Privacy Policy — Lumina Soul Therapy
Trading name: Lumina Soul Therapy
Legal entity: Roswitha Gaudion-Roseleur (sole trader)
Registered address: 12 The Meadows, Gillingham, Dorset, SP8 4SP, United Kingdom
Contact email: luminasoultherapy@gmail.com
Website: https://www.riseintoyourlight.co.uk/rise-into-your-light
Date last updated: 14/08/2026
1. Who we are
1.1 For the purposes of data protection law, the "controller" responsible for your personal data is Roswitha Gaudion-Roseleur, trading as Lumina Soul Therapy (referred to in this policy as "Lumina", "we", "us" or "our").
1.2 We are the controller because we decide how and why your personal data is used when you interact with our website, podcast, courses, quiz, and one-to-one services.
1.3 You can contact us about anything in this policy by emailing luminasoultherapy@gmail.com.
1.4 We are a small UK sole trader. We are not required to register with or pay a fee to the Information Commissioner's Office (ICO) under the current exemption for small businesses, but we are still fully required to comply with the UK GDPR and the Data Protection Act 2018.
2. What this policy covers
2.1 This policy explains what personal data we collect about you, how and why we use it, who we share it with, how long we keep it, and what rights you have.
2.2 It applies to: (a) visitors to our website; (b) people who sign up to our newsletter or download free resources; (c) people who take our free quiz or archetype assessment; (d) people who purchase our products and courses (including The Inner Light Process); (e) people who book one-to-one RTT or EFT sessions with us; (f) members of our private Facebook community; (g) listeners of our podcast "The Inner Work" who contact us directly.
2.3 It does not apply to third-party platforms themselves (Facebook, Instagram, Stripe, Systeme.io, Interact, podcast hosting platforms). Each of those has its own privacy practices, and we encourage you to read them.
3. What is "personal data"?
3.1 Personal data is any information that can identify you as a living person, directly or indirectly. Examples include your name, email address, billing address, IP address, and information you share with us during sessions.
3.2 Some personal data is "special category data" under UK GDPR Article 9, which gets extra protection. This includes data about your health, mental health, or therapeutic history. We treat any information you share in RTT/EFT sessions as special category data. See clause 8 for more.
4. What data we collect, and how
We collect personal data in four ways: (a) you give it to us directly, (b) we collect it automatically as you use our site, (c) third parties provide it, and (d) it is generated by your use of our products and services.
4.1 Data you give us directly
Email and name when you sign up to our newsletter, download a free resource, or fill in a contact form
Email and answers when you complete our free quiz or archetype assessment
Name, email, billing address, and card details when you purchase a product or course (card details are handled by Stripe and are not stored by us)
Shipping address and phone number when you order a physical product such as the Reclamation Journal or Toolkit
Information you share with us in RTT or EFT sessions, including your answers to our pre-session intake questions, your therapeutic goals, what comes up during a session, and our session notes
Information you share in the private Facebook community, including posts, comments, and direct messages to us
Correspondence when you email us, request a refund, make a complaint, or otherwise contact us
4.2 Data we collect automatically
When you visit our website we, or our analytics provider, may automatically collect:
IP address
Device type and browser
Pages visited, time on page, and referring URL
Cookies and similar identifiers (see clause 11)
We use this data to understand how visitors use the site and to improve it. It is not used to identify you personally.
4.3 Data from third parties
Payment processor (Stripe): confirms whether a payment has succeeded or failed and provides us with your name, billing email, and last four digits of the card
Sales platform (Systeme.io): stores your order, course enrolment, and email subscription status
Quiz platform (Interact): sends us your email and your quiz answers when you complete the quiz
Facebook: when you join our private community or interact with our Facebook page, Facebook shares relevant metadata with us about your membership and engagement
Podcast hosting platforms (such as Spotify and Apple Podcasts): collect their own analytics about listeners. We have limited visibility into this, please see their own privacy notices
Royal Mail / courier: may notify us of delivery status for physical products
4.4 Data generated by your use of our products
Your progress through our courses (lessons completed, downloads accessed)
The Annual Letter to Yourself exercise — if you choose to submit a digital copy or share it with us, we store it
Your community membership history
5. How and why we use your data (lawful bases)
Under UK GDPR, every use of your personal data needs a "lawful basis". Here is what we rely on for each type of activity:
Where we rely on legitimate interests, you have the right to object (see clause 9).
6. Who we share your data with
We do not sell your personal data. We share it only with the people and organisations that help us run the business, and only the minimum they need to do their job.
Stripe — processes card payments. Stripe is a separate data controller for payment data; see stripe.com/privacy.
Systeme.io — runs our checkout, course platform and email system. They store your name, email and order details. See systeme.io/privacy-policy.
Interact — runs our free quiz. They receive your answers and email. See tryinteract.com/privacy-policy.
Facebook (Meta) — for our private community group and for advertising. Facebook acts as a separate data controller for what you do on its platforms. See facebook.com/policy.php.
Royal Mail / our courier — for delivery of physical products. They see your name and delivery address only.
Our accountant / HMRC — for statutory tax and accounts purposes.
Our email and storage providers — currently hosted within the UK and EEA, with limited international transfers as described in clause 7.
Professional advisers and regulators — if we are legally required to share information, or to defend a legal claim.
We do not share your therapy session content with anyone unless you give us written permission, or we are legally required to do so (for example, a court order, or a safeguarding situation where we believe there is a serious risk to life).
