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PRIVACY POLICY

Introduction

This Life Divine is a healing arts and coaching practice founded by Rachel Bennett, based in Asheville, North Carolina. We are committed to protecting your personal information and your right to privacy. This Privacy Policy describes how we collect, use, store, protect, and disclose information gathered through our website (www.this-life-divine.com), booking and scheduling systems, and during coaching, hypnosis, and QHHT® sessions.

This Privacy Policy applies to:

  • Website visitors and users

  • Newsletter subscribers

  • Booking and inquiry submissions

  • Current and former clients receiving coaching, hypnosis, or QHHT® sessions

  • Participants in any This Life Divine offerings

If you have questions or concerns about this policy or our data practices, please contact us at the information provided in Section 11 (Contact & Requests).

 

1. Data Controller

For the purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR) and North Carolina privacy standards, the data controller is:

This Life Divine LLC
Rachel Bennett
802 Fairview Rd, Office 6, Suite 4000
Asheville, NC 28803
Email: rachel@this-life-divine.com
Phone: 828-407-0573
Website: www.this-life-divine.com

2. What Personal Data We Collect

We collect different categories of information depending on how you interact with This Life Divine.

A. Website Visitors

When you visit our website without engaging services, we may collect:

  • Browser & Device Information: Browser type and version, device type (desktop, tablet, mobile), operating system

  • Usage Data: Pages visited, time spent on each page, referring website or source, clicks and interactions

  • Location Data: Approximate geographic location at country or region level (not precise)

  • Cookies & Tracking: Information from cookies, pixels, and similar technologies (see Section 8: Cookies)

This data is collected through Google Analytics and similar web analytics tools and is aggregated and anonymized. It does not directly identify you by name.

B. Contact Form & Inquiry Submissions

When you submit a contact form or inquiry through our website, we collect:

  • Your name

  • Your email address

  • Your phone number (if provided)

  • Subject line and message content

  • Any other information you voluntarily provide

C. Newsletter & Email List Sign-Ups

When you subscribe to our newsletter or email updates, we collect:

  • Your name (if provided)

  • Your email address

  • Date of subscription

  • Any preferences you select (e.g., content topics, frequency)

D. Booking & Scheduling Requests

When you request to book a session or consultation, we collect:

  • Your full name

  • Your email address and phone number

  • Preferred dates and times

  • Session type (QHHT, coaching, hypnosis, etc.)

  • Any notes or context about your intentions, goals, or needs

  • Availability preferences

E. Session & Client Information (Sensitive)

When you are an active client receiving coaching, hypnosis, QHHT®, or other services, we collect and maintain:

  • Session Records: Detailed notes from sessions including themes, topics discussed, insights, and work completed

  • Audio Recordings: With your explicit prior consent, sessions are audio-recorded and provided to you within 24 hours as an MP3 file. Rachel maintains a backup copy on an encrypted hard drive for 7+ years (see Section 5: Session Recordings & Audio Recording Consent)

  • Health & Wellness Context: Information about your physical health, mental health history, current stressors, life circumstances, and goals shared during intake or sessions

  • Personal & Spiritual Information: Details about your spiritual practices, beliefs, values, relationship status, family context, career, finances (if relevant to your work), and life experiences

  • Intake Forms: Completed intake questionnaires, consent forms, and assessment information

  • Communication Records: Emails, messages, and notes regarding session scheduling, cancellations, payment, and session-related communication

  • Payment Information: Transaction history, billing details, and payment method information (processed securely through third-party payment processors)

Note on Sensitivity: Information collected during sessions is more sensitive than website analytics. It may include personal, psychological, spiritual, and health-related details shared in confidence. This information is treated with the highest level of privacy protection.

F. Payment & Transaction Information

When you book sessions or purchase services:

  • Payment Processor Data: Payment information (credit card, debit card, PayPal, etc.) is NOT stored on our website or in our systems. Payment processing is handled by secure third-party payment processors (such as Stripe, Square, or similar). See Section 9 (Third-Party Service Providers) for details.

