Privacy policy

Last updated: 11 October 2026

1. About Path Therapy Network

Path Therapy Network is a professional website that brings together independent practitioners who offer their services separately.

The website is owned and operated by Elena Marinopoulou, based in Malta. The website itself does not provide therapy services and does not operate a shared client, therapy, or clinical records system.

Each practitioner listed on Path Therapy Network operates independently. When you contact a practitioner directly, that practitioner is responsible for the personal information you provide and acts as the Data Controller for their own professional practice.

The current practitioners are:

Vasilis Vlachodimos
Integrative Counsellor and Psychotherapist
United Kingdom
Email: vasilis@paththerapynetwork.com

Elena Marinopoulou
Board Certified Behaviour Analyst and ACT Practitioner
Malta
Email: elena@paththerapynetwork.com

Practitioners do not have access to each other’s client records, case notes, or email correspondence.

2. The Path Therapy Network Website

At present, the Path Therapy Network website does not provide:

  • Online appointment booking;
  • Online payments;
  • Newsletters or mailing lists;
  • User accounts;
  • Advertising or marketing tracking technologies; or
  • Website analytics.

The website hosting provider may process limited technical information necessary to operate, maintain, and secure the website. This may include:

  • IP addresses;
  • Browser information;
  • Device information; and
  • Server log data.

Contact forms

Each practitioner has their own contact form on their profile page. A message sent through a practitioner’s form is delivered only to that practitioner. It is not sent to, and cannot be seen by, any other practitioner.

The form asks for your name and email address, and optionally your phone number and a short message. This information is used only so that the practitioner can reply to your enquiry. Once received, the practitioner is responsible for it as described in Section 3.

To deliver form messages, the website hosting provider, Netlify, Inc., processes and stores a copy of each submission. Netlify is based in the United States (see Section 8). Stored copies are accessible only to the website’s technical administrator and are not shared with other practitioners.

The website is operated from Malta. Personal data processed in connection with the website is subject to the EU General Data Protection Regulation (GDPR) and applicable Maltese data protection law.

The competent supervisory authority in Malta is the:

Information and Data Protection Commissioner (IDPC)
Website: https://idpc.org.mt

If the website’s functionality changes, including the introduction of analytics, online booking systems, payment processing, or marketing tools, this Privacy Policy will be reviewed and updated accordingly.

3. Contacting a Practitioner

If you wish to enquire about services, please contact your chosen practitioner directly using the email address or contact form on their profile page.

We recommend that you avoid including detailed medical, psychological, or other sensitive information in your initial email or message.

Information sent directly to one practitioner is not routinely accessible to any other practitioner associated with Path Therapy Network.

Each practitioner is independently responsible for collecting, using, storing, and protecting the personal information of their prospective and current clients.

4. Information a Practitioner May Process

When you contact or work with a practitioner, they may process personal information including:

  • Your name and contact details;
  • Information contained in your enquiry;
  • Appointment and administrative information;
  • Payment and invoicing information;
  • Information you choose to share about yourself; and
  • Where relevant to the services provided, information relating to your physical health, mental health, wellbeing, circumstances, or therapy.

Information concerning physical or mental health constitutes special category personal data under the GDPR and UK GDPR and is subject to additional legal protections.

Each practitioner is responsible for identifying and documenting an appropriate lawful basis for processing personal information and, where required, a valid condition for processing special category data.

5. Why Information Is Used

Personal information may be processed where necessary to:

  • Respond to enquiries;
  • Assess whether services are suitable and appropriate;
  • Arrange and manage appointments;
  • Provide professional services;
  • Maintain professional and clinical records;
  • Manage payments, invoicing, and accounting obligations;
  • Comply with legal, regulatory, ethical, and professional requirements; and
  • Protect the rights, safety, and legitimate interests of clients and practitioners where permitted by law.

Where processing is necessary to take steps at your request prior to entering into a service agreement, or to provide agreed services, practitioners may rely on the lawful basis of contract under Article 6 GDPR or UK GDPR.

Where health or other special category information is processed, practitioners will also rely on an applicable Article 9 condition relevant to their professional practice and jurisdiction.

6. How Information Is Stored and Shared

Each practitioner maintains their own independent records.

Path Therapy Network does not operate a shared clinical records system, and practitioners do not routinely have access to one another’s client information.

Practitioners may use appropriately selected third-party service providers for activities such as:

  • Professional email services;
  • Video consultations;
  • Appointment administration;
  • Payment processing; and
  • Secure record keeping.

Each practitioner is responsible for ensuring that any providers they use offer appropriate standards of confidentiality, security, and data protection.

Because practitioners operate independently and may use different systems, this Privacy Policy identifies categories of recipients rather than naming specific technology providers.

Personal information will not be disclosed to third parties except where there is a lawful basis or a legal, ethical, regulatory, safeguarding, or professional obligation to do so.

7. Security of Your Information

Protecting the confidentiality and security of personal information is important to both Path Therapy Network and its independent practitioners.

Each practitioner is responsible for implementing appropriate technical and organisational measures to safeguard the personal information they control. Depending on the systems used by the individual practitioner, these measures may include:

  • Password-protected devices and accounts;
  • Encrypted storage and communication systems where available;
  • Restricted access to client information;
  • Secure professional email services;
  • Secure clinical record-keeping systems;
  • Regular software and security updates;
  • Confidentiality obligations; and
  • Secure disposal of records when no longer required.

While reasonable steps are taken to protect personal information, no method of transmitting information over the internet or storing information electronically can be guaranteed to be completely secure. Individuals should take care when sending information by email and avoid including unnecessary sensitive personal information in initial communications.

If a practitioner becomes aware of a personal data breach that poses a risk to individuals’ rights and freedoms, they will take appropriate action in accordance with applicable data protection laws, including notifying the relevant supervisory authority and affected individuals where required.

8. International Transfers

Some service providers used by practitioners may process personal information outside the country in which you or your practitioner are located.

Where such processing constitutes an international transfer under the GDPR or UK GDPR, the practitioner responsible for the information will ensure that an appropriate transfer mechanism and safeguards are in place.

These safeguards may include:

  • Adequacy regulations or adequacy decisions;
  • Standard Contractual Clauses (SCCs);
  • The UK International Data Transfer Agreement (IDTA); or
  • Other lawful transfer mechanisms recognised under applicable data protection law.

The website hosting provider, Netlify, Inc., is based in the United States and processes server log data and contact form submissions. Where this involves an international transfer, appropriate safeguards will be relied on as described above.

Transfer arrangements will be reviewed whenever systems or providers are introduced or changed.

9. How Long Information Is Kept

Personal information is retained only for as long as necessary to fulfil the purpose for which it was collected and to comply with legal, regulatory, professional, insurance, and record-keeping requirements.

Clinical records may need to be retained for longer periods than general correspondence due to professional and legal obligations.

Retention periods may vary depending on:

  • The practitioner’s profession and regulatory requirements;
  • The nature of the records kept; and
  • Whether UK or Maltese legal requirements apply.

When information is no longer required, it will be securely deleted, anonymised, or otherwise disposed of appropriately.

10. Your Rights

Depending on the applicable law and circumstances, you may have the right to:

  • Be informed about how your personal information is used;
  • Request access to your personal information;
  • Request correction of inaccurate or incomplete information;
  • Request erasure of personal information in certain circumstances;
  • Request restriction of processing;
  • Object to certain types of processing; and
  • Receive a copy of your personal information in a portable format where applicable.

These rights are not absolute and may be subject to exemptions or limitations under applicable law.

For example, practitioners may be required to retain clinical records where professional, legal, safeguarding, or insurance obligations apply.

To exercise any of your rights, please contact the practitioner who holds your information.

11. Complaints

If you have concerns about how Vasilis Vlachodimos has handled your personal information, please contact:

vasilis@paththerapynetwork.com

If your concern remains unresolved, you may lodge a complaint with the:

Information Commissioner’s Office (ICO)
Website: https://ico.org.uk

If your concern relates to Elena Marinopoulou or the operation of the Path Therapy Network website, please contact:

elena@paththerapynetwork.com

You may also lodge a complaint with the:

Information and Data Protection Commissioner (IDPC)
Website: https://idpc.org.mt

You have the right to contact the relevant supervisory authority at any time if you believe your data protection rights have been infringed.

12. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time to reflect:

  • Changes to website functionality;
  • Changes in how practitioners process personal information;
  • Changes to legal, regulatory, or professional requirements; or
  • Improvements to data protection practices.

The most current version will always be published on the Path Therapy Network website.

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