I am the fat – I mean – data controller, and I am responsible for your personal data. It’s key that the information I have and hold about you is accurate and up to date. So, please let me know if at any time if your personal information changes by emailing me at firstname.lastname@example.org
What is the data, for what purpose and how do I collect it?
As a coaching client: I will collect your data in the form of your name, email address, Skype name/account, home address and telephone number. I store this data in my confidential paper notes. I will use the data you provide me to contact you via email, Skype, mail or telephone for the purposes of communicating with you within the context of our coaching work together.
If you signed up to my mailing list (via the contact form on my website or Facebook): Your email address and name will be stored in an email system I use called MailChimp. I will use this information to contact you via Mailchimp for the purposes of sending you emails. You will not be added to any other email lists within Mailchimp or elsewhere unless you subscribe yourself to them. I will never share your personal data with any third party for their own marketing purposes. You can ask me to stop sending you emails at any time by following the opt-out links in my emails sent to you or by emailing me at email@example.com
While using my website, I may collect information about you, such as your IP address, details about your browser (Microsoft Edge, Safari, Chrome, Firefox), the amount of time you spend on the pages of my website, your page views and navigation paths, details about the number of times you use my website, time zone settings and other technology on the devices you use to access my website. The source of this data is from the analytics tracking system called Google Analytics. I process this data to analyse the use of my website to administer and protect my business and website, to deliver relevant website content and advertisements, and to understand the effectiveness of my advertising.
I do not and will not ever collect any sensitive data about you.
Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. I also do not collect any information about criminal convictions and offences.
I may also receive data from third parties, such as analytics providers like Google based outside the EU, advertising networks such as Facebook-based outside the EU, or providers of Payment services such as Paypal, both based outside the EU.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided because of transactions such as purchasing coaching services.
Again, if you’d like me to remove your information from my mailing list, please email me at firstname.lastname@example.org and I can arrange this for you.
Who with, and why might I share your personal data?
From time to time, I may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including bankers, auditors, accountants, insurers and lawyers.
- Government bodies that require me to report processing activities.
I require all third parties to whom I transfer your data to, to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions, and in the knowledge that they too must follow GDPR guidelines.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Any of my third parties service providers (such as Paypal, and MailChimp) that are based outside the European Economic Area (EEA), the processing of your personal data will involve a transfer of data outside the EEA.
Whenever I transfer your personal data out of the EEA, I do my very best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- I will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where I use certain service providers, I may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If I use US-based providers that are part of EU-US Privacy Shield, I may transfer data to them, as they have equivalent safeguards in place.
- If none of the above safeguards is available, I may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
What do I do with your data and how long do I hold on to it for?
I will only keep hold of your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for, I look at its amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires me to keep basic information about my clients (including contact information, financial and transaction data) for six years after they stop being clients.
In some circumstances, I may anonymise your personal data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.
Your legal rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to the portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email me at email@example.com
You will not have to pay a fee to access your personal data. However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.
I will do my best to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made several requests. In this case, I will notify you.
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
However, I would be grateful if you contact me first if you do have a complaint so that I can try to resolve it with you.
What about links on my website to third-party sites?
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and I am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit.
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and, in each case, you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
What is a cookie?
A cookie is a piece of information (not a biscuit) that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and will not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of this site.
Cookies are either:
- Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any personal data from your computer; or
- Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. I use persistent cookies for Google Analytics.
Cookies can also be categorised as follows:
- Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and/or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided.
These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance cookies: These cookies enable me to monitor and improve the performance of my website. For example, they allow me to count visits, identify traffic sources and see which parts of the site are most popular.
- Functionality cookies: These cookies allow my website to remember choices you make and provide enhanced features. For instance, I may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
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