PRIVACY POLICY

Last updated: January 5, 2025

1. Introduction

This Privacy Policy explains how Cyclical Awakening ApS ("we," "us," "our") collects, uses, stores, and protects your personal information in accordance with the EU General Data Protection Regulation (GDPR) and Danish data protection laws.

We take your privacy seriously, especially given the sensitive nature of the services we provide.


2. Data Controller

Business Name: Cyclical Awakening ApS
CVR Number: 44924595
Address: Constantin Hansens Gade 7, 1799 Copenhagen, Denmark
Email: wholewomanhood@gmail.com
Phone: +45 40403489

As the data controller, we are responsible for ensuring your personal data is processed lawfully, fairly, and transparently.

3. What Information We Collect and From What Sources

We collect personal information from the following sources:

3.1 Application Form for Mentorship

When you apply for mentorship services, we collect:

  • Full name

  • Email address

  • Phone number (if provided)

  • Location/address (city/region)

  • Date of birth

  • Information about your background, experience, and goals

  • Trauma history (if relevant and you choose to share)

  • Health information relevant to mentorship

  • Any other information you provide in your application

3.2 Application Form for Bodywork Services

When you apply for bodywork services, we collect:

  • Full name

  • Email address

  • Phone number

  • Date of birth

  • Location/address (city/region)

  • Medical history and current health conditions

  • Medications and allergies

  • Trauma history

  • Physical symptoms, pain, or areas of sensitivity

  • Previous injuries or surgeries

  • Mental health information (if relevant)

  • Emergency contact information

  • Any other information you provide in your application

3.3 General Email Inquiries

When you contact us via email, we collect:

  • Name (if you provide it)

  • Email address

  • Phone number (if you provide it)

  • Content of your inquiry or correspondence

  • Any information you choose to share in your communication

3.4 Newsletter Subscription

When you subscribe to our newsletter, we collect:

  • Email address

  • Name (if you provide it)

  • Subscription date and time

  • Email engagement data (opens, clicks)


3.5 Website Cookies and Technical Information

When you visit our website, we automatically collect:

  • IP address

  • Browser type and version

  • Device information

  • Pages visited and time spent

  • Referring website

  • Cookie data (see Cookie Policy section below)

3.6 Booking and Payment Information

When you book and pay for services:

  • Booking details (service type, date, time, location preference)

  • Payment information (processed through secure payment providers)

  • Invoices and payment receipts

3.7 Session Notes and Records

During and after sessions, we create:

  • Session notes and observations

  • Progress tracking

  • Treatment plans

  • Follow-up notes


Summary: Sources of Personal Data

We collect personal data from:

  1. Application form for mentorship

  2. Application form for bodywork services

  3. General email inquiries

  4. Newsletter subscription forms

  5. Website cookies

  6. Booking and payment systems

  7. Information you provide during sessions

4. Categories of Personal Data


4.1 Contact Information

  • Full name

  • Email address

  • Phone number (if provided)

  • Location/address (city/region)

4.2 Personal Details

  • Date of birth

  • Gender (if relevant for services)

4.3 Sensitive Personal Data (Special Categories)

Under GDPR Article 9, we collect sensitive personal data including:

  • Trauma history

  • Health information relevant to bodywork services

  • Physical or mental health details you share during intake and sessions

  • Information about past experiences relevant to somatic therapy

  • Medical conditions, medications, allergies

  • Physical symptoms, pain, injuries

4.4 Technical Information

  • IP address

  • Browser type and version

  • Cookies (see Cookie Policy below)

  • Website usage data (via analytics)

4.5 Communication Records

  • Email correspondence

  • Session notes and records

  • Intake forms and questionnaires

  • Application forms

5. Legal Basis for Processing Your Data

We process your personal data based on the following legal grounds:

5.1 Explicit Consent (GDPR Article 9)

For sensitive personal data (trauma history, health information), we rely on your explicit, informed consent, which you provide by:

  • Completing application forms for mentorship or bodywork

  • Agreeing to our Terms & Conditions (which includes consent provisions)

  • Verbally confirming during sessions

You have the right to withdraw consent at any time.

5.2 Contractual Necessity

We need your contact information and basic details to:

  • Provide somatic therapy, coaching, and mentorship services

  • Schedule and confirm appointments

  • Process payments

  • Fulfill our service agreement with you

5.3 Legitimate Interests

We may process certain data for legitimate business interests, such as:

  • Sending newsletters (with your consent)

  • Improving our services

  • Maintaining business records

  • Responding to general inquiries

5.4 Legal Obligations

We may need to retain certain records to comply with Danish bookkeeping laws and professional requirements.

6. How We Use Your Information


We use your personal information for the following purposes:

6.1 Service Delivery

  • Providing trauma-informed bodywork, somatic therapy, coaching, and mentorship

  • Creating and maintaining client records

  • Tailoring services to your needs

  • Tracking progress and session history

  • Assessing suitability for services via application forms

6.2 Communication

  • Responding to email inquiries

  • Confirming appointments and bookings

  • Sending service-related information

  • Responding to questions

  • Sending newsletters (only with your consent)

6.3 Business Operations

  • Processing payments and invoicing

  • Maintaining business records

  • Improving our services

  • Compliance with legal obligations

  • Website functionality and analytics

6.4 Marketing (Optional)

  • Sending newsletters and updates (only if you opt in)

  • Sharing relevant content about bodywork and somatic practices

You can unsubscribe from marketing emails at any time using the link in each email.

7. How Long We Keep Your Data

We retain your personal data only for as long as necessary:

Contact information (active clients) is kept for the duration of service plus 1 year, based on contractual necessity.

Trauma/health history (active clients) is retained for the duration of service plus 5 years, based on consent and legal obligations.

Session notes are kept for 5 years after the last session, in accordance with professional standards and legal obligations.

Financial records (invoices, payments) are retained for 5 years, as required by the Danish Bookkeeping Act.

Newsletter subscribers data is kept until you unsubscribe, based on consent.

Email inquiries are retained for 2 years after last correspondence, based on legitimate interest.

Application forms (rejected/withdrawn) are kept for 1 year, based on legitimate interest.

Website cookies retention varies (see Cookie Policy), based on consent and legitimate interest.

Inactive client data is deleted after 5 years of inactivity, in accordance with the GDPR minimization principle.

Note: You can request deletion of your data at any time (see Your Rights below), subject to our legal obligations to retain certain records.

8. Who We Share Your Data With

We do not sell or rent your personal information to third parties.

We may share your data with:

8.1 Service Providers

  • Email service provider (e.g., Gmail, Mailchimp, ConvertKit) for newsletters and email communication

  • Payment processors (e.g., MobilePay, bank transfers)

  • Website hosting provider

  • Booking/scheduling software (if applicable)

  • Analytics providers (e.g., Google Analytics)

All third-party providers are GDPR-compliant and process data only according to our instructions.

8.2 Legal Obligations

We may disclose your information if required by:

  • Danish law enforcement or authorities

  • Court orders

  • Legal proceedings

8.3 Professional Supervision (If Applicable)

With your explicit consent, we may share anonymized case information with professional supervisors or peer consultation groups for quality assurance. No identifying information is shared without your permission.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

Security Measures:

  • Encrypted email communication (where possible)

  • Secure password-protected storage

  • Limited access (only authorized personnel)

  • Regular backups

  • Physical security of paper records (locked storage)

  • Secure destruction of data when no longer needed

Client Records:

  • Session notes and trauma history are stored securely

  • Paper records are kept in locked cabinets

  • Digital records are password-protected and encrypted

Despite our best efforts, no data transmission over the internet is 100% secure. We cannot guarantee absolute security but take all reasonable precautions.

10. International Data Transfers

Your data is primarily stored and processed within the European Economic Area (EEA).

If we use service providers outside the EEA (e.g., US-based email services), we ensure:

  • They are GDPR-compliant

  • Adequate safeguards are in place (e.g., Standard Contractual Clauses, EU-US Data Privacy Framework)

  • Your data is protected to EU standards

11. Your Rights Under GDPR

You have the following rights regarding your personal data:

11.1 Right of Access (Article 15)

You can request a copy of all personal data we hold about you.

11.2 Right to Rectification (Article 16)

You can request corrections to inaccurate or incomplete data.*

11.3 Right to Erasure / "Right to be Forgotten" (Article 17)

You can request deletion of your data, unless we have legal obligations to retain it (e.g., financial records).

11.4 Right to Restrict Processing (Article 18)

You can request we limit how we use your data.

11.5 Right to Data Portability (Article 20)

You can request your data in a structured, machine-readable format.

11.6 Right to Object (Article 21)

You can object to processing based on legitimate interests or for marketing purposes.

11.7 Right to Withdraw Consent (Article 7)

You can withdraw consent for processing sensitive data at any time. Note: This may affect our ability to provide services.

11.8 Right to Lodge a Complaint

You can file a complaint with the Danish Data Protection Agency (Datatilsynet):

  • Website: www.datatilsynet.dk

  • Email: dt@datatilsynet.dk

  • Phone: +45 33 19 32 00

12. How to Exercise Your Rights

To exercise any of your rights, please contact us:

Email: natalya.skjelmose@gmail.com
Phone: +45 40403489
Mail: Constantin Hansens Gade 7, 1799 Copenhagen, Denmark

We will respond within one month of receiving your request (may be extended by two months for complex requests).


13. Cookies and Tracking

What Are Cookies?

Cookies are small text files stored on your device when you visit our website.

Cookies We Use:

Essential Cookies are used for website functionality and session management. These cookies last for the duration of your session or up to 1 year and are not shared with third parties.

Analytics Cookies use Google Analytics to help us understand website usage. These cookies last for 2 years and are provided by a third party (Google).

Marketing Cookies (Optional) track conversions and social media pixels. The duration of these cookies varies, and they may be provided by third parties if applicable.Managing Cookies:

You can control cookies through your browser settings:

  • Chrome: Settings → Privacy and Security → Cookies

  • Firefox: Settings → Privacy & Security → Cookies

  • Safari: Preferences → Privacy → Cookies

Note: Disabling cookies may affect website functionality.

Google Analytics:

We use Google Analytics to understand how visitors use our website. Google Analytics collects information anonymously and reports website trends.

Opt out: Install the Google Analytics Opt-out Browser Add-on

14. Newsletter and Marketing Communications


14.1 Newsletter Subscription

When you subscribe to our newsletter, we collect:

  • Email address

  • Name (optional)

  • Subscription date

Legal basis: Your explicit consent (GDPR Article 6(1)(a))

How we use it: Sending updates, articles, and information about bodywork and somatic practices.

Unsubscribe: Click the "unsubscribe" link in any email or contact us directly.

14.2 Client Communications

If you are a current or past client, we may send you service-related information (appointment reminders, policy updates). This is based on our legitimate interest in maintaining client relationships.


15. Children's Privacy

Our services are intended for adults (18+). We do not knowingly collect data from individuals under 18 without parental consent.

If you are under 18 and interested in services, please have a parent/guardian contact us.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

  • Changes in law

  • Changes in our practices

  • New services or features

When updated:

  • We will post the new policy on our website

  • The "Last updated" date will be revised

  • For significant changes, we will notify you via email

Your continued use of our services after changes constitutes acceptance of the updated policy.

17. Contact Us

If you have questions about this Privacy Policy or how we handle your data:

Cyclical Awakening ApS
Email: wholewomanhood@gmail.com
Phone: +45 40403489
Address: Constantin Hansens Gade 7, 1799 Copenhagen, Denmark
CVR: 44924595

18. Supervisory Authority

Danish Data Protection Agency (Datatilsynet)
Address: Borgergade 28, 5., 1300 Copenhagen K
Email: dt@datatilsynet.dk
Phone: +45 33 19 32 00
Website: www.datatilsynet.dk

By using our services, you acknowledge that you have read and understood this Privacy Policy.

END OF PRIVACY POLICY