At Smiley Mind, we respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.smileymind.com or use our professional coaching, training, and advisory services.

This policy complies with applicable global data protection regulations, including the EU General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR / Data Protection Act 2018), and the Australian Privacy Act 1988 (including the Australian Privacy Principles - APPs).

1. Data Controller & Contact Information

For the purposes of applicable data protection laws, the Data Controller responsible for your personal data is:

• Business Name: Smiley Mind

• Contact Email: info@smileymind.com

• Website: www.smileymind.com

If you have any questions about this Privacy Policy or wish to exercise your legal rights, please contact us via email.

2. Personal Data We Collect

We may collect, store, and process the following categories of personal information:

• Contact & Identity Data: Full name, job title, veterinary practice/clinic name, professional role, email address, phone number, and location.

• Consultation & Service Data: Information you provide when booking a consultation, completing pre-session questionnaires, or during coaching/sparring sessions (e.g., individual professional goals, team dynamics, workplace challenges).

• Technical & Usage Data: IP address, browser type, operating system, time zone setting, page interaction information, and device details collected automatically when visiting our website.

• Communication Data: Messages, inquiries, or feedback sent to us via online forms, email, or messaging platforms.

• Financial & Payment Data: Payment card details, billing address, bank account details, and transaction history. Please note: all payment transactions are processed directly and securely by our payment processor (Stripe). We do not store or directly process your full credit card numbers or sensitive financial credentials on our servers.

3. Legal Basis and Purpose of Processing

We collect and process your personal data for the following purposes and under the following legal bases across our operating jurisdictions:

• Delivering Coaching & Advisory Services:

  • EU & UK GDPR Legal Basis: Performance of a contract or taking required steps prior to entering a contract.

  • Australian Privacy Principle: APP 3 (Necessary for primary business functions and service delivery).

• Responding to Inquiries & Consultations:

  • EU & UK GDPR Legal Basis: Legitimate interests (responding to client requests) or your direct consent.

  • Australian Privacy Principle: APP 3 (Direct consent and solicited collection).

• Administrative & Invoicing Communications:

  • EU & UK GDPR Legal Basis: Compliance with legal obligations and fulfillment of contractual commitments.

  • Australian Privacy Principle: APP 6 (Use of personal information for the primary purpose of collection).

• Website Optimisation & Security:

  • EU & UK GDPR Legal Basis: Legitimate interests (ensuring platform security, reliability, and proper user functionality).

  • Australian Privacy Principle: APP 3 & APP 11 (Security, protection, and operational management of information).

4. How We Share Your Data

We do not sell, rent, or trade your personal data to third parties. We only share information with trusted third-party service providers (Data Processors) necessary to operate our business and deliver services, including:

• Cloud Infrastructure & Email: Google Workspace (Google LLC)

• Scheduling & Consultation Tools: Calendly / Google Calendar

• Communication Platforms: Google Meet / Zoom

• Web Hosting: Google Sites

• Payment Processing & Invoicing: Stripe (Stripe, Inc. / Stripe Payments Europe, Ltd.) – used for secure processing of online payments, client invoicing, and financial transactions. Stripe complies with PCI-DSS Level 1 standards (the highest level of security in the payment industry).

All third-party service providers are bound by strict confidentiality and data protection agreements.

5. International Data Transfers

As Smiley Mind operates across the European Union, United Kingdom, and Australia, your personal data may be stored or processed in servers located outside your home country (including Google’s global cloud infrastructure).

We ensure that all cross-border transfers comply with lawful transfer mechanisms, such as Standard Contractual Clauses (SCCs) for EU/UK data subjects, and compliance with APP 8 (Cross-border Disclosure) for Australian residents.

6. Data Security & Retention

We implement appropriate technical and organisational security measures to protect your personal data from unauthorized access, loss, misuse, or alteration. All online consultations and communications are handled with strict professional confidentiality.

Financial and invoice data is retained for the minimum period required by applicable tax and accounting laws in the relevant jurisdictions (EU, UK, and Australia).

We retain personal data only as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or professional regulatory compliance.

7. Your Legal Rights

Depending on your location, you have specific rights regarding your personal information:

For EU and UK Residents (Under GDPR):

• Access & Rectification: Request a copy of your personal data or ask us to correct inaccurate information.

• Erasure ("Right to be Forgotten"): Request deletion of your personal data where applicable.

• Restriction & Objection: Object to or restrict the processing of your data.

• Data Portability: Request transfer of your data to another provider in a structured format.

• Lodge a Complaint: Right to lodge a complaint with your local Data Protection Authority (e.g., ICO in the UK, UODO in Poland).

For Australian Residents (Under the Privacy Act 1988):

• Access & Correction: Request access to the personal information we hold about you and request corrections if inaccurate (APPs 12 & 13).

• Anonymity: Option to interact anonymously where lawful and practicable.

• Lodge a Complaint: If you believe we have breached the Australian Privacy Principles, contact us first. If unsatisfied, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

To exercise any of these rights, please email us at info@smileymind.com.

8. Cookies and Third-Party Links

Our website uses essential cookies necessary for functionality and security. Our site may contain links to external third-party websites (e.g., professional credentialing bodies like ICF, RCVS, or FVE VetJoy). We are not responsible for the privacy practices or content of third-party websites.

9. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our legal obligations or operational practices. Updated versions will be published on this page with an updated "Last Updated" date.

Last Updated: October 2026