covered by Elite HRV's own privacy policy at elitehrv.com/privacy. Elite HRV stores data in the United States.

5. AI note-taking

With your permission, I sometimes use Google Meet's built-in AI note-taking ("take notes for me") during video sessions, so I can give you my full attention rather than writing notes.

I'll always ask before it starts, and it's entirely your choice. Saying no won't affect your session in any way. While it's running, everyone in the call sees an on-screen notice, and you can ask me to pause or stop it at any time, including for any part of a session you'd rather not have noted.

The feature produces a summary document, saved in my Google Drive. It is never shared with anyone else. I don't record sessions or generate transcripts.

I use the summary only to write my own session notes, and I delete it within 7 days. My own notes contain only what's needed for our work together.

Because sessions can cover your health and personal experiences, anything captured this way is treated as special category data and is only processed with your explicit consent, which you can withdraw at any time.

Google processes this information as part of Google Workspace, under the transfer safeguards described in section 7, and under terms which provide that your information is not used to train AI models.

6. Who I share it with

I share information only with the services I need to run my practice. Each handles it on my behalf, or under its own privacy terms:

Wix: website hosting and contact forms
Google Workspace: email, calendar, documents, and Google Meet video calls
Google Business Profile: if you leave a public review, it's handled under Google's terms
Calendly: booking, reminders and booking questions
Elite HRV: HRV readings you choose to share
Google Workspace: email, calendar, documents, Google Meet video calls, and — only with your permission — AI note-taking during video sessions.
WhatsApp and Zoom: messages and video calls
Stripe and Revolut: payments
Google Ads and Microsoft Clarity: website analytics and advertising, only with your cookie consent

I may also share information if the law requires it, or where I believe you or someone else is at serious risk of harm.

7. Transfers outside the UK and EU

Several of these services, including Calendly, Google, Elite HRV, Microsoft, WhatsApp, Google Meet, may store or process data in the United States. Where they do, I rely on recognised safeguards, such as the EU–US Data Privacy Framework and its UK extension, or standard contractual clauses approved by the European Commission and the UK. You can ask me for details.

8. Website cookies and session recording

The website uses cookies for analytics and advertising, including Microsoft Clarity, which records how visitors move around pages. These are only set if you accept them in the cookie banner, and you can change your choice at any time.

Clarity is set to mask everything you type, so form entries never appear in recordings.

9. How long I keep it

Session notes and wellbeing information: 3 years after our last session
HRV data I've exported: 3 years]after our last session, or sooner if you ask
AI note-taker recordings and transcripts: deleted within 7 days, once my session notes are written
Booking and contact details: 3 years after our last contact
Payment and accounting records: as long as tax law requires, typically 7 years
Enquiries that don't lead to a booking: 12 months

10. Keeping it safe

I keep your information in secure, password-protected accounts with two-step verification, and I'm the only person with access. Session notes are kept separately from payment records.

11. Your rights

You have the right to:

see the information I hold about you
have it corrected
have it deleted
limit or object to how I use it
receive it in a portable format
withdraw your consent at any time, without affecting anything done before

To use any of these rights, email me. I'll respond within one month.

If you're unhappy with how I've handled your information, please tell me first. You also have the right to complain to the Information and Data Protection Commissioner in Malta (idpc.org.mt) or, if you're in the UK, the Information Commissioner's Office (ico.org.uk).

12. Changes to this policy

I'll update this policy if my practice or the law changes, and show the date at the top.