Effective Date: February 20, 2026
This Privacy Policy explains how EVARA GROUP LTD (“Company”, “we”, “us”, “our”), trading as Frances Auralia Delacroix, collects, uses, and protects your personal information when you visit this website or engage with our services.
By using this website or purchasing our services, you acknowledge the practices described in this Policy.
1. Company Details
EVARA GROUP LTD acts as the data controller for the personal data described in this Policy.
EVARA GROUP LTD
Registered in England and Wales
Trading as Frances Auralia Delacroix
128 City Road
London
EC1V 2NX
Email: cfo@auraliadelacroix.com
2. Information We Collect
We may collect and process the following categories of personal data:
• Name
• Email address
• Payment information (processed securely via Stripe)
• Booking and scheduling information (via Calendly)
• Communication content
• Technical data (IP address, browser type, device information)
• Website usage data (analytics and cookies)
• Session recordings, where mutually agreed
• Special category data, including information relating to your mental or emotional wellbeing, where voluntarily disclosed during eligibility assessment or sessions.
We collect only data necessary for legitimate business purposes.
3. How We Collect Data
Personal data may be collected when you:
• Submit forms on this website
• Book appointments via Calendly
• Make payments via Stripe
• Subscribe to emails or newsletters
• Contact us directly
• Interact with cookies or analytics tools
4. How We Use Your Information
We use personal data for legitimate business activities, including:
• Delivering consultancy services
• Scheduling and managing sessions
• Processing payments
• Communicating with you
• Providing customer support
• Improving website performance
• Legal and regulatory compliance
• Referencing anonymised, non-identifiable themes or case examples for educational or marketing purposes
You can opt out of marketing communications at any time by using the unsubscribe link in any email or by contacting us directly.
5. Legal Basis for Processing
Where applicable, we process personal data under:
• Contractual necessity
• Legitimate interests
• Legal obligations
• Consent (where required)
• Explicit consent, specifically for special category data such as information relating to your mental or emotional wellbeing, in accordance with Article 9 UK GDPR.
UK Clients: We process personal data in accordance with UK GDPR and the Data Protection Act 2018.
International Clients: Where you are located outside the UK, we process your personal data in accordance with UK GDPR and, where applicable, the equivalent data protection laws of your country of residence, including the EU GDPR for clients based in the European Economic Area.
6. Payment Processing
Payments are handled securely by Stripe.
We do not store or have access to full payment card details.
Stripe processes personal data in accordance with its own privacy and security policies.
7. Scheduling & Booking
Appointments are managed through Calendly.
Calendly may collect personal data required for scheduling and operates under its own privacy framework.
8. Data Sharing & Disclosure
We do not sell, rent, or trade personal data.
We may share personal information with trusted third parties where necessary for business operations, including:
• Stripe – payment processing and fraud prevention
• Calendly – appointment scheduling
• Brevo - email service providers – communications
• Google & Siteground - Analytics providers – website performance
• Professional advisers – legal, tax, accounting
• Authorities / regulators – where legally required
All third parties are expected to implement appropriate data protection safeguards.
9. How Information Is Disclosed
Personal data is disclosed securely via:
• Encrypted payment gateways
• Secure scheduling platforms
• Encrypted communication systems
• Secure analytics and hosting services
We require service providers to process data in a secure and lawful manner.
10. International Data Transfers
Where personal data is transferred outside the UK, we ensure appropriate safeguards are applied, including:
• Adequacy regulations
• Standard Contractual Clauses (SCCs)
• Equivalent lawful transfer mechanisms
11. Data Retention
We retain personal data only for as long as necessary to:
• Provide contracted services
• Comply with legal, tax, or accounting obligations
• Resolve disputes
• Enforce agreements
Retention periods vary depending on the nature of the data and legal requirements.
Financial records are retained for a minimum of 6 years in accordance with HMRC requirements.
12. Data Security
We implement appropriate technical and organisational security measures, including:
• SSL / HTTPS encryption
• Secure payment processing via Stripe
• Access controls and authentication measures
• Data minimisation principles
• Use of reputable third-party providers
• In the event of a data breach likely to affect your rights and freedoms, we will notify the ICO within 72 hours where required, and inform affected individuals without undue delay where there is a high risk to their rights.
Despite these safeguards, no method of electronic transmission or storage is entirely secure.
13. Your Rights
Under applicable data protection laws, you may have the right to:
• Access your personal data
• Request correction
• Request erasure
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent in writing (where applicable)
Requests may be submitted to:
cfo@auraliadelacroix.com
UK Clients: You have the right to lodge a complaint with the Information Commissioner's Office (ICO).
International Clients: You may also have the right to lodge a complaint with the data protection supervisory authority in your country of residence.
14. Cookies & Analytics
This website may use cookies and analytics tools to improve functionality and performance.
You may control cookie preferences through your browser settings.
Where required by law, we obtain your consent before setting non-essential cookies via a cookie consent tool. You may withdraw or amend consent at any time through the cookie settings on this website.
15. Third-Party Services & Links
This website may contain links to third-party platforms including Stripe and Calendly.
We are not responsible for the privacy practices or policies of third-party services. Your interactions with them are governed by their respective policies.
16. Children’s Data
This website and services are not directed to individuals under 18.
We do not knowingly collect personal data from children.
17. Liability & Disclaimer
We take reasonable steps to protect personal data.
To the fullest extent permitted by law, we disclaim liability for:
• Unauthorised access beyond our reasonable control
• Data breaches originating from third-party providers
• Technical failures or cyber incidents
• Indirect or consequential damages
Nothing excludes liability where such exclusion is not legally permitted.
18. Amendments
We reserve the right to update this Privacy Policy at any time.
Continued use of the website constitutes acceptance of revisions.
19. Contact
For privacy-related enquiries:
cfo@auraliadelacroix.com