Privacy Policy

PRIVACY NOTICE

How We Use Your Personal Information

Noxora Wellness Limited  |  Complementary & Wellness Therapy Services

Document Details

 

Organisation

Noxora Wellness Limited

Registered Address

46 Kyriakou Matsi, Office 101

1082, Nicosia, Cyprus

Data Protection Contact

Barak Melnik

Version

1.01

Effective Date

May 24th, 2026

Last Reviewed

May 24th, 2026

 

About This Notice

This Privacy Notice explains what personal information we collect about you, why we collect it, how we use it, and your rights regarding that information.

Noxora Wellness Limited (“we”, “us”, “our”) is a complementary and wellness therapy practice based in Cyprus, providing services including neurostimulation, meditation and other sleep enhancing treatments. . We are committed to protecting your privacy and handling your personal data in accordance with the terms of this Privacy Notice.

You are not legally required to provide us with personal data, however, some of our services require you to do so pursuant to this Privacy Notice. In these cases, if you choose to withhold any personal data requested by us, it may not be possible for you to access certain features of the website and/or certain services. If you do not agree to the terms and conditions set forth herein please do not use or visit the website or use our services. By providing any personal data to us pursuant to this Privacy Notice, all users fully understand and unambiguously consent to this Privacy Notice and to the collection and processing of personal data as detailed herein.

We act as the Data Controller for the personal data described in this notice. This means we are responsible for deciding how and why your data is used.

 

Who This Notice Applies To

This notice applies to:

  • Existing and prospective clients who book or enquire about our therapy services
  • Visitors to our website at noxorasleep.com
  • Individuals who contact us by phone, email, or in person
  • Individuals who subscribe to our email newsletter or marketing communications

 

What Personal Information We Collect Contact and Booking Information

When you book an appointment or make an enquiry with us, we collect:

  • Full name, date of birth, and contact details (email address, phone number, home address)
  • Appointment history, booking preferences, and correspondence with us
  • Payment information (processed securely; we do not store full card details)

 

Health and Medical Information (Special Category Data)

As a complementary and alternative therapy practice, we collect the following health-related information that is necessary to provide you with safe and effective treatment:

  • Medical history, current health conditions, medications, and allergies
  • Details of previous injuries, surgeries, or relevant physical conditions
  • Treatment notes, clinical assessments, and progress records from your sessions
  • Any other health information you share with us during consultation or treatment

Health data is classified as Special Category data under Article 9 EU GDPR and receives a higher level of protection. We only collect health information that is directly relevant to your care.

 

Website Information

When you use or visit our website, we automatically collect or receive:

  • IP address, browser type, device type, and operating system
  • Information and statistics about your online/offline status
  • Pages visited, time spent on pages, and referring website, internet service provider, search history, type of browser/device, your regional and language settings and software and hardware attributes
  • Our systems may automatically record and store technical information regarding the method and nature of your use of the website
  • Cookie identifiers — see below for full details of our cookie use
  • Information you submit through our website, such as your name, contact details, appointment request details, and any other information you choose to provide.
  • Information from Third Parties.

We may also receive limited personal information about you from third parties where relevant to providing our services, managing bookings, operating our website, or responding to your enquiries. This may include information received from a person making a booking on your behalf, a healthcare professional who refers you to us, our website, booking or practice management provider, or our payment service provider. We will only use such information in accordance with this Privacy Notice and applicable law.

 

Marketing Information

If you opt in to our email newsletter, we collect your name and email address and record the date and method of your consent. You may opt out of this service at any time by clicking on the “Unsubscribe” link at the bottom of the email, or by sending us a notification to care@noxorasleep.com.

 

Why We Use Your Information (Lawful Basis)

We are required by EU GDPR to have a lawful basis for every use of your personal data. The table below sets out what we use your information for and the legal justification for doing so.