  • Transaction Records: We retain records of payments made, session dates, amounts, and invoice information for billing and accounting purposes.

G. Testimonials & Client Consent

If you provide a testimonial or allow us to share your experience:

  • We collect your written or recorded testimonial, photos (if provided), and any identifying information you permit us to use

  • This is only collected with your explicit written consent

  • See Section 7 (Testimonials) for details on use and withdrawal

 

3. Legal Basis for Processing Data (GDPR)

For visitors located in the European Economic Area (EEA), Switzerland, or under similar data protection regulations, we process your personal data on the following legal grounds:

Consent: When you subscribe to our newsletter, submit a contact form, or book a session, you are providing informed consent for us to process your data for that specific purpose. You may withdraw consent at any time.

Legitimate Interests: We process analytics data to understand and improve our website and services. Our legitimate interest in improving user experience does not override your privacy rights. Visitors can opt out of analytics tracking (see Section 8: Cookies).

Contract Performance: When you book a session or purchase services, processing your information is necessary to:

  • Confirm and schedule your session

  • Process payment

  • Communicate with you about the service

  • Provide the service you have requested

Legal Obligation: We may process personal data when required by law, such as to respond to lawful requests from law enforcement or courts.

Vital Interests: We may process data to protect the safety and wellbeing of individuals in cases of imminent harm or emergency.

 

4. How We Use Your Data

We use the information we collect for the following purposes:

Website & Administrative

  • To respond to your contact form inquiries and questions

  • To process booking requests and confirm session scheduling

  • To send newsletters, updates, and offerings you have subscribed to

  • To send transactional emails (booking confirmations, payment receipts, session reminders, policy updates)

  • To improve the content, design, and usability of our website

  • To understand how visitors interact with our website through analytics

  • To address technical issues or troubleshoot website problems

Client Services & Sessions

  • To provide you with coaching, hypnosis, QHHT®, or other services you have booked

  • To prepare for your session and tailor the experience to your goals

  • To maintain continuity of care across multiple sessions

  • To follow up after sessions and check in on your wellbeing

  • To track your progress and insights over time (with your awareness and consent)

  • To ensure your safety and the appropriate application of techniques

  • To comply with professional standards and ethical obligations

  • To maintain records for legal and liability protection

Communication & Administrative

  • To contact you about session scheduling, changes, or cancellations

  • To send payment reminders or receipts

  • To notify you of important updates to policies or service offerings

  • To respond to requests or complaints

Marketing & Testimonials (with Consent)

  • To feature your testimonial or experience in promotional materials (only with explicit written permission)

  • To send you relevant information about new services or offerings

5. Session Recordings & Audio Recording Consent

Recording Practice

This Life Divine audio-records all QHHT, coaching, and hypnosis sessions for your benefit. Recordings allow you to revisit your session, integrate insights, and access guidance at your own pace after the session concludes.

Recording Consent

Sessions will NOT be recorded without your explicit prior consent. Before each session, you will be asked to consent to audio recording during your intake interview or pre-session process.

Consent Checkpoint: You will check a box on your intake form or in your session agreement confirming:

  • You consent to the session being audio-recorded

  • You understand the recording will be provided to you via email

  • You acknowledge the recording is yours to keep, use, and share as you wish

No consent = No recording. If you do not consent to recording, Rachel will not record your session.

Recording Storage & Delivery

  • Delivery Timeframe: Your recording will be provided to you within 24 hours of your session via email as an MP3 file

  • What You Receive: You receive a complete copy of your session recording

  • Your Ownership: The recording is yours. You may listen to it, share it with trusted people, or use it however you wish

  • Rachel's Copy: Rachel maintains a backup copy on an encrypted external hard drive for record-keeping and compliance purposes

How Long Recordings Are Kept

  • Client Copy: You have permanent ownership of your recording

  • Rachel's Backup Copy: Retained for a minimum of 7 years (standard professional record retention) and then securely deleted

  • Secure Deletion: When deleted, recordings are permanently removed and cannot be recovered

Use of Your Recording by This Life Divine

Rachel will NOT use your recording for any purpose beyond providing it to you without your separate written consent.

