01Who controls your data
The data controller is Živilė Kazlauskaitė, gestalt psychotherapist, operating under an individual-activity certificate.
- Name
- Živilė Kazlauskaitė
- Form
- Individual activity (Lithuania)
- Activity code
- [CLIENT TO FILL]
- Address
- Paribio g., Vilnius / Gedimino g., Kaunas
- [email protected]
- Associations
- EAGT (certified), LGTA member
02What data I collect
Different contexts, different data. Here's the full list:
When you browse the site
Anonymous analytics via OpenPanel (self-hosted, GDPR-compliant): pages viewed, browser type, country code (not IP). No cookies, no cross-site tracking.
When you book a conversation
Via Google Calendar Appointment Schedules: name, email, phone (if you provide it), chosen time, intake answers (context — what brings you here).
When we work together
Session notes (kept separately from contact details), billing information, date history. Sessions are not recorded.
When you write to me
Email content, your address, your name (if you sign). Hosted in Gmail (Google Workspace, EU region).
03Why and on what basis
- Contract
- Booking, billing, therapeutic services (GDPR Art. 6(1)(b)).
- Consent
- Newsletter, marketing emails, if you agree (GDPR Art. 6(1)(a)).
- Legal obligation
- Bookkeeping, taxes (Lithuanian Tax Administration Law).
- Legitimate interest
- Anonymous analytics to improve the site (GDPR Art. 6(1)(f)).
- Health data
- Session notes — explicit consent at the first session (GDPR Art. 9(2)(a)+(h)).
04Who I share data with
Only those who must process it. Specifically:
- Google Workspace — email, calendar. EU data region. DPA.
- OpenPanel — analytics, self-hosted in Lithuania. Data does not leave the EU.
- Cloudflare — site hosting + CDN. EU data region.
- Bookkeeping ([CLIENT TO FILL]) — invoices with tax ID only, never session content.
Never shared with advertisers, insurance, employers, family members or other third parties without your explicit consent or a court order.
05How long I keep it
- Booking data
- 1 year after last contact, then deleted
- Session notes
- 5 years after last session (LGTA ethics requirement)
- Invoices
- 10 years (Lithuanian Accounting Law)
- 2 years if inactive
- Analytics
- Anonymously, indefinitely (cannot be linked to you)
06Your rights
Under GDPR you can — by writing to [email protected]:
- Access your data — I respond within 30 days
- Rectify inaccurate data
- Erasure("right to be forgotten") — except session notes I'm required to keep under the ethics code
- Restrict processing
- Data portability
- Object to processing based on legitimate interest
- Withdraw consent at any time (no effect on prior processing)
- Complain to the State Data Protection Inspectorate (vdai.lrv.lt)
07Security
Session notes — encrypted, kept separately from contact details, paper notes locked away. Digital notes — on an encrypted disk volume. Email — Google Workspace with 2FA. In a security incident I notify within 72 hours under GDPR Art. 33.
08Changes to this policy
The policy may need updating. Material changes will be posted on this page with a new date. If the way I use already-collected data changes, I'll ask for consent separately.
See also the cookie policy — separate page, with a list of cookies set when.
This document will be reviewed by a qualified Lithuanian data-protection officer before publication. Until then some fields are marked [CLIENT TO FILL] — they must be replaced with verified information before launch. See service agreement and privacy policy for the full context.