Privacy Notice & Legal Information

01Data Controller & Legal Identity

The data controller responsible for the processing of your personal data under this notice is:

In accordance with Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE), the information above constitutes the mandatory legal identification of the operator of this website.

02Personal Data Collected

SHANOI collects only the personal data necessary to deliver the requested services and to respond to enquiries. The categories of data processed are:

2.1 Data you provide directly

• Contact information: name, email address, and the content of any message you send via the contact form or by direct email
• Session intake information: date of birth and place of birth (for akashic readings and lineage work), areas of life you wish to explore, and any information you choose to share before, during, or after a session
• Billing information: name, postal address, country of residence, and (where legally required for invoicing in Spain) tax identification number
• Payment information: payments are processed by third-party providers (Stripe, iCard, or SEPA bank transfer). SHANOI does not store full card numbers; only the transaction reference and amount are retained for accounting purposes

2.2 Data collected automatically

• Technical data: IP address, browser type and version, operating system, device type, pages visited, referral source, and timestamps. This data is collected via server logs and used for security, debugging, and anonymous traffic analysis
• SHANOI does not use third-party analytics such as Google Analytics, Meta Pixel, or similar tracking services

2.3 Sensitive data

Sessions may incidentally involve the sharing of information considered special categories of data under Article 9 GDPR, including health, spiritual beliefs, religious or philosophical convictions, or details of your personal life. Such information is only processed with your explicit consent, is held in the strictest confidence, and is never used for any purpose beyond the session itself.

03Purposes & Legal Basis of Processing

Under Article 6 GDPR (and the equivalent provisions of Spanish LOPDGDD 3/2018), personal data is processed on the following legal bases:

• Consent (Art. 6.1.a GDPR): when you submit the contact form, book a session, subscribe to a newsletter, or share sensitive information in session
• Contract performance (Art. 6.1.b GDPR): to deliver the services you have booked (sessions, audits, reports) and to communicate with you about them
• Legal obligation (Art. 6.1.c GDPR): to comply with Spanish tax, accounting and invoicing law (General Tax Law 58/2003, Billing Regulation RD 1619/2012), and with Spanish Social Security obligations
• Legitimate interest (Art. 6.1.f GDPR): for website security, fraud prevention, and the defence of legal claims

04Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected:

• Contact form enquiries that do not lead to a booking: deleted within 12 months
• Client session notes and intake information: retained for the duration of the client relationship plus 3 years, unless the client requests earlier deletion
• Invoices and accounting records: retained for 6 years in accordance with Spanish commercial law (Art. 30 Código de Comercio)
• Tax records: retained for 4 years in accordance with the Spanish General Tax Law (Art. 66 LGT)
• Server logs: retained for a maximum of 12 months for security purposes

05Data Sharing & International Transfers

SHANOI does not sell, rent, trade, or share personal data with third parties for marketing or advertising purposes. Data is shared only with the following categories of recipients, strictly as necessary to deliver services:

• Payment processors: Stripe (Ireland, GDPR-compliant), iCard (Bulgaria, licensed EMI under EU regulation), SEPA banking providers
• Email and hosting providers: the hosting provider of shanoi.net and the email provider used for client correspondence
• Video conferencing: Zoom (United States, operating under GDPR Standard Contractual Clauses) when sessions take place remotely
• Spanish tax and social security authorities (AEAT, Seguridad Social): when legally required
• Professional advisors: legal counsel, where strictly necessary for the defence of legal claims

International transfers: where data is transferred outside the European Economic Area, it is governed by the European Commission's Standard Contractual Clauses or by equivalent safeguards. Clients based outside the EU (United Kingdom, Canada, United States, UAE, Singapore, and elsewhere) acknowledge that their personal data is processed in Spain under GDPR and LOPDGDD.

06Your Rights

Under GDPR, LOPDGDD, UK GDPR, and equivalent legislation in your country of residence, you have the following rights with respect to your personal data:

To exercise any of these rights, write to shanoi@shanoi.net. Requests will be responded to within 30 days (extendable to 60 days where necessary and with notification). No fee is charged, except where requests are manifestly unfounded or excessive.

07Cookies & Tracking

The shanoi.net website uses only strictly necessary technical cookies required for the website to function (such as session management and security). These do not require consent under Spanish Royal Decree-Law 13/2012 or the EU ePrivacy Directive.