Purpose

Data Used

Lawful Basis

Providing therapy services and managing your appointments

Contact details, booking history

Contract performance (Article 6(1)(b))

Delivering safe and effective treatment

Health and medical information

Provision of health care (Article 9(2)(h)) and Explicit Consent (Article 9(2)(a))

Maintaining clinical treatment records

Health data, treatment notes

Legal obligation and health care provision (Article 6(1)(c) and Article 9(2)(h))

Processing payments

Payment information

Contract performance (Article 6(1)(b))

Responding to enquiries and communications

Contact details, correspondence

Legitimate interests (Article 6(1)(f))

Sending email newsletters and appointment reminders

Name, email address

Consent (Article 6(1)(a)) — you may withdraw at any time

Improving our services and website

Anonymised analytics data

Legitimate interests (Article 6(1)(f))

Complying with legal and regulatory obligations

Relevant records as required

Legal obligation (Article 6(1)(c))

Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of any processing carried out before withdrawal.

 

How We Process or Use Your Information

We process your personal data only for the purposes described in this Privacy Notice and take reasonable steps to ensure that the personal data we hold is accurate, relevant, and kept up to date. We ask that you let us know promptly if any of your contact details, health information, or other relevant personal data changes.

In an ongoing effort to better understand and serve our users, we often conduct research on our client demographics, interests and behavior based on their personal data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated client statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

 

How We Handle Your Health Information

Because your health information is special category data, we apply the following additional safeguards:

  • Health records are accessible only to the practitioner(s) directly involved in your care
  • Paper records are stored in locked cabinets; digital records are encrypted and access-controlled
  • We obtain your explicit consent before recording health information at your first appointment
  • You may request to see, correct, or receive a copy of your health records at any time

 

Who We Share Your Information With

We do not sell, rent, or share your personal data with third parties for their own marketing purposes.

We may share your information in the following limited circumstances:

  • With other healthcare providers — for example if we refer you to a specialist or GP for the purpose of obtaining further details on your medication, or past treatments you have undergone
  • With our practice management or booking software provider — as a data processor acting on our instructions, under a data processing agreement for the purpose of managing messaging communications and or scheduling appointments.
  • With payment processors — to handle transactions securely; they act as independent controllers under their own privacy policies
  • Where required by law — for example, in response to a court order, or to comply with a legal or regulatory obligation
  • With providers that support the operation, hosting, analytics, communications, and security of our website and related systems — only where necessary for those purposes and subject to appropriate contractual and data protection safeguards.
  • With our affiliates, agents, representatives, and third-party providers for the purpose of preparing treatment sessions, or the on-site experiences
  • If required for the provision, maintenance and improvement of our services
  • To satisfy applicable law; when permitted by you;
  • To prevent fraud or harm;
  • In the event of a merger, acquisition or other structural change or form of sale of part or all of our assets.

If we transfer your personal data outside the EEA, we will ensure that appropriate safeguards are in place as required by applicable law, including reliance on an adequacy decision where available or the use of approved standard contractual clauses and, where appropriate, supplementary measures.

 

 

How Long We Keep Your Information

Type of Information

Retention Period

Client health and treatment records

7 years from last appointment (or until age 25 if client was a minor — whichever is longer)

Booking and appointment records

5 years from last appointment

Payment and invoicing records

6 years (tax and legal obligation)

Email marketing consent records

Duration of subscription + 3 years after unsubscribe

Website analytics data

26 months (Google Analytics default, anonymised)

Enquiry and correspondence records

3 years from date of last contact

At the end of the relevant retention period, your personal data will be securely deleted or anonymised so that you can no longer be identified from it.

 

Cookies, Links and Website Tracking

Our website uses cookies — small text files placed on your device — to help us understand how visitors use the site and to improve your experience. For more information please see our Cookie Policy available at: /cookie-policy/

Cookie Type

Purpose

Can You Opt Out?

Essential / Functional

Required for the website to work (e.g. session management, booking forms)

No — these are necessary

Analytics (Google Analytics)

Helps us understand how visitors use the site — pages visited, time on site, traffic sources. Data is anonymised.

Yes — via our cookie banner or browser settings

We do not use advertising or targeting cookies. When you first visit our website, you will be shown a cookie banner allowing you to accept or decline non-essential cookies. You can change your preferences at any time via the Cookie icon on the bottom left of the screen.

