Privacy Notice

How Dragonfly Mind & Body collects, uses and protects your personal information

Status: Current
Last updated: 7 October 2026

Data controller: Beate Rotheneder, trading as Dragonfly Mind & Body
Privacy contact: info@dragonflymindbody.com

1. Who we are

Dragonfly Mind & Body Ltd is a health and wellbeing coaching practice operated by Beate Rotheneder, trading as Dragonfly Mind & Body.

Beate Rotheneder is the data controller responsible for the personal information described in this Privacy Notice.

Contact details

Beate Rotheneder
Dragonfly Mind & Body
Suite RA01, 195-197 Wood Street, London, E17 3NU
Email: info@dragonflymindbody.com

Dragonfly Mind & Body provides non-clinical health and wellbeing coaching, education and behaviour-change support. Health coaching complements, but does not replace, medical care or other regulated healthcare services.

2. Information we may collect

The information we collect depends on how you interact with Dragonfly Mind & Body and which services you use.

It may include:

  • your name and contact details;

  • age or date of birth where relevant to the service;

  • occupation, working patterns and relevant lifestyle information;

  • information you provide when making an enquiry or booking a service;

  • appointment and service information;

  • payment and transaction information;

  • questionnaire, food diary, lifestyle diary or check-in responses;

  • information about your goals, habits and circumstances;

  • notes and records created as part of providing health coaching;

  • communications between you and Dragonfly Mind & Body;

  • information you choose to provide through our website, forms or booking systems; and

  • technical or usage information relating to your use of our website, where applicable.

We aim to collect only information that is relevant and reasonably necessary for the purpose for which it is collected.

Health information

If you use our health-coaching services, you may choose to provide information about your physical or mental health.

Depending on the service, this might include information about:

  • health conditions or symptoms;

  • medication and supplements;

  • allergies or intolerances;

  • relevant family health history;

  • nutrition and eating habits;

  • physical activity and movement;

  • sleep;

  • stress and wellbeing;

  • relevant health measurements, test results or investigations that you choose to share; and

  • other health or lifestyle information relevant to your coaching goals.

Health information is special-category personal data under UK data-protection law and receives additional protection.

Dragonfly Mind & Body is a non-clinical health-coaching service. We do not collect health information for the purpose of diagnosing or treating medical conditions. We aim to collect only the health information reasonably necessary to understand your circumstances, support your goals, provide appropriate coaching and recognise when referral to an appropriately qualified healthcare professional may be advisable.

Please do not provide medical or other sensitive information that is not relevant to your coaching.

3. Why we use your information

We may use your personal information to:

  • respond to enquiries;

  • arrange discovery calls and appointments;

  • provide health and wellbeing coaching services;

  • understand your circumstances, goals and relevant health and lifestyle information;

  • prepare for and conduct coaching sessions;

  • provide appropriate health education, behaviour-change coaching and practical support;

  • communicate with you about your service;

  • manage bookings and payments;

  • maintain appropriate client and coaching records;

  • provide continuity of support;

  • identify circumstances where it may be appropriate to recommend that you seek support from a GP or another appropriately qualified professional;

  • manage our relationship with you;

  • meet applicable legal, accounting, insurance and record-keeping obligations;

  • establish, exercise or defend legal claims where necessary;

  • maintain and improve the administration and security of Dragonfly Mind & Body; and

  • send marketing communications where we have an appropriate lawful basis to do so.

We do not use your health information for marketing.

4. Our lawful bases for using personal information

UK data-protection law requires us to have a lawful basis for processing personal information.

Depending on the circumstances, Dragonfly Mind & Body may rely on:

Contract — where processing your information is necessary to take steps at your request before entering into a contract or to provide a service you have requested or purchased.

Legal obligation — where we need to process or retain information in order to comply with a legal requirement.

Legitimate interests — where Dragonfly Mind & Body has a legitimate business reason for processing information and your interests, rights and freedoms do not override that interest. This may include appropriate business administration, security, record management and the establishment or defence of legal claims.

Consent — where we ask you to make a genuine choice about a particular use of your information, such as certain forms of marketing.

Different lawful bases may apply to different processing activities.

5. Health and other special-category information

Health information is special-category personal data and requires an additional condition under Article 9 of the UK GDPR as well as an Article 6 lawful basis.

Where Dragonfly Mind & Body needs to process health information in order to provide a health-coaching service you have chosen, we will normally ask for your explicit consent to process that health information for the specified purpose.

This consent is separate from your agreement to receive coaching services.

You may withdraw your explicit consent at any time by contacting info@dragonflymindbody.com. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Because relevant health information may be necessary to provide health coaching safely and appropriately, withdrawing consent may mean that we are unable to continue some or all of the service.

We will not assume consent merely because you have booked a service or supplied information to us.

6. Health-coaching confidentiality and professional boundaries

Information you provide during individual health coaching is treated confidentially and is accessed only where reasonably necessary for the operation or delivery of the service.

Dragonfly Mind & Body provides health coaching rather than medical diagnosis or treatment. Where information you provide indicates that an issue may require assessment or treatment outside the scope of health coaching, we may recommend that you consult an appropriate professional such as your GP, a registered dietitian, pharmacist or another suitably qualified healthcare professional.

We will not ordinarily contact a healthcare professional about you or disclose your information to them without your knowledge and an appropriate lawful basis.

There may be exceptional circumstances in which information needs to be disclosed without your consent, for example where disclosure is required by law or where another lawful basis permits or requires disclosure in connection with a serious safeguarding concern. Any disclosure would be limited to information reasonably necessary in the circumstances.

7. Organisations we use to operate our services

Dragonfly Mind & Body may use third-party service providers to operate the business and deliver its services.

These may include providers used for:

  • business email and communications;

  • secure document and record storage;

  • website hosting;

  • website forms;

  • booking and appointment management;

  • video consultations;

  • payment processing;

  • accounting and administration;

  • email newsletters or marketing communications; and

  • other essential business systems.

Where another organisation processes personal information on our behalf, we take reasonable steps to use appropriate providers and data-protection arrangements.

Some providers may also act as independent data controllers for particular activities, in which case their own privacy information will apply.

We do not sell your personal information.

We do not permit service providers acting on our behalf to use client health information for their own marketing purposes.

8. Payments

Payments may be processed by third-party payment providers.

Where payment-card information is entered directly into a payment provider's system, Dragonfly Mind & Body does not need to receive or store your full payment-card details.

The payment provider processes information in accordance with its own privacy, security and regulatory arrangements.

9. Marketing

If you choose to receive marketing communications from Dragonfly Mind & Body, we may use your contact details to send relevant news, information, events and service updates.

Where consent is required or relied upon, you can withdraw that consent at any time by using the unsubscribe option provided or by contacting info@dragonflymindbody.com.

Where permitted by law, we may use another lawful basis for particular marketing activities, subject to the requirements of UK data-protection law and the Privacy and Electronic Communications Regulations.

Choosing not to receive marketing does not affect your ability to use Dragonfly Mind & Body's coaching services.

We do not add you to a marketing list simply because you complete a health questionnaire or provide health information.

We do not use health information to target marketing communications.

10. Corporate wellbeing services

Dragonfly Mind & Body may provide health-coaching or wellbeing services commissioned by an employer or another organisation.

Where this occurs, we will explain how relevant personal information is handled and, where appropriate, whether Dragonfly Mind & Body, the commissioning organisation or both organisations have data-protection responsibilities.

Information that an individual provides privately during health coaching will not routinely be disclosed to their employer or commissioning organisation in an identifiable form.

Where feedback or reporting is provided to an employer or commissioning organisation, Dragonfly Mind & Body will use aggregated or anonymised information wherever reasonably appropriate, for example participation levels or general themes.

We will not provide an employer with an individual's identifiable health or coaching information merely because the employer has paid for the service.

Any disclosure of identifiable information must have an appropriate lawful basis and be consistent with the privacy information provided to the individual, subject to any exceptional legal or safeguarding circumstances.

11. How we protect your information

We take appropriate and proportionate technical and organisational measures to protect personal information against unauthorised access, accidental loss, misuse, alteration or disclosure.

Depending on the systems and information involved, these measures may include:

  • restricting access to information according to need;

  • password protection, authentication and appropriate access controls;

  • using reputable business systems and service providers;

  • keeping health and coaching information separate from marketing activities where appropriate;

  • minimising the personal and health information we collect;

  • avoiding unnecessary duplication of sensitive information;

  • maintaining appropriate backups and security measures; and

  • securely deleting or anonymising information when it is no longer required.

No method of electronic transmission or storage can be guaranteed to be completely secure. We therefore use safeguards proportionate to the nature and sensitivity of the information concerned.

12. International transfers

Some technology providers used by Dragonfly Mind & Body may process or store personal information outside the United Kingdom.

Where this involves a restricted transfer under UK data-protection law, we will take reasonable steps to ensure that an appropriate transfer mechanism applies.

Depending on the circumstances, this may include UK adequacy regulations or appropriate safeguards recognised under UK data-protection law.

Information about relevant safeguards can be requested by contacting info@dragonflymindbody.com.

13. How long we keep information

Dragonfly Mind & Body keeps personal information only for as long as reasonably necessary for the purposes for which it was collected, including applicable legal, accounting, insurance, safeguarding and dispute-resolution requirements.

Different categories of information may therefore have different retention periods.

Client health and coaching records are normally retained for 7 years following the end of the coaching relationship, unless there is a justified reason to retain particular information for longer or a legal requirement requires otherwise.

Financial and transaction records may be retained for the period required by applicable tax and accounting requirements.

Marketing information is retained until you unsubscribe or we determine that it is no longer appropriate to retain it, subject to keeping limited information where necessary to respect an opt-out.

When personal information is no longer required, it will be securely deleted or anonymised where appropriate.

14. Information received from other sources

Most information used by Dragonfly Mind & Body will normally be obtained directly from you.

In some circumstances we may receive information from another source, for example:

  • an employer or organisation arranging a corporate wellbeing service;

  • a booking or payment provider;

  • a person making an enquiry or referral with your knowledge; or

  • another source where you have authorised the disclosure or where there is another lawful basis for it.

Where required by data-protection law, we will provide appropriate privacy information about data obtained from another source.

15. Your data-protection rights

Depending on the circumstances and the lawful basis being used, you may have rights including:

  • the right to be informed about how your information is used;

  • the right to request access to your personal information;

  • the right to ask us to correct inaccurate or incomplete information;

  • the right to request erasure of your information in certain circumstances;

  • the right to request restriction of processing in certain circumstances;

  • the right to object to certain processing;

  • the right to data portability in certain circumstances; and

  • the right to withdraw consent where processing is based on consent.

Not every right applies in every situation.

Where you have the right to object to processing based on our legitimate interests, you can contact us using the details below. You also have the right to object to the use of your personal information for direct marketing.

To exercise a data-protection right or ask a question about your personal information, contact:

Beate Rotheneder
Dragonfly Mind & Body
info@dragonflymindbody.com

We may need to verify your identity before fulfilling certain requests.

16. Automated decision-making

Dragonfly Mind & Body does not currently use solely automated decision-making that produces legal or similarly significant effects on clients.

If this changes, we will update this Privacy Notice and provide the information required by data-protection law.

17. Website cookies and similar technologies

Our website may use cookies or similar technologies.

Where these technologies are strictly necessary for the operation, security or functionality of a service you request, consent may not be required.

Where consent is required for other cookies or similar technologies, you will be given appropriate information and a means of making your choice before they are used.

Further details about the technologies used on our website, their purposes and their duration will be provided through our cookie information or cookie settings where applicable.

18. Complaints

If you have concerns about how Dragonfly Mind & Body has handled your personal information, please contact us first so that we have an opportunity to investigate and respond.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data-protection regulator.

Information about your rights and how to make a complaint is available at ico.org.uk.

19. Changes to this Privacy Notice

We may update this Privacy Notice when our services, systems, service providers, legal obligations or data-processing arrangements change.

The current version will be published on the Dragonfly Mind & Body website together with its latest revision date.

Dragonfly Mind & Body
Health & Wellbeing Coaching · UK