Πολιτική Απορρήτου HMCY
PRIVACY POLICY
Healing Mind CY respects your privacy and is committed to handling your personal information responsibly, securely and transparently.
This Privacy Policy explains what information we collect, why we collect it, how it may be used and shared, how long it may be retained, and the rights available to you.
It applies when you visit hmcy.org, contact Healing Mind CY, submit a form, book a discovery call or appointment, receive Clinical Hypnotherapy or NLP Coaching, participate in an HMCY programme, or subscribe to communications.
Some information provided during enquiries, intake or sessions may concern your physical or mental health. This information is treated with particular care and additional protection.
Healing Mind CY does not sell your personal information.
Effective date: 10 September 2026
Last updated: 19 October 2026
1. WHO IS RESPONSIBLE FOR YOUR INFORMATION?
Healing Mind CY is a trading name used by Charalambos “Charles” Eleftheriou.
For data-protection purposes, Charalambos Eleftheriou, trading as Healing Mind CY, is responsible for deciding how and why your personal information is processed.
Healing Mind CY is based in Kiti, Larnaca, Cyprus and provides services in person in Cyprus and online.
Privacy enquiries may be directed to:
Email: info@hmcy.org
Telephone: +357 99 331689
Website: https://www.hmcy.org
Contact page: https://www.hmcy.org/contact
UK ICO registration reference: ZB857379.
2. WHEN THIS POLICY APPLIES
This Privacy Policy applies when you:
• Visit the HMCY website.
• Contact HMCY by email, telephone, contact form, social media or another communication channel.
• Submit a discovery-call questionnaire, intake form, consent form, feedback form or other HMCY form.
• Book or attend a discovery call.
• Book or receive Clinical Hypnotherapy, NLP Coaching or related personal-change support.
• Participate in Executive Reset, Coaching Excellence or another HMCY programme.
• Request or download an HMCY resource.
• Subscribe to HMCY marketing or wellbeing communications.
• Respond to an HMCY advertisement or Meta lead form.
• Create or use a website member account,where this feature is available.
3. INFORMATION WE MAY COLLECT
Depending on how you interact with HMCY, we may collect:
Identity and contact information
• First and last name.
• Email address.
• Telephone number.
• Country, location or time zone.
• Address where required for invoicing or legal purposes.
Enquiry and booking information
• The service or programme you are interested in.
• Appointment dates, attendance and booking history.
• Information included in enquiries and correspondence.
• Discovery-call questionnaire responses.
• Communication preferences.
Client and service information
• Intake and informed-consent information.
• Your goals, concerns, circumstances and relevant personal history.
• Relevant medical conditions, medication or current treatment.
• MMental healthinformation where relevant to suitability and safety.
• Coaching goals and relevant personal or professional circumstances.
• Practitioner notes and agreed actions.
• Progress information and service outcomes.
• Relevant communications during the professional relationship.
Payment and administrative information
• Invoice and payment status.
• Transaction references.
• Services or programmes purchased.
• Accounting and tax records.
HMCY does not normally receive or retain complete payment card information when payment is handled by an external payment provider.
Marketing information
• Whether you have consented to marketing.
• The date, source and wording of that consent.
• Email engagement information,where provided by the email platform.
• Unsubscribe or communication-preference records.
• Lead source, campaign, advertisement and form information.
Website and technical information
• Internet Protocol address.
• Browser, device and operating-system information.
• Website pages visited and interactions with the website.
• Cookie preferences.
• Security, diagnostic and website-performance information.
Testimonials, recordings and case material
Testimonials, identifiable case material, photographs, audio recordings or video recordings will only be used where appropriate, and separate permission has been obtained.
4. HEALTH AND OTHER SENSITIVE INFORMATION
Information concerning physical health, mental health or treatment may constitute special-category personal data under data-protection law.
HMCY will only collect sensitive information that is reasonably relevant to:
• Assessing whether a service is appropriate.
• Providing services safely and responsibly.
• Personalising therapeutic or coaching work.
• Maintaining appropriate professional records.
• Meeting safeguarding, insurance, legal or professional responsibilities.
Where required, explicit consent will be requested before this information is processed. Other lawful conditions may apply where processing is necessary to establish or defend legal claims, protect vital interests or meet another applicable legal responsibility.
You may decline to provide information, but HMCY may be unable to offer or continue a service if relevant information needed for suitability or safety is unavailable.
5. HOW INFORMATION IS COLLECTED
Information may be collected:
• Directly from you during enquiries, forms, discovery calls and sessions.
• Through the HMCY website, Wix Forms, Wix Bookings and website member features.
• Through email, telephone, video conferencing or messaging.
• Through Meta lead forms when you respond to an HMCY advertisement.
• Through payment, invoice and booking systems.
• Automatically through essential website technologies and, where permitted, analytics or marketing cookies.
• From another professional or person to whom you have authorised the disclosure or for which another lawful basis applies.
6. WHY WE PROCESS INFORMATION
HMCY may process personal information to:
• Respond to enquiries.
• Arrange and conduct discovery calls.
• Assess suitability for a service or programme.
• Manage bookings, appointments and cancellations.
• Provide Clinical Hypnotherapy, NLP Coaching and related support.
• Deliver Executive Reset, Coaching Excellence and other agreed programmes.
• Personalise services around your goals and circumstances.
• Maintain appropriate consent and practitioner records.
• Send invoices and administer payments.
• Provide requested resources and communications.
• Maintain professional boundaries, safety and service quality.
• Meet legal, accounting, insurance and professional obligations.
• Establish, exercise or defend legal claims.
• Protect the security and operation of the website and business systems.
• Send marketing communications where valid permission has been provided.
• Understand how the website and campaigns perform where lawful cookie consent or another appropriate basis applies.
7. LAWFUL BASES
Depending on the purpose, HMCY may rely on:
Steps before entering a contract
This may apply when you request information, book a discovery call or ask HMCY to prepare a proposal.
Contract
This may apply when information is necessary to arrange, administer or deliver an agreed paid service or programme.
Consent
This may apply to marketing, optional cookies, testimonials, recordings and certain processing of sensitive information. Consent may be withdrawn at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.
Legitimate interests
This may apply to responding to enquiries, maintaining website security, improving business administration, managing professional communications and establishing or defending legal claims. HMCY will consider your interests, rights and reasonable expectations before relying on legitimate interests.
Legal obligation
This may apply where information must be retained or disclosed to comply with tax, accounting, court, regulatory or other legal requirements.
Vital interests
This may apply in exceptional situations involving a serious and immediate risk to someone’s life or safety.
Special-category information will only be processed where both a general lawful basis and an appropriate additional condition are available.
8. DISCOVERY CALLS AND SUITABILITY
A discovery call is an introductory conversation used to understand what you would like support with, discuss possible options and consider suitability.
Information shared during a discovery call may be recorded in brief professional or administrative notes.
Booking or attending a discovery call does not require either you or HMCY to begin an ongoing professional relationship.
9. SERVICE COMMUNICATIONS AND MARKETING
HMCY may contact you about:
• A form or enquiry you submitted.
• A discovery call or appointment.
• An agreed service or programme.
• An invoice or payment.
• Information reasonably necessary to administer your relationship with HMCY.
These are service or administrative communications, separate from marketing.
HMCY will send promotional emails, wellbeing information or service announcements where appropriate marketing permission has been recorded.
You may unsubscribe from marketing at any time by:
• Using the unsubscribe link in an email.
• Contacting info@hmcy.org.
Unsubscribing from marketing does not prevent HMCY from sending necessary booking, payment, consent, safety or service communications.
A minimal suppression record may be retained to ensure that an unsubscribe request continues to be respected.
10. META LEADS AND AUTOMATED WORKFLOWS
When you submit information through a Meta lead form, Meta initially processes that information under its own privacy arrangements.
The information selected in the form may then be transferred to HMCY and authorised business systems for the purpose explained in the advertisement and form.
HMCY may use automated workflows to:
• Transfer authorised lead information between Meta and Wix.
• Create or update a contact record.
• Record the source of an enquiry and marketing consent.
• Send a resource requested by the person.
• Administer bookings and related communications.
Make.com may be used to facilitate an authorised transfer between Meta and Wix.
HMCY does not make decisions about a person’s suitability for therapy or coaching solely through automated processing.
10A. HMCY SUPERVISION COMPANION AND AI PROCESSING
The HMCY Supervision Companion is an AI-supported practice and reflective-learning tool for practitioners. It may be used in AI Supervisor mode for reflective supervision conversations or in AI Supervisee mode to practise supervision skills with a fictional or simulated supervisee.
The Companion supports professional reflection, supervision practice and development. It does not replace qualified human supervision, professional judgement, clinical governance or a practitioner's own ethical and professional responsibilities.
Information used by the Companion
Depending on how the Companion is used, HMCY may process:
• Website member and session identifiers.
• Selected supervision mode, guidance level and session settings.
• Scenario or supervision-focus information.
• Text generated from the supervision conversation.
• Developmental feedback, strengths, development areas, key reflections and next steps.
• Saved supervision-record names.
• A concise continuity summary where a supervision thread is saved for later continuation.
• Technical and diagnostic information reasonably required to operate, secure or troubleshoot the service.
Client confidentiality and anonymisation
The Companion is intended for practice and reflective learning using fictional, simulated, composite or appropriately anonymised material.
Users must not enter information that identifies, or could reasonably identify, a real client, patient or other third party. This includes names, contact details, addresses, dates of birth, identification numbers, medical-record identifiers, case numbers, employer details, or combinations of circumstances that could reasonably identify a person.
When a practitioner refers to real professional experience for reflective purposes, they remain responsible for ensuring the material is appropriately anonymised and that its use aligns with their professional, ethical, confidentiality, and data-protection obligations.
The Companion is not intended to function as a client record, patient record, or case-management system.
AI and voice processing
The Companion uses the OpenAI API to provide AI voice interaction, reasoning and developmental feedback.
During a live voice session, audio is processed so that the AI can understand and respond to the user. HMCY does not intentionally create or retain a separate audio recording of the supervision session within its Wix systems.
Relevant OpenAI API requests are configured with available settings intended to minimise persistent storage, including store:false where supported.
OpenAI states that data submitted through its API is not used to train or improve its models unless the customer has explicitly opted in to data sharing. Under OpenAI's standard API data controls, abuse-monitoring logs may contain customer content such as prompts and responses and are normally retained for up to 30 days, unless longer retention is required by law or is reasonably necessary for security or harm-prevention purposes. OpenAI Developers
HMCY may adopt additional OpenAI data-retention controls, including Zero Data Retention or Modified Abuse Monitoring, if and when these controls are made available to HMCY.
Temporary transcript processing
During an active session, text derived from the conversation may be stored temporarily within HMCY's Wix systems so that post-session developmental feedback and continuity information can be generated.
After HMCY successfully generates and saves the required developmental feedback and continuity information, it automatically deletes the raw transcript messages associated with that session from HMCY's Wix database.
If post-session processing fails, transcript information may remain temporarily so you can retry processing rather than losing the session.
The raw transcript is not used as the long-term memory for an ongoing supervision record.
Saved supervision and continuity
Where a user chooses to save or continue a supervision record, HMCY may retain the information reasonably required to maintain continuity between sessions.
This may include supervision settings, developmental feedback, reflective information, the saved-record title and a concise rolling continuity summary.
The continuity summary preserves relevant context without retaining or replaying complete previous transcripts.
Deleting supervision records
Users can delete an individual saved supervision record or delete all saved supervision records through the Companion.
Deleting a saved supervision record removes the associated saved record, linked sessions, developmental feedback, reflections, continuity information and any remaining linked transcript messages held within HMCY's Wix systems.
Deletion from HMCY's systems does not necessarily result in immediate deletion of information temporarily retained by third-party infrastructure providers for legitimate security, abuse-prevention or legal purposes. For example, under OpenAI's standard API controls, relevant API content may remain in abuse-monitoring logs for up to 30 days as described above. OpenAI Developers
Sensitive information
The Companion is not intended to collect identifiable client health information, medical information or other special-category personal data about third parties.
Health information relating to an identifiable person can constitute special-category personal data under the GDPR and receives additional protection. Eur-Lex
Because users control what they say or type, they could still disclose sensitive or confidential information contrary to these instructions. Users must therefore remove identifying information and appropriately anonymise professional material before using it within the Companion.
Safeguarding
The Companion may discuss safeguarding, self-harm, suicide, abuse, violence or other high-risk topics as part of fictional, simulated or professional practice scenarios.
A hypothetical or practice scenario is not automatically treated as evidence of a real emergency.
Where information provided to the Companion appears to indicate a real and current risk of serious harm, the Companion may encourage the user to seek appropriate real-world safeguarding, professional or emergency support.
The HMCY Supervision Companion is not an emergency service.
11. COOKIES, CONSENT AND WEBSITE TECHNOLOGIES
Healing Mind CY uses cookies, local storage, tags and similar website technologies to operate and secure the website, provide requested functionality and, where permitted, understand website use and measure marketing effectiveness.
Cookie and technology preferences are managed through Usercentrics for Wix. Technologies are grouped into categories including Essential, Functional, Analytics and Marketing. Essential technologies support functions such as website security, network management, consent management, account access, forms and bookings. Optional Functional, Analytics and Marketing technologies are used according to the visitor’s consent choices.
Where Analytics consent is provided, HMCY may use services including Wix Analytics, Google Analytics and TWIPLA Website Intelligence, including website interaction and session-recording features where enabled, to understand how visitors use the website and to identify technical or usability improvements.
Where Marketing consent is provided, technologies such as Google Ads and other advertising measurement services may be used to measure campaign effectiveness. Meta/Facebook advertising technologies may also be used where enabled.
The website uses Google Consent Mode v2. Where relevant consent is denied, Google technologies may operate in a restricted mode and may send limited cookieless measurement signals without reading or writing analytics or advertising cookies. Where the relevant consent is granted, additional measurement functionality and cookies may be enabled.
Embedded or third-party content, including services such as YouTube, Google Maps and Botpress, may process technical information such as IP address, device or browser information and interactions when those services are loaded.
HMCY may retain a record of cookie and privacy choices for compliance purposes. This may include a consent identifier, the date and time of the decision, consent categories and associated technical information.
Visitors can change or withdraw their optional consent at any time using the privacy settings control available throughout the website. They may also manage or delete cookies through their browser settings, although disabling essential technologies may affect website functionality.
12. HOW INFORMATION MAY BE SHARED
HMCY does not sell personal information.
Information may be shared only where reasonably necessary with:
Wix
For website hosting, forms, contact records, bookings, invoices, member features and email automation.
Meta
Where you interact with HMCY through Facebook, Instagram, advertising or a Meta lead form.
Make.com
Where an authorised automation transfers lead information between connected systems.
Communication providers
• For email, telephone, messaging or video-conferencing services.
• Payment providers and financial institutions
• For processing or confirming payments.
• Secure technology and storage providers
Where systems are used to maintain authorised business or professional records
Professional advisers
Including accountants, insurers, legal advisers or technical specialists where reasonably necessary.
Professional supervisors
Relevant aspects of client work may be discussed within professional supervision for ethical practice, professional development and client care. Identifying information will be minimised or anonymised wherever reasonably possible.
Public authorities
Information may be disclosed where required by law, a valid court order or another binding legal obligation.
Safety-related disclosure
Information may be disclosed where there is a lawful and proportionate need to address a serious and immediate risk of harm.
Service providers are expected to handle information only for authorised purposes and with appropriate confidentiality and security arrangements.
13. INTERNATIONAL TRANSFERS
Some service providers may process or store information outside Cyprus or the European Economic Area.
Where data-protection law requires additional safeguards, HMCY will seek to use providers and arrangements supported by:
• An applicable adequacy decision.
• Approved contractual protections.
• Another valid transfer mechanism.
The protections available in another country may differ from those in Cyprus. You may contact HMCY for further information about relevant transfer safeguards.
14. HOW LONG IIS INFORMATIONRETAINED
HMCY will not retain personal information for longer than reasonably necessary for the purpose for which it was collected.
The following periods or criteria normally apply:
Enquiries that do not become client relationships
Normally retained for up to 12 months after the last meaningful communication, unless there is a valid reason to retain them longer.
Marketing information
Retained while consent remains valid or until you unsubscribe. A minimal suppression record may be retained afterwards.
Client consent, intake and practitioner records
Normally retained for the period reasonably required to meet professional, insurance, safeguarding and legal responsibilities. HMCY’s intended standard retention period is up to seven years after the final professional contact, unless a different period is required or justified.