SHANOI does not use:

• Advertising cookies
• Analytics or tracking cookies (no Google Analytics, no Meta Pixel, no LinkedIn Insight Tag)
• Social media tracking pixels
• Behavioural profiling or retargeting cookies

Your browsing of shanoi.net is not tracked, profiled, or sold to third parties.

08Security Measures

SHANOI implements appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:

• Encrypted HTTPS transmission across the entire website
• Access to session notes and client records restricted to Natalie de Alma personally
• Secure storage of digital records with password protection and encrypted backups
• Regular review of access permissions and data minimisation
• Payment data handled exclusively by PCI-DSS compliant third-party processors

In the event of a personal data breach likely to result in a risk to your rights and freedoms, you will be notified without undue delay in accordance with Article 34 GDPR.

09Minors

SHANOI services are intended exclusively for adults aged 18 and over. The website is not directed at minors, and personal data of minors is not knowingly collected or processed. If you become aware that a minor has provided personal data without the consent of their legal guardian, please contact natalie@shanoi.net and the data will be deleted immediately.

10Region-Specific Rights

10.1 United Kingdom (UK GDPR)

If you are located in the United Kingdom, you have equivalent rights under the UK GDPR and the Data Protection Act 2018. You may lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

10.2 Canada (PIPEDA)

If you are located in Canada, SHANOI processes your personal data in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). You may lodge a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.

10.3 California, United States (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA): the right to know what personal information is collected, the right to delete personal information, the right to correct inaccurate personal information, the right to opt out of the sale or sharing of personal information (SHANOI does not sell or share personal information), and the right to non-discrimination for exercising these rights.

To exercise CCPA rights, write to natalie@shanoi.net with the subject line "CCPA Request".

10.4 Other jurisdictions

Clients located outside the EU, UK, Canada, or California retain the right to lodge a complaint with the data protection authority of their country of residence, where applicable.

11Supervisory Authority & Complaints

If you believe that the processing of your personal data by SHANOI infringes applicable data protection law, you have the right to lodge a complaint with the primary supervisory authority:

You may equally lodge a complaint with the supervisory authority of your EU/EEA country of residence, or with the equivalent authority in your jurisdiction (ICO in the UK, OPC in Canada, etc.).

12Terms of Service

12.1 Nature of services

SHANOI provides consulting services in AI relational literacy, filter architecture awareness, and sacred channel clearing. L'Atelier Sacré provides akashic readings, field reading, psychosomatic listening, lineage work, and guided meditations. These services are offered as complementary to, and not a substitute for, medical, psychological, psychiatric, or legal advice. If you are experiencing a medical or mental health crisis, seek qualified professional help without delay.

12.2 Session confidentiality

All content shared during sessions is held in the strictest professional confidence and is never disclosed to third parties, except where disclosure is required by Spanish law or to protect the vital interests of the client or another person.

12.3 Intellectual property

All content published on shanoi.net, including text, images, protocols, methodologies, and the SHANOI name itself, is the intellectual property of Natalie de Alma and is protected under Spanish Law 1/1996 on Intellectual Property (Ley de Propiedad Intelectual) and international copyright conventions. Unauthorised reproduction, distribution, or adaptation is prohibited.

12.4 Cancellation and refunds

Specific cancellation and refund terms are communicated at the time of booking. Clients retain the statutory right of withdrawal under Spanish Royal Legislative Decree 1/2007 (Ley General para la Defensa de los Consumidores y Usuarios), where applicable.

12.5 Governing law and jurisdiction

These terms and the services provided by SHANOI are governed by Spanish law. Any dispute arising from the use of this website or the services provided shall be submitted to the exclusive jurisdiction of the courts of Málaga, Spain, without prejudice to any mandatory consumer-protection rights available to clients in their country of residence.

13Updates to This Notice

This Privacy Notice may be updated from time to time to reflect changes in the services provided, in applicable law, or in SHANOI's practices. The date of the most recent update is shown at the top of this page. Significant changes will be communicated by email to clients with active bookings or active correspondence.

14Contact

For any question regarding this Privacy Notice, the processing of your personal data, or to exercise your rights, please write to: