PRIVACY POLICY

She Thinks Different

Last updated: September 2026

At She Thinks Different, we take your privacy seriously. This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and your rights under UK data protection law.

She Thinks Different is a trading name operated by The Center of Wellbeing.

The data controller is Gemma Louise Wharton, registered with the Information Commissioner's Office (ICO), registration reference ZB692697.

Contact:
info@shethinksdifferent.co.uk
gemma@thecenterofwellbeing.co.uk

This Privacy Policy applies to our website and services, including neurodivergent coaching and therapy, the Bluebell Path, PARS therapeutic and psychological interventions, online workshops and programmes, and corporate wellness consultancy.

1. INFORMATION WE MAY COLLECT

Depending on the service you use and how you interact with us, we may collect:

Your name
Email address
Telephone number
Contact and emergency-contact information
Information submitted through website or enquiry forms
Workshop and programme bookings
Payment and transaction information
Your chosen workshop cohort or programme
Communications between you and She Thinks Different
Information required to provide coaching, therapy or psychological interventions
Relevant health and mental-health information
Information relating to neurodivergence, including ADHD or autism where relevant
Relevant diagnoses, medication or treatment information that you choose to provide
Assessment, formulation, therapeutic and session information
Session and clinical notes
Goals, progress and outcome information
Risk and safeguarding information where relevant
Parent or guardian information where we work with a child or young person
Information provided by or shared with other professionals where appropriate and lawful
Information relating to corporate wellness services and business contacts
Information you voluntarily provide when participating in workshops, programmes or communities
Website usage and cookie information

We aim to collect only information that is reasonably necessary for the service we are providing.

Payments made through our website are processed using third-party payment services. We do not need to receive or store your complete card details ourselves in order to process your booking.

2. HOW WE USE YOUR INFORMATION

We may use your information to:

Respond to enquiries
Arrange appointments, consultations and services
Provide neurodivergent coaching and therapeutic services
Provide the Bluebell Path
Deliver PARS therapeutic and psychological interventions
Maintain appropriate therapeutic and clinical records
Develop formulations, therapeutic plans and appropriate interventions
Monitor progress and outcomes
Communicate with clients, parents or guardians where appropriate
Manage safeguarding, welfare or risk concerns where necessary
Liaise with other professionals or services where appropriate and lawful
Process and administer bookings and payments
Confirm workshop or programme places
Send Microsoft Teams links and joining instructions
Send workbooks, resources and programme materials
Manage workshop cohorts and participant lists
Provide access to relevant communities and resources
Deliver corporate wellness consultancy
Maintain appropriate business, financial and regulatory records
Operate, protect and improve our website and services

PARS is provided as a therapeutic and psychological intervention. She Thinks Different does not provide formal ADHD or autism diagnoses through PARS.

3. OUR LAWFUL BASES

Under UK data protection law, we must have a lawful basis for processing personal information.

Depending on the purpose and circumstances, we may rely on:

Contract — where processing is necessary to provide a service you have requested or purchased or to take steps at your request before entering into a contract.

Legal obligation — where we need to process information to comply with a legal or regulatory obligation.

Legitimate interests — where processing is reasonably necessary for the legitimate interests of operating, administering, protecting and improving She Thinks Different, providing appropriate services, responding to enquiries and communicating with clients or customers, provided those interests are not overridden by your rights and interests.

Consent — where you have specifically agreed to a particular use of your information and consent is the appropriate lawful basis.

Vital interests — in limited circumstances where processing is necessary to protect someone's life.

Where we rely on consent, you can withdraw that consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

4. HEALTH AND OTHER SPECIAL CATEGORY INFORMATION

Because some of our services involve therapeutic, psychological and neurodivergence-related support, we may need to process information concerning physical or mental health, neurodivergence or other information classified as special category personal data.

Special category data receives additional protection under UK data protection law.

Where we process special category information, we will identify an appropriate lawful basis under Article 6 of the UK GDPR and an appropriate condition under Article 9, together with any applicable requirements of the Data Protection Act 2018.

Depending on the circumstances and purpose of the processing, relevant conditions may include the provision of health or social care or treatment, explicit consent, safeguarding or other conditions permitted by law.

We will only process this information where it is necessary and proportionate for the relevant purpose and will apply appropriate confidentiality and security safeguards.

5. CHILDREN AND YOUNG PEOPLE

Some She Thinks Different services are provided to children and young people.

Where we work with a child or young person, we take particular care with their personal information and aim to explain how their information will be used in a way that is appropriate to their age and level of understanding.

Depending on the child's age, capacity, the nature of the service and the circumstances, we may also collect and use information relating to a parent, guardian or other person with parental responsibility.

We respect the privacy of children and young people while recognising that there may be circumstances in which information needs to be shared with a parent, guardian, safeguarding professional or another appropriate person.

Where there is a safeguarding concern or a risk of serious harm, information may be shared where this is necessary and lawful to protect the child, young person or another person.

Children and young people have data-protection rights in their own right.

6. CONFIDENTIALITY, RISK AND SAFEGUARDING

Information shared during therapeutic or psychological services is treated confidentially.

However, confidentiality is not absolute.

There may be circumstances where we need to disclose relevant information, including where:

There is a serious concern about your safety or the safety of another person
There is a safeguarding concern involving a child or vulnerable person
We are legally required to disclose information
Disclosure is otherwise necessary and lawful

Where appropriate and safe to do so, we will normally seek to discuss such disclosure with you.

We will only share information that is reasonably necessary for the relevant purpose.

7. EMAIL COMMUNICATIONS

If you purchase or participate in one of our workshops, programmes or services, we will use the email address you provide to send communications necessary to administer and deliver that service.

These may include:

Booking confirmations
Appointment information
Joining instructions
Programme updates
Microsoft Teams links
Workbooks
Resources
Information relating to your participation

Purchasing or accessing a service does not automatically subscribe you to marketing emails.

If She Thinks Different introduces an optional marketing mailing list in the future, this will be managed separately and, where required, you will be asked to provide appropriate consent.

8. WHO WE SHARE INFORMATION WITH

We do not sell your personal information.

Where necessary and lawful, information may be shared with trusted organisations or professionals involved in operating our business or delivering services.

These may include providers of:

Website hosting, registration and booking services
Payment processing
Email and communications
Microsoft Teams and Microsoft 365
Secure IT and cloud storage
Accounting, legal and professional services

In appropriate circumstances, information may also be shared with:

Parents or guardians
Healthcare professionals
GPs
Schools or educational professionals
Social care or safeguarding services
Emergency services
Other professionals involved in your care or support
Relevant authorities where disclosure is required or permitted by law

We will only share information where there is an appropriate reason and lawful basis to do so and will aim to limit disclosure to information reasonably necessary for that purpose.

Third-party organisations may process information on our behalf or, in some circumstances, act as independent data controllers.

9. CORPORATE WELLNESS SERVICES

Where we provide corporate wellness consultancy, we may process information relating to organisations, employees, representatives or other business contacts.

Where possible, reporting and recommendations provided to organisations will use aggregated or anonymised information rather than identifying individual participants.

Where identifiable information needs to be processed or disclosed, we will ensure there is an appropriate lawful basis and will explain how that information will be used where required.

10. INTERNATIONAL DATA TRANSFERS

Some technology providers we use may process or store information outside the United Kingdom.

Where personal information is transferred internationally, we take reasonable steps to ensure appropriate safeguards recognised under UK data protection law are in place.

11. HOW LONG WE KEEP YOUR INFORMATION

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable legal, professional, regulatory, contractual, tax and accounting requirements.

Different types of information may therefore have different retention periods.

Clinical and therapeutic records may need to be retained for longer periods than general workshop or enquiry information, particularly where services have been provided to children or young people.

Booking, payment and transaction records may be retained for the period required to meet applicable legal, tax and accounting obligations.

Workshop and programme participant information will be retained only for as long as reasonably necessary to administer the programme, provide associated services and resources, respond to subsequent enquiries and meet applicable legal obligations.

When information is no longer required, we will securely delete, anonymise or otherwise dispose of it where appropriate.

12. SECURITY

We take reasonable organisational and technical measures to protect personal information against unauthorised access, accidental loss, misuse, alteration or disclosure.

Access to sensitive and clinical information is limited to those who reasonably require it for legitimate professional or business purposes.

Because health and therapeutic information can be particularly sensitive, we recognise the importance of applying appropriate additional safeguards to this information.

However, no method of electronic transmission or storage can be guaranteed to be completely secure.

13. YOUR DATA PROTECTION RIGHTS

Depending on the circumstances, UK data protection law may give you rights including the right to:

Ask for access to personal information we hold about you
Ask us to correct inaccurate or incomplete information
Ask us to erase your information in certain circumstances
Ask us to restrict how your information is processed
Object to certain processing
Request transfer of your information in certain circumstances
Withdraw consent where processing is based on consent

These rights are not absolute and do not all apply in every circumstance.

To exercise your rights, contact:

info@shethinksdifferent.co.uk
or
gemma@thecenterofwellbeing.co.uk

14. COOKIES

Our website uses cookies and similar technologies to help the website function correctly and, where applicable, to understand how visitors use our website.

Some cookies are essential for the operation of the website and do not require consent. Other cookies, such as analytics, functionality or advertising cookies, may require your consent.

Where consent is required, you can choose whether to accept or reject non-essential cookies through our cookie consent banner.

You can also change your cookie preferences at any time using our cookie settings.

15. OTHER WEBSITES

Our website may contain links to websites or services operated by third parties.

We are not responsible for the privacy practices of independent third-party websites or services and encourage you to review their privacy information when leaving our website.

16. COMPLAINTS

If you have concerns about how we use your personal information, please contact us first so that we have an opportunity to address them.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our services, technology, business practices or legal obligations.

The latest version will be available on this website, with the date it was last updated shown at the top.

CONTACT US

For questions about this Privacy Policy, your personal information or how your information is handled: