Privacy Policy for Clients in Australia
Online Psychotherapy Services Provided from Poland
About This Policy
This Privacy Policy explains how I collect, use, store, share, and protect your personal data and personal information when you use my online psychotherapy services, particularly if you are located in Australia. In couples therapy, it applies to both partners; you are each treated as a client and give your own consent.
It should be read together with the therapy agreement, which sets out the terms of the service itself—scope, fees, cancellation, crisis arrangements, and so on. Where a question concerns how your information is handled, this policy applies.
As the person responsible for your data (the "controller"), I process it in line with the EU General Data Protection Regulation (GDPR). Where you are located in Australia, the Australian Privacy Act 1988 and the Australian Privacy Principles may also be relevant, as explained in the "Australian Privacy Principles and Consumer Rights" section below.
This policy is effective from June 26, 2026, and may be updated in the event of changes in law, the manner in which services are provided, the technical tools used, or the rules concerning data processing.
1. About My Practice (Your Data Controller)
Business name: Ewelina Tur
Address: Mazowiecka 11 lok. 49, 00-052 Warsaw, Poland
Tax ID (NIP): 8442317749
Phone: (+48) 514 130 322
Email: ewelinatur@gmail.com
Website: https://www.ewelinatur.com
Degree/Licence and Number/Country: M. Psych. No. 47687/CCBT No. 1183/Poland
I hold current professional insurance with STU ERGO HESTIA S.A. The full insurance certificate is available upon request.
2. What Data I Collect & Process
In connection with the provision of services, I may process:
identification and contact details, including your name, email address, and telephone number;
your current residential address in Australia and emergency contact details;
information disclosed during the therapeutic process, including information concerning
your personal, relational, family, and emotional circumstances;
special category data, in particular information concerning physical and mental health,
sex life, sexual orientation, family relationships, and partner relationships;
billing information required to issue an invoice or receipt;
basic technical information necessary for online communication.
I do not collect information that is not necessary to provide services, maintain records, bill, ensure the safety of the therapeutic process, or comply with legal obligations.
3. Purposes and Legal Bases for Processing
I process personal data for the following purposes:
entering into and performing an agreement for the provision of online psychotherapy services – Article 6(1)(b) GDPR;
conducting the therapeutic process and maintaining necessary records – Article 6(1)(b) GDPR and, where special category data are processed, Article 9(2)(a) GDPR;
billing and complying with tax obligations – Article 6(1)(c) GDPR;
protecting the life, health, or safety of the client or other persons – Article 6(1)(d) GDPR and Article 9(2)(c) GDPR;
establishing, exercising, or defending legal claims – Article 6(1)(f) GDPR and, where special category data are processed, Article 9(2)(f) GDPR;
obtaining professional supervision or specialist consultation, subject to confidentiality and only to the extent necessary for that purpose – Article 6(1)(f) GDPR and Article 9(2)(a) GDPR.
4. Special Category Data
Due to the nature of online psychotherapy, the provision of services may require the processing of special category data.
Before starting work together, the client will be asked to provide explicit consent to the processing of such data. Consent may be withdrawn at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal, but it may prevent the continuation of services if processing such data is necessary for therapy.
5. Data Retention
I retain personal data for as long as necessary to fulfil the purposes for which it was collected.
As a general rule, records related to the therapeutic process may be retained for up to 6 years after the end of our work together, unless a longer retention period is required by law or justified by the need to protect against legal claims, client safety concerns, or professional obligations.
Accounting and tax records are retained for the period required by applicable law.
6. Recipients of Data
Personal data may be disclosed only where necessary and lawful, in particular to:
providers of email services, video consultation systems, hosting, IT services, and payment services;
accounting service providers;
legal advisers;
professional indemnity insurers;
professional supervisors or consultants;
public authorities, courts, or other authorised bodies, where required by law;
emergency services or the emergency contact nominated by the client, where necessary to protect life, health, or safety.
7. Transfers of Data Between Australia and Poland
The services are provided on a cross-border basis. This means that personal data may be transferred between Australia and Poland.
Data may be stored in Poland or within the European Economic Area. Where tools or service providers located outside the EEA are used, data may also be transferred to other countries.
Where data is transferred outside the EEA, appropriate safeguards required under the GDPR are applied, in particular standard contractual clauses, data processing agreements, and technical and organisational measures designed to protect confidentiality.
The client acknowledges that cross-border data transfers are connected with the use of online psychotherapy services provided from Poland to persons located in Australia.
8. Data Security
I apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration, or disclosure.
However, online communication, including video consultations, email, and internet-based services, may involve technical risks that cannot be completely eliminated.
9. Client Rights
You have the right to:
access your data;
receive a copy of your data;
rectify inaccurate data;
request erasure of data, where legally available;
restrict processing;
request data portability;
object to processing based on legitimate interests;
withdraw consent at any time;
lodge a complaint with a supervisory authority.
In the case of couples therapy, the exercise of some rights may require consideration of the rights and confidentiality of the other partner, the safety of persons, legal obligations, or the need to protect against legal claims.
10. Australian Privacy Principles and Consumer Rights
If you are located in Australia, I acknowledge that the Australian Privacy Act 1988 and the Australian Privacy Principles may be relevant, particularly regarding transparency, the protection of sensitive information, data security, and overseas data transfers.
To the extent that mandatory provisions of Australian consumer law apply, including the Australian Consumer Law, nothing in this Privacy Policy or in the agreement with the client is intended to exclude any rights that cannot lawfully be excluded.
Detailed terms concerning the provision of services, payments, cancellation of sessions, termination of cooperation, crises, and liability are set out in the therapeutic agreement.
11. Automated Processing
I do not make decisions concerning clients based solely on automated processing, including profiling, which would produce legal effects concerning clients or similarly significantly affect them.
12. Contact and Complaints
For matters concerning personal data, privacy, or the exercise of your data protection rights, you may contact me at:
Ewelina Tur
Address: Mazowiecka 11 lok. 49, 00-052 Warsaw, Poland
Email: ewelinatur@gmail.com
Phone: (+48) 514 130 322
Website: https://www.ewelinatur.com
You have the right to lodge a complaint with:
the President of the Personal Data Protection Office in Poland;
the competent supervisory authority in the European Economic Area, where applicable;
the Office of the Australian Information Commissioner (OAIC), where Australian law applies.