For more information about Google Analytics and how to opt out, visit: tools.google.com/dlpage/gaoptout

Please note that, our services may contain links to other services, sites and applications that are subject to their own privacy and data protection policies.

 

Children

Our website is not directed to children acting independently, and our services are not directed to children.. If you are a child under the age of 18, you must obtain parental consent prior to visiting our website. We will not knowingly contact or engage with children under the age of 18.

 If you believe that a child has provided us with their personal data or that we have collected personal data from a child inappropriately or without the necessary authority, please contact us and we will take appropriate steps to review and, where applicable, delete that information from our databases.

 

Your Rights

Under EU GDPR, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us using the details below.

Your Right

What This Means

Right of Access

Request a copy of the personal data we hold about you (a Subject Access Request).

Right to Rectification

Ask us to correct any inaccurate or incomplete information we hold about you.

Right to Erasure

Ask us to delete your personal data where there is no compelling reason for us to keep it. Note that we may need to retain certain records (e.g. health records) for legal reasons.

Right to Restriction

Ask us to temporarily stop using your data in certain circumstances, for example while you contest its accuracy.

Right to Data Portability

Request your personal data in a structured, machine-readable format so you can transfer it to another provider.

Right to Object

Object to our use of your data where we rely on legitimate interests. We will stop unless we have compelling grounds that override your interests.

Right to Withdraw Consent

Where we rely on consent (e.g. for email marketing or recording health data), you may withdraw it at any time. This will not affect any processing already carried out.

Right to Lodge Complaint

Lodge a complaint with a data protection supervisory authority regarding the processing of your data.

We will not charge you for exercising your rights unless a request is manifestly unfounded or excessive.

 

Email Marketing

We will only send you marketing emails if you have explicitly opted in to receive them. Each marketing email we send will include a clear and easy unsubscribe link.

You can withdraw your consent and unsubscribe at any time by:

  • Clicking the “unsubscribe” link in any of our emails
  • Emailing us at care@noxorasleep.com
  • Contacting us directly at the practice

Unsubscribing from marketing communications will not affect your ability to receive appointment confirmations, reminders, or other service-related communications.

 

How We Keep Your Information Secure

We take the security of your personal data seriously and have put in place appropriate technical and organisational industry standards to protect against unauthorized access, alteration, disclosure or destruction of your personal data, including:

  • Encryption of digital records containing personal and health data
  • Password-protected systems with role-based access controls
  • Locked storage for paper-based health records
  • Staff trained in data protection and confidentiality obligations
  • Secure disposal of paper records and electronic equipment

However, we cannot guarantee its absolute security.

 

How to Contact Us or Make a Complaint

If you have any questions about this Privacy Notice, wish to exercise your rights, or have a concern about how we have handled your personal data, please contact our Data Protection Lead:

Contact Details

 

Name / Role

Barak Melnik, VP Data and Training

Email

barak@noxorasleep.com

Phone

+39 349 4541576

Address

46 Kyriakou Matsi, Office 101

1082, Nicosia, Cyprus

 

Changes to This Notice

We may update this Privacy Notice from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes, we will:

  • Update the “Last Reviewed” date at the top of this notice
  • Post the revised notice prominently on our website
  • Notify existing clients by email where the changes significantly affect how we use their data

We encourage you to review this notice periodically. The current version will always be available at www.noxorasleep.com/privacy and in our Sleep Restoration Centers’ reception area.

Internal Approval Record

Approval

 

Approved by

Ronen Melnik

Date approved

May 25, 2026

Next review date

February 7th, 2027

Your path to better sleep

1

Short questionnaire

2

Further information gathering

3

25 minute consultation (zoom)

4

Schedule program days

5

3 half days on-site program

6

6 week & 3 month follow up calls

1

Is the Sleep Recovery
Program for you?

 Answer a very short questionnaire to find out.
The Insomnia Severity Index (ISI) questionnaire is the standard used by many experts as a first step to assess sleep problems. It is a quick way to check how severe your sleeping issues might be.
Fill in the ISI and a few additional short questions to check if the Noxora Sleep Recovery Program might be relevant for you.

Thank You

Your assessment has been received.

A member of the Noxora team will review your information and contact you shortly regarding the next steps.