This means Rachel will not:

  • Share your recording with others (except as legally required)

  • Use it in testimonials, case studies, or marketing materials

  • Use it in training or educational content for other practitioners

  • Feature it on social media or any public platform

  • Use it for any purpose beyond your personal reference

If Rachel wants to use your recording: Rachel will ask for your permission separately, providing a Recording Release Form for you to sign. You can agree or decline—declining will have no impact on your coaching relationship or future sessions.

Session Recording Limitations

  • Confidentiality: Your recording is confidential and protected under the same privacy and confidentiality terms as your session

  • No Third-Party Sharing: Rachel will not share, license, or sell your recording to any third party

  • Legal Exceptions: Recordings may be disclosed only if required by law (court order, subpoena, mandatory reporting of harm)

  • Security: Recordings are stored securely and protected from unauthorized access

Withdrawal of Recording Consent

If you consented to recording but later want to revoke that consent:

  • Email Rachel at rachel@this-life-divine.com with your request

  • Rachel will delete her backup copy and confirm deletion to you

  • Your personal copy remains yours to keep or delete as you choose

  • Future sessions can proceed without recording if you prefer

Recording Technical Details

  • Format: MP3 audio file

  • Quality: Standard audio quality suitable for personal listening

  • Delivery Method: Email attachment or link (you choose preference)

  • Accessibility: Compatible with all standard audio players and devices

  • To invite you to events or special offerings (only if you have opted in)

Legal & Compliance

  • To comply with applicable laws and regulations

  • To protect our rights, privacy, safety, or property

  • To respond to lawful requests from government agencies or law enforcement

  • To establish, exercise, or defend legal claims

6. Data Retention & Deletion

We retain personal data only as long as necessary to fulfill the purposes for which it was collected.

Website & Analytics Data

  • Duration: Typically retained for 12–24 months

  • Exception: Aggregated, anonymized analytics data may be retained longer as it does not identify individuals

Contact Form & Inquiry Submissions

  • Duration: Retained for 1–2 years for reference and follow-up purposes

  • Deletion: You may request deletion at any time

Newsletter Subscribers

  • Duration: Retained while you are subscribed

  • Deletion: Automatically deleted upon unsubscribe; manual deletion upon request

Session & Client Records

  • Duration: Retained for a minimum of 7 years following the final session (or as required by professional standards and legal obligations)

  • Rationale: This period allows for adequate follow-up care, legal protection, and professional documentation

  • Audio Recordings: Your recording is yours to keep forever. Rachel's backup copy is retained for a minimum of 7 years on an encrypted external hard drive, then securely deleted

  • Secure Destruction: After the retention period expires, records and backup recordings are securely destroyed unless legal obligations require longer retention

  • Early Deletion: You may request deletion of your records and Rachel's backup recording at any time by emailing rachel@this-life-divine.com (subject to legal and professional obligations)

Payment Records

  • Duration: Retained for 7 years for tax, accounting, and legal purposes

  • Method: Secure storage separate from session records when possible

Testimonials & Consent-Based Material

  • Duration: Retained as long as you consent to their use

  • Withdrawal: You may request removal at any time

7. Confidentiality & Legal Limits

Your privacy is our highest priority. All information shared in sessions is held in strict confidence and will not be disclosed to third parties without your explicit written consent, except in the limited circumstances described below.

Legal Exceptions to Confidentiality

Rachel may disclose information without your consent if required or permitted by law in the following situations:

Imminent Danger or Harm:

  • If you disclose a specific, imminent plan or intent to harm yourself or another person

  • If Rachel believes you pose an immediate risk to your own safety or the safety of others

  • In this case, Rachel may contact emergency services, mental health professionals, or appropriate authorities

Abuse, Neglect, or Exploitation:

  • If you disclose abuse, neglect, or exploitation of a child or vulnerable adult

  • North Carolina law requires Rachel to report suspected child abuse or neglect to the appropriate authorities

  • In such cases, Rachel will comply with legal obligations

Criminal Activity:

  • If information suggests you are planning or committing a crime that poses imminent danger to yourself or others

  • Rachel may disclose information to law enforcement as required by law

Court Order or Legal Process:

  • If a valid court order, subpoena, or legal process requires disclosure of your records

  • Rachel will comply with the legal order and will attempt to notify you of the disclosure when legally permitted

Payment & Business Purposes:

  • If you authorize disclosure to payment processors, billing services, or accountants for transaction processing

  • Rachel may share minimal information (name, email, transaction details) with payment processors and business service providers

Your Rights Regarding Disclosures

  • Rachel will inform you when legally permitted to do so

  • You have the right to be informed of any disclosure made without your consent (except in urgent safety situations)

  • If you have concerns about a disclosure, contact Rachel immediately

8. Testimonials & Client Consent

Testimonials are powerful tools for sharing experiences, and we value client feedback. However, we only use testimonials with explicit written consent.

How Testimonials Are Used

With your permission, we may:

  • Feature your testimonial on our website, blog, or social media

  • Include your testimonial in marketing materials, email newsletters, or promotional content

  • Share your experience in talks, presentations, or educational content (without specific identifying information if you prefer)

  • Use your photo or name alongside your testimonial (if you consent)

Your Control

  • Consent is explicit and in writing — You will be asked to sign or digitally confirm before your testimonial is used

  • Consent is specific — You choose exactly which platforms or materials your testimonial will appear in

  • Withdrawal is simple — You can request removal of your testimonial at any time by contacting Rachel

  • No payment required — We do not require testimonials and do not compensate for them

  • Anonymity available — You may provide a testimonial anonymously or have your name withheld

Important Note

Testimonials reflect individual experiences and are not guarantees of specific outcomes. Results vary based on individual effort, circumstances, and background.

9. Cookies & Tracking Technologies

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help us remember your preferences, track how you use our website, and improve your experience.

Cookies We Use

Necessary Cookies:

  • Required for basic website functionality (e.g., shopping cart, login, form submission)

  • Cannot be disabled; essential for website operation

  • No data is shared with third parties

Analytics Cookies:

  • Used by Google Analytics to understand how visitors interact with our website

  • Track pages visited, time spent, referral sources, and general location data

  • Data is aggregated and anonymized

  • Does not directly identify individuals

Functional Cookies:

  • Enhance user experience (e.g., remembering preferences, language selection)

  • Optional but improve website usability

Marketing/Advertising Cookies:

  • Used to track how you interact with ads or promotional content

  • May be set by third-party services (e.g., Facebook, Google Ads)

  • Only if you have engaged with our marketing

Your Cookie Choices

Opt Out of Analytics:

  • You can disable Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-on

  • Opt-out by adjusting your browser privacy settings

  • Note: Disabling analytics does not affect basic website functionality

Browser Controls:

  • Most browsers allow you to disable cookies entirely or select which cookies to accept

  • Disabling cookies may limit website functionality

  • See your browser's privacy settings for details

Do Not Track Requests:

  • If your browser sends a "Do Not Track" signal, we will respect it for analytics tracking

  • Essential cookies cannot be disabled as they are required for website operation

10. Third-Party Service Providers

We use third-party services to help operate our website and provide services. These providers may access your data only as necessary to perform their functions and are contractually obligated to keep your information confidential and secure.

Payment Processing

Payment Processors: Stripe, Square, PayPal, or similar
Data Shared: Card number (encrypted), billing address, email, transaction amount
Purpose: Process payments for services
Privacy Policy: See the payment processor's own privacy policy

Note: Credit card and payment information is never stored on our servers. Payment processing is handled entirely by secure third-party processors.

Email & Communication Services

Email Service Provider: Mailchimp, ConvertKit, or similar
Data Shared: Name, email address, subscription preferences
Purpose: Send newsletters, updates, and transactional emails
Unsubscribe: You can unsubscribe from email lists at any time using the link in the email footer
Privacy Policy: See the email provider's own privacy policy

Booking & Scheduling

Scheduling Platform: Calendly, Acuity Scheduling, or similar
Data Shared: Name, email, phone, preferred dates/times, session notes
Purpose: Manage session bookings and scheduling
Privacy Policy: See the scheduling platform's own privacy policy

Website Hosting & Analytics

Website Host: Wix or similar
Analytics: Google Analytics
Data Shared: Browser type, device type, pages visited, time on site, location (country/region)
Purpose: Host website, track usage, improve user experience
Privacy Policy: See Wix's and Google's privacy policies

Customer Relationship Management (if applicable)

CRM Platform: Dubsado, HubSpot, or similar
Data Shared: Contact information, client notes, communication history
Purpose: Manage client relationships and communication
Privacy Policy: See the CRM provider's own privacy policy

Social Media Platforms

If we link to or use social media platforms (Facebook, Instagram, Twitter, etc.):

  • Social media platforms may track your activity and collect data

  • This Life Divine is not responsible for their data practices

  • See each platform's privacy policy

11. Your Privacy Rights & Data Subject Requests

You have rights regarding your personal data. Depending on your location and applicable laws, you may have the following rights:

Right to Access

You have the right to request a copy of the personal data we hold about you. To exercise this right:

  • Contact Rachel with a written request

  • We will provide your data in a readable format within 30 days

  • No fee required for access requests

Right to Correct or Update

You have the right to request correction of inaccurate or incomplete data. To exercise this right:

  • Contact Rachel with details of the inaccuracy

  • We will update your records and confirm the change

Right to Delete ("Right to Be Forgotten")

You have the right to request deletion of your personal data, subject to certain exceptions. To exercise this right:

  • Contact Rachel with a deletion request

  • We will delete your data unless:

    • Legal obligations require us to retain it (e.g., tax records)

    • Professional standards require retention (e.g., session records for 7 years)

    • The data is necessary for legal or safety reasons

  • We will explain any reasons for non-deletion

  • Timeline: 30 days from request

Right to Data Portability

You have the right to request your data in a portable, machine-readable format (GDPR, applicable jurisdictions). To exercise this right:

  • Contact Rachel with a portability request

  • We will provide your data in a standard format (e.g., CSV, PDF)

  • Timeline: 30 days from request

Right to Object or Opt Out

You have the right to object to certain types of data processing, including:

  • Marketing Communications: Opt out of newsletters and promotional emails by clicking the unsubscribe link or contacting Rachel

  • Analytics Tracking: Disable Google Analytics through browser settings or the opt-out add-on

  • Cookies: Adjust cookie preferences through browser settings

Right to Restrict Processing

You have the right to request that we limit how we use your data in certain circumstances. Contact Rachel to discuss restrictions.

Right to Withdraw Consent

If you consented to our processing of your data, you may withdraw that consent at any time by contacting us. We will stop processing your data for that purpose, though any processing before withdrawal remains valid.

How to Submit Requests

To exercise any of these rights, contact Rachel:

Email: rachel@this-life-divine.com
Mail: This Life Divine, 802 Fairview Rd, Office 6, Suite 4000, Asheville, NC 28803
Phone: 828-407-0573

Include in your request:

  • Your full name

  • Email address

  • Specific request (access, correction, deletion, portability, opt-out, etc.)

  • Any relevant dates or details

Response Timeline: We will respond to your request within 30 days. If your request is complex, we may request additional time.

12. Data Security

We take data security seriously and employ reasonable measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

Security Measures

  • Encrypted Transmission: Sensitive data transmitted over the internet is encrypted using SSL/TLS technology (indicated by "https://" in the URL)

  • Secure Storage: Client records are stored in secure, password-protected systems

  • Access Controls: Only authorized personnel have access to personal data

  • Backups: Regular backups are maintained to prevent data loss

  • Physical Security: Paper records (if any) are stored in locked, secure locations

Limitations

No security system is 100% secure. While we implement industry-standard protections, we cannot guarantee absolute security against all threats (hacking, viruses, breaches, etc.). By using our services, you acknowledge this inherent risk.

Data Breach Notification

If a data breach occurs that compromises your personal information:

  • We will notify affected individuals promptly (within legally required timeframes)

  • We will provide details about the breach, affected data, and steps to protect yourself

  • We will comply with all legal notification requirements

13. Children's Privacy

This Life Divine's website and services are not directed to children under the age of 16. We do not knowingly collect personal information from children under 16.

If we become aware that we have collected data from a child under 16 without parental consent:

  • We will delete that information promptly

  • We will contact the parent or guardian

For services with minors, we require parental or guardian consent and may collect the parent/guardian's contact information as an emergency contact or responsible party.

14. International Data Transfers

If you are located outside the United States and we transfer your data internationally:

  • We comply with applicable data protection laws regarding cross-border transfers

  • For EU/EEA residents, we ensure adequate safeguards (e.g., Standard Contractual Clauses)

  • By using our services, you consent to data transfer where necessary

15. Updates to This Privacy Policy

This Privacy Policy may be updated periodically as our practices evolve or legal requirements change.

Material Changes: If we make substantial changes that affect your privacy, we will:

  • Post the updated policy on this page with a new "Last Updated" date

  • Send email notification to active clients (when feasible)

  • Request your consent if required by law

Your Continued Use: Your continued use of our website or services after policy updates indicates your acceptance of the revised policy.

Archive of Past Policies: We may maintain previous versions of this policy for reference. If you need to review an earlier version, contact Rachel.

16. Contact & Privacy Requests

For questions, concerns, or to submit a data privacy request:

Email: rachel@this-life-divine.com
Phone: 828-407-0573
Mail: This Life Divine
802 Fairview Rd, Office 6, Suite 4000
Asheville, NC 28803

Response Time: We will respond to privacy inquiries within 5–10 business days.

17. Jurisdiction & Complaints

Governing Law

This Privacy Policy is governed by the laws of North Carolina, United States.

Privacy Complaints

If you believe your privacy rights have been violated:

  1. Contact Rachel directly to discuss your concern

  2. We will investigate and respond within 30 days

  3. If unresolved, you may file a complaint with:

    • In North Carolina: Your state privacy authority

    • In the EU/EEA: Your local Data Protection Authority

    • In other jurisdictions: Applicable regulatory body for data protection

18. GDPR-Specific Information (EU/EEA Residents)

If you are located in the European Economic Area or United Kingdom, additional rights apply under the General Data Protection Regulation (GDPR):

Rights Summary:

  • Access, rectification, erasure, portability, and objection rights (see Section 10)

  • Right to lodge a complaint with your local Data Protection Authority

  • Right to withdraw consent at any time

  • Right to restrict or object to processing

Data Protection Authority Contact:

Standard Contractual Clauses: For international data transfers, we use Standard Contractual Clauses approved by the EU Commission to ensure adequate safeguards.

19. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

  • Right to Know: Request information about personal data collected about you

  • Right to Delete: Request deletion of personal data

  • Right to Opt-Out: Opt out of the sale or sharing of personal data

  • Right to Correct: Request correction of inaccurate data

  • Right to Limit: Limit use of sensitive personal information

To exercise CCPA/CPRA rights, contact Rachel using the information in Section 15. Requests will be handled within 45 days.

Acknowledgment

By using This Life Divine's website or services, you acknowledge that you have read and understood this Privacy Policy and agree to the data practices described herein.

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