1. WHAT THIS POLICY COVERS
2. WHO WE ARE
Email address: firstname.lastname@example.org
Postal address: 13 St Luke’s Avenue, London SW4 7LG, UK
3. HOW YOU CAN MAKE A COMPLAINT
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
4. WHAT DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may process different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, age and gender.
- Contact Data includes postal address, email address, telephone numbers and social media addresses.
- Transaction Dataincludes details about payments to and from you and other details of services you have purchased from us.
- Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Other Personal Data: Hans may be keeping notes ofmatters discussed in your coaching sessions with him. On occasions this may include Special Categories of Personal Data, such asdetails about your ethnicity, religious or philosophical beliefs, sex life, sexual orientation, trade union membership or information about your health. We will collect this data only if you have provided it to us in the context of your coaching sessions with Hans. This data will never be shared with third parties unless we are required to do so by law.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Please inform us of changes in your data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. HOW WE COLLECT YOUR PERSONAL DATA
Whenever you interact with us, we collect data. Sometimes you provide us with data, sometimes data about you is collected automatically.
Here is how and when we do this:
- You sign up to our newsletters on our website, landing pages, emails or social media profiles
- You contact us via email, telephone or postal mail
- You enquire about services from us
- You instruct us to provide services
- You opt in to your marketing communications
- You interact with us on social media sites
We may also receive your personal data from the following third parties:
- Online coaching directories where you have posted your interest in coaching services, such as Bidvine and Bark
- Social media sites where you have publicised your information
- Third parties who refer you to us, such as fellow coaches or previous clients
6. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contractwe are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests(or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Where you have given us consent.
7. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Lawful basis for processing|
|To respond to your enquiry about services||To perform a contract with you|
|To register you as a new client||To perform a contract with you|
|To provide services to you||To perform a contract with you|
|To collect and recover money owed to us||To pursue our |
|To manage our relationship with you||To perform a contract with you|
To comply with a legal obligation
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||To pursue our legitimate interestsTo comply with a legal obligation|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||To pursue our legitimate interests|
|To share free resources with you or to make suggestions and recommendations to you about goods or services that may be of interest to you||To pursue our legitimate interests|
Promotional offers from us
We may use your data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased similar services from us and you have not opted out of receiving that marketing.
We will never share your personal data with any third party for their own marketing purposes.
You can ask us to stop sending you newsletters and marketing messages at any time by following the opt-out links on any marketing message sent to you orby contacting us at any time via email@example.com.
7. WITH WHOM WE MAY SHARE YOUR PERSONAL DATA
We may share your personal data with the parties set out below:
- Service providers:these are companies or persons who provide IT and system administration services to us, such as website maintenance, social media management or database management.
- Professional advisers: including lawyers, bankers, tax advisors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services to us.
Third parties will nothave access to notes that Hans may create about your coaching sessions with you. Any such notes will be kept 100% confidential and not be shared with any third party.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. WHERE YOUR DATA WILL BE LOCATED
We will not transfer your data outside the UK. However, some of our external third parties may use servers outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA. This applies to standard services with reputable suppliers such as Google, Dropbox and GoDaddy. Whenever your personal data is transferred out of the EEA, these third parties will ensure a similar degree of protection is afforded to it in compliance with EU data protection laws.
9. HOW WE KEEP YOUR DATA SAFE
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. FOR HOW LONG WE WILL USE YOUR DATA
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We keep basic information about our customers for six years after they cease being customers for tax purposes and to be able to respond to any requests for further support or legal claims that are served with the six-year limitation.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rightsbelow for further information.
11. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you feel that processing your personal data impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
THIRD PARTY LINKS