Privacy Policy, Terms of Service, and Scope of Practise

Last updated: 23 February 2026

This page explains how confidentiality, data handling, and client terms work at Wellbeing Mastery Academy. It applies to coaching services, digital materials, online sessions, written communication, and use of wellbeingmastery.academy.

1. Professional Scope & Ethics

I am a Valvira-registered trained masseur and I provide trauma-informed coaching and wellbeing support.

My services are coaching and wellbeing support, not psychotherapy, psychiatric treatment, medical diagnosis, or emergency care.

If your situation needs licensed mental-health or medical treatment, I will support referral to the right professional.

2. Scope of Coaching & Client Safety Policy

Nature of Services

Wellbeing Mastery provides developmental coaching for adults seeking personal growth, emotional development, habit and behavior change, and increased self-awareness. Coaching may include psychology-informed methods such as schema-informed tools and Emotional Freedom Techniques. Coaching is not psychotherapy, psychiatric care, or medical treatment.

What Coaching Is

Coaching focuses on increasing awareness of emotional and behavioral patterns, developing healthier strategies, and processing meaningful life experiences within a growth-oriented context.

What Coaching Is Not

Coaching does not diagnose or treat mental health disorders, does not provide trauma therapy, and does not provide crisis or emergency mental health care. Referral to licensed care will be recommended when necessary.

Suitability Criteria

• Coaching is appropriate for individuals able to engage safely in non-clinical coaching.
• Coaching is not suitable when there is active suicidality or unstable trauma symptoms requiring licensed mental-health treatment.
• Clients must be able to maintain basic daily responsibilities and participate safely in coaching work.

Referral Policy

If symptoms arise that fall outside coaching scope, services will pause and referral to licensed care will be advised.

Client Responsibility

Clients are responsible for providing accurate information and seeking appropriate medical or psychological care when needed. Coaching is not a substitute for psychotherapy.

Emergency Situations

Coaching is not an emergency service. If there is immediate risk or crisis, contact emergency services (112 in Finland) or your local emergency number immediately.

3. Confidentiality

Everything shared in sessions is treated as confidential.

Information is disclosed only if:

• You give explicit written or otherwise recorded consent, or
• Disclosure is required by law.

My aim is to create a safe space where you can speak openly and clearly.

4. Data Controller

Data Controller: Kevin Gibbs / Wellbeing Mastery Academy

Email: kevin@wellbeingmastery.academy

Postal address: Kuutamokatu 6 E 88, 02210 Espoo, Finland

Business ID: 2630250-9

5. What Data I Collect

• Identity and contact details (name, email, phone, messaging handle)
• Booking and service details (session dates, selected services, communication history)
• Payment and invoicing details
• Coaching notes and questionnaire responses
• Optional recordings, only with explicit consent

6. Why I Process Data (Legal Bases)

• To respond to enquiries and arrange sessions (GDPR Art. 6(1)(b))
• To deliver coaching services (GDPR Art. 6(1)(b))
• To meet accounting and legal duties (GDPR Art. 6(1)(c))
• To keep services secure and workable (GDPR Art. 6(1)(f))
• For optional recordings (GDPR Art. 6(1)(a), consent)

If data is processed as healthcare patient data, legal basis may also be legal obligation and healthcare provision under applicable Finnish health-data law.

If sensitive wellbeing/health-related data is processed in coaching context outside statutory patient-record duties, it is handled on explicit consent basis.

Basic identity/contact/booking/payment data is required to provide services. Without it, I may not be able to deliver coaching.

I do not use solely automated decision-making or profiling with legal or similarly significant effects.

7. Session Recordings, Questionnaires, and Communication

No session is recorded without your explicit consent. Recording is always optional and never assumed. You can withdraw recording consent at any time.

Questionnaires and check-ins may be used to personalize your process and track progress.

You can contact me through the channels listed on this website. Typical response time is 24-48 hours on weekdays.

8. Data Sharing and International Transfers

I do not sell personal data.

Data may be shared only when needed with:

• Stripe (payments)
• Hosting and technical service providers
• Accounting providers
• Authorities where legally required

If a provider processes data outside the EU/EEA, lawful safeguards are used.

In plain terms, this usually means either:

• The destination country is officially recognized by the EU as providing adequate protection, or
• EU-approved contract terms are in place (Standard Contractual Clauses).

9. Retention (Important Distinction)

Retention depends on the type of data:

• Healthcare patient records: retained according to Finnish law. As a rule, key patient records are retained for 12 years after death, or 120 years from birth if date of death is unknown.
• Coaching-only records (not statutory patient records): typically up to 36 months after the last session, unless a longer period is needed for legal reasons.
• General enquiries: typically up to 12 months.
• Accounting/tax records: retained for the period required by Finnish law.

Where law requires retention (for example healthcare or accounting records), deletion rights are limited to that extent.

10. Your Rights

You can request:

• Access to your data
• Correction of inaccurate data
• Deletion where legally applicable
• Restriction or objection where applicable
• Data portability where applicable
• Withdrawal of consent for consent-based processing

To exercise rights, contact: kevin@wellbeingmastery.academy

You also have the right to lodge a complaint with the Finnish Data Protection Ombudsman: tietosuoja.fi/en/contact-information

11. Contracts, Programs, and Confirmations

A binding service contract is formed when a service is booked/purchased and accepted under the terms presented at checkout or booking.

For longer coaching programs, I use a written client agreement to keep expectations and boundaries clear for both sides.

For short one-off services, a separate signed document is not always necessary if terms are clearly provided and confirmed in a durable form (for example email confirmation).

12. Payments, Cancellation, and Withdrawal

Payments are processed securely via Stripe when applicable. Payments may also be made via Wise or direct-to-bank payments.

Cancellation/refund terms are shown before purchase. Sessions cancelled with less than 24 hours’ notice may be charged, except in reasonable circumstances.

Consumers generally have a 14-day withdrawal right for distance sales, unless a legal exception applies.

For services started during the withdrawal period at your explicit request, proportionate payment may apply for work already performed.

For digital content delivered immediately, withdrawal right can be lost only after explicit prior consent and acknowledgement at checkout, as required by law.

Coaching outcomes depend on participation and cannot be guaranteed.

13. Cookies and Tracking

This website does not use analytics, advertising, or marketing cookies during normal browsing.

When you actively open checkout/payment, Stripe may set strictly necessary technical cookies (or similar technologies) for secure payments, fraud prevention, and compliance.

If non-essential cookies are introduced later, this page will be updated and consent will be requested where legally required.

14. Consumer Disputes

If you have a concern, contact me first at kevin@wellbeingmastery.academy.

Finnish consumers can also contact Consumer Advisory Services: kkv.fi/en/consumer-advisory-services

Disputes may be referred to the Consumer Disputes Board: kuluttajariita.fi

15. Changes to This Page

This page may be updated when services, tools, or legal requirements change. The latest version is always published here with the updated date.