Privacy Policy
Last updated: 2026
Data Controller
Panayi Therapy
[Controller name, address, and contact details to be confirmed by client before launch.]
Data We Collect and Why
We collect only the personal data necessary to provide our services:
| Data | Purpose | Legal Basis (GDPR) |
|---|---|---|
| Email address | Account identity and communication | Contract performance |
| Full name, phone, gender (encrypted) | Session management and personalisation | Consent (explicit) |
| Appointment notes (encrypted) | Session continuity and record-keeping | Consent (explicit) |
| Messages (encrypted) | Communication between client and practitioner | Contract performance / Consent |
| Passkey credential (public key only) | Passwordless authentication | Contract performance / Legitimate interest |
How We Protect Your Data
All personally identifiable fields (name, phone, gender, appointment notes, message content) are encrypted at the application layer using AES-256 via the ASP.NET Core Data Protection API. Encryption keys are stored outside the database and outside version control.
Authentication uses passkeys (WebAuthn/FIDO2). Only the public key credential is stored; biometric data never leaves your device.
Data Retention
We retain personal data only for as long as necessary:
- Account and appointment data: retained for [period TBC — confirm with client] after last session
- Messages: retained for [period TBC] or until deleted by the user
- Consent logs: retained for the duration of the relationship plus [period TBC]
- On erasure request, PII is anonymised; non-PII records may be retained for audit purposes
Your Rights
Under GDPR and applicable data protection law, you have the following rights:
| Right | What It Means | How to Exercise |
|---|---|---|
| Access (Art. 15) | Receive a copy of your personal data | Portal → Account → Export Data |
| Rectification (Art. 16) | Correct inaccurate data | Portal → Account → Edit Profile |
| Erasure (Art. 17) | Request deletion of your data | Portal → Account → Delete Account |
| Portability (Art. 20) | Receive your data in a machine-readable format | Portal → Account → Export Data (JSON) |
| Restriction (Art. 18) | Restrict processing in certain circumstances | Contact us via portal messaging |
| Object (Art. 21) | Object to processing based on legitimate interest | Contact us via portal messaging |
Withdrawing Consent
Where processing is based on your consent, you can withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before you withdrew consent.
Lodging a Complaint
If you believe your rights under GDPR have not been respected, you have the right to lodge a complaint with a supervisory authority. In the EU, this is the data protection authority in your country of residence. In the UK, this is the ICO.
Contact
For any privacy-related enquiries or to exercise your rights, please contact us through the client portal messaging system.