Financial and invoice records
Retained for the period required by applicable accounting and tax law.
Website, security and diagnostic records
Retained according to operational, security and provider requirements and deleted or anonymised when no longer reasonably necessary.
Meta and automation information
Retained only for as long as reasonably necessary to administer the enquiry, demonstrate consent, maintain accurate contact records or troubleshoot an authorised automation.
Information may be retained longer where necessary for a legal obligation, complaint, safeguarding matter or legal claim.
15. SECURITY
HMCY takes reasonable technical and organisational measures to protect personal information against:
• Unauthorised access.
• Accidental loss.
• Inappropriate use or disclosure.
• Unauthorised alteration.
• Destruction.
Measures may include access controls, account security, restricted permissions, trusted providers, confidentiality arrangements, backups and appropriate separation of professional information.
No internet transmission or electronic-storage method can be guaranteed as completely secure. HMCY will review suspected personal-data breaches and notify the relevant supervisory authority and affected individuals where required by law.
16. YOUR DATA-PROTECTION RIGHTS
Depending on the circumstances and applicable law, you may have the right to:
• Be informed about how your information is used.
• Request access to your personal information.
• Ask for inaccurate or incomplete information to be corrected.
• Request deletion of information.
• Request restriction of processing.
• Object to processing based on legitimate interests.
• Withdraw consent.
• Request data portability where applicable.
• Object to direct marketing.
• Raise concerns about solely automated decisions where applicable.
• Complain to a data-protection supervisory authority.
These rights are not absolute. HMCY may need to retain certain information where there is a legal, professional or compelling lawful reason.
Withdrawing consent does not affect processing that was lawful before consent was withdrawn.
To exercise a right, contact info@hmcy.org. HMCY may need to verify your identity before responding.
17 CHILDREN AND YOUNG PEOPLE
HMCY services are normally intended for adults aged 18 or over.
HMCY does not knowingly offer services to, or collect service-related information from, a person under 18 without appropriate prior agreement, consent and safeguarding arrangements.
If you believe that a person under 18 has submitted personal information without appropriate authorisation, contact info@hmcy.org.
18. CONFIDENTIALITY AND PROFESSIONAL SUPERVISION
Information shared within Clinical Hypnotherapy, NLP Coaching or related services will normally be treated as confidential.
Confidentiality may have limited exceptions where:
• You authorise information to be shared.
• Appropriately anonymised information is discussed in professional supervision.
• Disclosure is required by law.
• There is a lawful and proportionate reason to address a serious and immediate risk of harm.
Where reasonably possible and appropriate, HMCY will discuss a proposed disclosure with you.
18. THIRD-PARTY WEBSITES
The HMCY website may contain links to websites operated by other organisations.
HMCY does not control how those websites collect or process information. You should review the privacy information provided by the relevant third party before submitting personal information.
19. BUSINESS CHANGES
If the HMCY business is reorganised, transferred or succeeded by another provider, relevant information may need to be transferred as part of that change.
Any transfer will be handled subject to applicable data-protection requirements, professional confidentiality and appropriate notice to affected individuals.
20. CHANGES TO THIS PRIVACY POLICY
HMCY may update this Privacy Policy when services, systems, providers, legal requirements or professional practices change.
HMCY will publish the revised policy on this page with an updated revision date.
If a change materially affects how HMCY processes existing client information, HMCY will provide additional notice where reasonably necessary or legally required.
21. QUESTIONS, REQUESTS AND COMPLAINTS
Please contact HMCY first if you have a question, request or concern about your information:
Healing Mind CY
Charalambos “Charles” Eleftheriou
Email: info@hmcy.org
Telephone: +357 99 331689
Website: https://www.hmcy.org/contact
You also have the right to complain to the Office of the Commissioner for Personal Data Protection in Cyprus or another competent supervisory authority.
Cyprus Commissioner for Personal Data Protection:
https://www.dataprotection.gov.cy
UK ICO registration reference, where applicable: ZB857379.
22. RELATED HMCY INFORMATION
Privacy Policy:
https://www.hmcy.org/privacypolicy
Website and Service Terms:
https://www.hmcy.org/terms
Informed Consent and Client Acknowledgement:
https://www.hmcy.org/client-consent
Contact HMCY:
https://www.hmcy.org/contact