Privacy Policy
We ask for as little information as possible, explain why we need it and never sell it. This page explains what happens to the personal information you share with The Breathing Space Project.
Last updated: 28 July 2026
Who we are
The data controller is:
Emma Hunter-James, trading as The Breathing Space Project.
The Breathing Space Project is established and operated from Spain and works with families, schools and community partners internationally.
Privacy email
hello@thebreathingspaceproject.comWhich data-protection law applies
Because The Breathing Space Project is established in Spain, our principal data-protection framework is the European Union General Data Protection Regulation, known as the EU GDPR, together with applicable Spanish data-protection law.
The UK GDPR may also apply where we specifically offer services to individuals in the United Kingdom or monitor their behaviour there.
The law that applies may depend on where a person is located, the service being provided and how their personal information is used.
What information we collect
We only collect the categories below where they genuinely apply to the enquiry, programme or service concerned.
Contact enquiries
- Name
- Email address
- Role, such as parent, carer, teacher, school representative or other
- The contents of the message
- Any information chosen to be shared in later correspondence
Waiting lists and programme interest
- Parent or carer name
- Email address
- Telephone number, where requested
- The child's age or age group
- The programme or group of interest
- Notes voluntarily provided by the parent or carer
Bookings and participation
- Parent or carer contact details
- The child's name and age
- Booking and attendance information
- Emergency contact details
- Parental permissions and consent records
- Communications relating to the booking
- Information needed to administer and safely deliver the programme
Payments and financial records
- Payment status
- Transaction references
- Invoice and billing information
- Records required for accounting and tax purposes
Payment card or bank details may be processed directly by an external payment provider rather than stored by The Breathing Space Project.
Newsletter: The Explorer List
- Name
- Email address
- Subscription date
- Consent record
- Email preferences
- Unsubscribe record
Communications
- Parents and carers
- Schools
- Educators
- Community partners
- Service providers
We may retain relevant communications with the people and organisations listed above.
Website and technical information
- IP address
- Browser and device information
- Pages visited
- Referral source
- Cookie preferences
- Website security and diagnostic logs
This depends on the website tools enabled at the time.
Photographs and recordings
- Images
- Video or audio recordings
- Related parental permissions
- Information about the agreed use of the material
The Breathing Space Project does not record sessions as standard.
Safeguarding information
- Information shared by a child, parent, carer or professional
- Observations relevant to a child's safety
- The actions taken
- Information shared with safeguarding leads, child-protection services or other appropriate authorities
Safeguarding records are handled separately from ordinary enquiries and marketing information.
How the website itself gathers technical information is explained in our Cookie Policy.
Sensitive, health and support information
Please do not include medical, diagnostic, safeguarding or other sensitive information in a general website enquiry form.
Where limited health, allergy, disability, accessibility, sensory or support information is genuinely necessary to help a child participate safely and comfortably, we will arrange for it to be provided through an appropriate private channel.
We will:
- Explain why the information is needed
- Ask only for information that is relevant
- Limit who can access it
- Keep it only for as long as it is genuinely required
- Identify an appropriate lawful basis and, where required, an additional condition for processing sensitive information
Where consent is relied upon for information relating to a child, it will be obtained from the person legally able to provide it.
Why we use personal information
Responding to enquiries
Information used: To answer questions and provide information requested by a parent, carer, educator or organisation.
Lawful basis: Steps taken at the person's request before entering into a contract, and/or our legitimate interests in responding to genuine enquiries.
Administering bookings and delivering programmes
Information used: To manage registrations, bookings, attendance, communication and programme delivery.
Lawful basis: Performance of a contract, or steps taken before entering into a contract.
Keeping children safe during programmes
Information used: To manage emergency contacts, relevant participation information, safeguarding concerns and safety-related records.
Lawful basis: The applicable legal obligation, vital interests, legitimate interests or other appropriate lawful basis, together with an additional condition where sensitive information is involved.