7. International transfers
7.1 Some of our service providers are based outside the UK. When we transfer your data outside the UK, we make sure it is protected to UK GDPR standards, for example by using providers that participate in the UK–US Data Bridge, the EU–US Data Privacy Framework, or by using the ICO's International Data Transfer Agreement.
7.2 If you would like details of the specific safeguards in place for any particular transfer, please email luminasoultherapy@gmail.com.
8. Special category data — therapy sessions
8.1 Information you share with us in RTT or EFT sessions (including intake forms, what comes up during a session, and our session notes) is special category data under UK GDPR.
8.2 We rely on the following lawful bases to process this data: (a) UK GDPR Article 9(2)(h) — provision of preventive medicine, occupational health, or the assessment of the working capacity of an employee, which is carried out by a regulated health professional or someone working under their supervision; and (b) UK GDPR Article 6(1)(h) — preventive medicine and the assessment of the working capacity of the natural person.
8.3 We may also rely on your explicit consent in certain cases (Article 9(2)(a)).
8.4 We keep therapy session notes confidential and store them securely. They are not shared with third parties except: (a) with your written consent; (b) where we are legally required to disclose (for example, a court order); (c) where we have a safeguarding duty (a serious and imminent risk to life).
8.5 If we ever need to refer you to another practitioner (for example, your GP), we will only do so with your consent, or where a legal duty applies.
9. Your rights
You have the following rights under UK GDPR. To exercise any of them, email us at luminasoultherapy@gmail.com.
Right of access — ask for a copy of the personal data we hold about you (a "subject access request"). We will respond within one month.
Right of rectification — ask us to correct anything that is wrong or incomplete.
Right of erasure ("right to be forgotten") — ask us to delete your data, where we are not required to keep it for legal reasons (for example, HMRC records).
Right to restrict processing — ask us to pause using your data while a question is resolved.
Right to data portability — receive your data in a machine-readable format (for example, your quiz answers or course progress).
Right to object — object to processing based on legitimate interest, including marketing. We will stop unless we have a compelling reason to continue.
Right to withdraw consent — where we rely on consent (for example, the newsletter), you can withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
Right to complain to the ICO — if you are unhappy with how we handle your data, you can complain to the Information Commissioner's Office at ico.org.uk.
We will respond to most requests within one month. If your request is complex, we may take up to a further two months and will tell you.
10. Marketing and email consent
10.1 When you sign up to our newsletter, download a free resource, or complete our quiz, we ask for your explicit consent. You can unsubscribe at any time by clicking the "unsubscribe" link in any email, or by emailing luminasoultherapy@gmail.com.
10.2 If you are an existing customer, we may email you about similar products and services under the "soft opt-in" rule in PECR (the Privacy and Electronic Communications Regulations). You can opt out at any time, every marketing email has an unsubscribe link.
10.3 We never pass your email address to a third party for their own marketing.
11. Cookies and analytics
11.1 Our website uses cookies. Cookies are small text files placed on your device. We use: (a) Strictly necessary cookies — for the website to function (for example, to remember your checkout progress); (b) Analytics cookies — to understand how visitors use the site; (c) Marketing cookies — where we use advertising or retargeting tools (currently minimal).
11.2 On your first visit, we display a cookie banner that lets you accept or reject non-essential cookies.
11.3 For full details, see our Cookie Policy https://www.riseintoyourlight.co.uk/cookies.
12. How long we keep your data
We do not keep your personal data for longer than we need it. Specific retention periods:
When data reaches the end of its retention period, we delete it securely.
13. How we protect your data
13.1 We take appropriate technical and organisational measures to protect your data, including: (a) encryption of our website (HTTPS / TLS); (b) limited access to personal data on a need-to-know basis; (c) strong, unique passwords and two-factor authentication on our business accounts; (d) secure cloud storage with reputable UK / EEA-based providers; (e) regular review of access logs; (f) safe disposal of data when it is no longer needed.
13.2 Therapy session notes are kept separately from other records and are only accessible to us.
13.3 If we ever suffer a personal data breach that is likely to result in a risk to your rights, we will notify you and the ICO within the timescales required by UK GDPR (within 72 hours of becoming aware, where required).
14. Children
14.1 Our products and services are designed for adults. We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, please email us at luminasoultherapy@gmail.com and we will delete it promptly.
15. Automated decision-making and profiling
15.1 We do not make automated decisions about you that have legal or similarly significant effects.
15.2 Our quiz groups you into an archetype and sends you personalised journaling prompts based on your answers. This is automated but does not produce legal or significant effects on you — it is for your own reflection and personalisation.
16. Third-party links
16.1 Our website may link to third-party sites (for example, our social media pages, podcast platforms, or other resources). We are not responsible for the privacy practices of those sites. We encourage you to read their privacy policies.
17. Changes to this policy
17.1 We may update this policy from time to time. The "Date last updated" at the top will always show when the latest version was published.
17.2 If changes are material (for example, a new use of your data or a new third party), we will notify you by email where we have your email address on file.
18. How to contact us
If you have any questions about this policy, or want to exercise any of your rights, please contact:
Roswitha Gaudion-Roseleur (trading as Lumina Soul Therapy)
Email: luminasoultherapy@gmail.com
Postal address: 12 The Meadows, Gillingham, Dorset, SP8 4SP, United Kingdom
You can also complain to the Information Commissioner's Office at ico.org.uk if you are unhappy with how we handle your data.
End of Privacy Policy