Sending newsletters and promotional emails
Information used: To send information about stories, resources, programmes and project updates.
Lawful basis: Consent, which may be withdrawn at any time.
Payments, accounting and tax records
Information used: To process payments, issue invoices and meet legal accounting and tax responsibilities.
Lawful basis: Performance of a contract, and legal obligation.
Website administration and security
Information used: To keep the website secure, diagnose problems, prevent misuse and maintain the effective operation of the service.
Lawful basis: Our legitimate interests in protecting and administering the website, provided those interests are not overridden by the rights and interests of the people concerned.
Optional analytics and non-essential cookies
Information used: To understand how visitors use the website and improve the experience.
Lawful basis: Consent, where required.
Photographs and promotional recordings
Information used: To use agreed photographs or recordings for the specific purposes explained to the family.
Lawful basis: Consent, where relied upon. A child's wishes are also respected, even where parental permission has been given.
Legal claims, complaints and protecting the project
Information used: To respond to complaints, establish facts, protect legal rights or manage disputes.
Lawful basis: Legitimate interests, legal obligation, or the establishment, exercise or defence of legal claims, depending on the circumstances.
The exact lawful basis may depend on the circumstances. We do not use legitimate interests as a general justification for every type of processing, especially where children's information is involved.
Who we share information with
We use a limited number of trusted service providers to help us operate the website and deliver our services. Depending on the services being used, these may include:
- Website hosting providers
- Website or database platforms
- Email newsletter providers
- Booking or payment providers
- Video-meeting platforms
- Secure cloud-storage providers
- Accountancy or invoicing providers
- Professional advisers
- Schools or community partners involved in delivering a programme
- Safeguarding leads, child-protection services, police, emergency services or other appropriate authorities where necessary
These organisations may act as processors working on our instructions or, in some circumstances, as independent data controllers with their own legal responsibilities.
We do not sell, rent or trade personal information.
A list of the specific providers we rely on, and the safeguards that apply to them, is available on request by emailing hello@thebreathingspaceproject.com.
International transfers
Some service providers may process personal information outside Spain, the European Economic Area or the United Kingdom.
Where international data-transfer rules apply, we use an appropriate lawful transfer mechanism. This may include:
- An adequacy decision
- Approved contractual safeguards
- European Commission Standard Contractual Clauses
- A United Kingdom International Data Transfer Agreement or approved Addendum, where applicable
- Another transfer mechanism permitted by applicable data-protection law
The mechanism used will depend on the provider, processing location and applicable law.
Further information about the safeguards used may be requested by emailing hello@thebreathingspaceproject.com.
How long we keep information
We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, to meet legal responsibilities, protect children or handle a complaint or legal claim.
General enquiries that do not lead to a booking
Kept while we are still helping, then reviewed and deleted once the enquiry is closed and there is no further reason to keep it.
Waiting-list registrations
Until the relevant programme has been offered or the waiting list has ended, followed by a limited review period.
Booking, attendance and programme administration records
For the period needed to deliver the programme and manage related enquiries, complaints or legal responsibilities.
Emergency contact, accessibility and participation-support information
Normally deleted or securely anonymised when it is no longer needed for the child's safe participation, unless there is another lawful reason to retain it.
Newsletter records
Until the person unsubscribes. A minimal suppression record may be retained afterwards so that we can respect the request not to send further marketing.
Financial and invoice records
For the period required by applicable Spanish tax and accounting law.
Photographs and recordings
For the period explained when permission was requested, or until consent is withdrawn where withdrawal applies and no other lawful reason requires retention.
Safeguarding records
For the period required or justified by safeguarding, legal and child-protection responsibilities. Safeguarding records are not automatically deleted in response to a general deletion request where retention remains necessary to protect a child, meet a legal obligation or manage a legal claim.
Security and technical logs
For a limited period appropriate to website security, investigation and maintenance.
If you would like to know how long we are holding something you have sent us, please email hello@thebreathingspaceproject.com and we will tell you.
Children's information
The public website and its enquiry, booking and newsletter forms are intended for adults, including parents, carers, educators and partner organisations.
We do not knowingly invite children to submit personal information directly through general website forms.
Where a child takes part in a programme, their information is normally provided by a parent, carer, school or another appropriately authorised adult.
We aim to collect only the information genuinely needed to administer the programme, support the child's participation and meet our safety and safeguarding responsibilities.
Where information is provided by a school or partner organisation, that organisation may also have responsibilities as a data controller. Families should refer to the organisation's own privacy information where relevant.
Your data-protection rights
Depending on the circumstances and the law that applies, you may have the right to:
- Ask for access to your personal information
- Ask us to correct inaccurate or incomplete information
- Ask for information to be deleted
- Ask us to restrict how information is used
- Object to certain uses of information
- Receive certain information in a portable format
- Withdraw consent at any time where processing is based on consent
- Complain to an appropriate data-protection authority
These rights are not absolute and may not apply in every situation.
For example, we may need to retain information to:
- Meet a legal obligation
- Protect a child
- Maintain an appropriate safeguarding record
- Keep legally required financial records
- Establish, exercise or defend a legal claim
To make a request, email hello@thebreathingspaceproject.com. We will normally respond within one month, and we may ask for reasonable information to confirm your identity before completing a request.
Withdrawing newsletter consent
You may withdraw consent for newsletters and promotional emails at any time by:
- Using the unsubscribe link in an email
- Using the website's unsubscribe page
- Emailing hello@thebreathingspaceproject.com
Withdrawing consent does not affect processing that took place before consent was withdrawn.
A minimal suppression record may be retained so that we can respect your request not to receive future marketing.
Complaints
We would appreciate the opportunity to address any privacy concern directly.
Please contact hello@thebreathingspaceproject.com.
You also have the right to complain to the relevant data-protection authority.
Because The Breathing Space Project is established in Spain, the principal supervisory authority is the Agencia Española de Protección de Datos — AEPD.
Where the UK GDPR applies to the relevant processing, a person may also have the right to complain to the Information Commissioner's Office — ICO.
Keeping information safe
We use reasonable technical and organisational measures to help protect the information entrusted to us. Depending on the systems involved, these measures may include:
- Encrypted website connections
- Access-controlled accounts
- Strong passwords and appropriate authentication
- Limited access based on role and need
- Secure storage
- Regular software and security updates
- Separate handling of safeguarding records
- Careful selection of service providers
- Procedures for responding to suspected data breaches
No online service can guarantee perfect security, but we take appropriate care with the information entrusted to us.
Cookies and website choices
The website may use cookies or similar technologies for essential operation, security, preferences, analytics or embedded content.
Essential cookies may operate without consent where they are strictly necessary. Non-essential analytics, advertising or similar cookies will not be activated before the visitor has made the required choice.
Our cookie banner lets you:
- Accept non-essential cookies
- Reject non-essential cookies
- Review or change your cookie preferences at any time
Rejecting non-essential cookies is as clear and accessible as accepting them. Full details are in our Cookie Policy.
Automated decision-making
The Breathing Space Project does not currently use personal information to make solely automated decisions that produce legal or similarly significant effects.
If this changes, we will update this policy and provide the information required by applicable law.
Changes to this policy
We may update this Privacy Policy when our services, website systems, service providers or legal responsibilities change.
When we make changes, we will update the date at the top of this page.
Significant changes will be highlighted on this page and, where appropriate, communicated directly to affected users.
Contact us about privacy
Questions about this policy, the information we hold or the way we use personal information may be sent to:
Closing note
This page provides a public summary of how The Breathing Space Project handles personal information.
It is written in plain language for parents, carers, educators and partner organisations.
It is not legal advice, an independent certification or an external data-protection audit.