Last reviewed: 12/05/2018
1. Background introduction
At Fresh Insight Coaching Limited we understand that your privacy is important to you and that you care about how your information is used and shared. We feel the same. So we are committed to protecting and respecting your privacy and aim to ensure that will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law and regulatory requirements, including the Data Protection Act.
For the purpose of the Data Protection Act 1998 and under the General Data Protection Regulation (GDPR), the data controller is Tam Johnston of Fresh Insight Coaching Limited of Suite 163, 2 Lansdowne Row, Berkeley Square, Mayfair, London, W1J.
The date controller complies with her obligations by keeping personal data up to date; by storing (and destroying it) securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
By submitting personal data to us, you agree to us using your data as follows.
This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and applies to our use of any and all data collected by us in relation to your use of our sites and services.
This includes information provided at the time of registering to use our sites including any information you may provide through our sites or to us when you subscribe to our service, purchase a product or service, sign up to our newsletter and mailing lists, take part in a survey, offers, prize draws or competitions, any posting material or requesting further services.
This privacy notice also covers any personal data that you provide us with by placing orders at events, workshops, training courses or in paper form.
We may also ask you for information when you report a problem with our sites.
2.1. Definitions and Interpretation
This can all be a bit wordy so let’s clarify. In this Policy the following terms shall have the following meanings:
|“Account”||Means an account required to access and/or use certain areas and features of Our sites;|
|“Cookie”||Means a small text file placed on your computer or device by Our sites when you visit certain parts of Our sites and/or when you use certain features of Our sites. Details of the Cookies used by our sites are set out in section 8, below;|
|“Our sites”||Means the following websites: www.freshinsightcoaching.com www.freshinsightnlp.com|
|“UK and EU Cookie Law”||Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;|
|“We/Us/Our”||Means Fresh Insight Coaching Ltd , a limited company registered in England under 8381425 whose registered address is Suite 163, 2 Lansdowne Row, Berkeley Square, Mayfair, London, W1J|
3. Children and Privacy
If you’re aged 13 or under, you need to get permission to register on our sites and we will only collect and store data about you with consent from your parents or guardian.
4. Information we may collect from you
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may collect and process the following data about you:
Identity data: first name, maiden name, last name, business/company name, job title, profession, username, marital status, title, date of birth and gender;
Contact Data: may include your billing address, delivery address, email address and telephone numbers;
Financial Data: may include your bank account and payment card details;
Transaction Data: may include details about payments between us and other details of purchases made by you;
Technical data: some data will be collected automatically related to your visits to our sites including, but not limited to, traffic data, location data, plug-in types and versions, time zone setting and location, web browser type and version, operating system, IP address, a list of urls starting with a referring site, your activity on our sites, and the site you exit to automatically collected and other technology on the devices you use to access this site;
Usage Data: may include information about how you use our website, products and services;
Profile Data: may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses;
5. How we collect your personal data
We collect data about you through a variety of different methods including:
5.1. Direct interactions: You may provide data by filling in forms on our sites (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- Order our products or services;
- Create an account on our sites;
- Subscribe to our service or publications;
- Request resources or marketing be sent to you;
- Enter a competition, prize draw, promotion or survey; or
- Give us feedback;
- Where you have given us your name and email address either on a handwritten list at for example an event, or have handed us your business card;
- If you contact us, we may keep a record of that correspondence;
5.3. Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- Analytics providers such as Google based outside the EU;
- Search information providers such as Google based inside or outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Wave, Paypal, Stripe or World pay based inside OR outside the EU;
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU;
- Ticket websites such as Eventbrite if you are purchasing tickets for our events;
- Events websites such as Meetup if you join any of our meetup groups, sign up for events or request information;
6. Usage of your personal data
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
You have given consent to the processing of your personal data for one or more specific purposes:
- Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation to which we are subject;
- Processing is necessary to protect the vital interests of you or of another natural person;
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
We use your personal data for the following purposes
- Supplying and delivering our services and products that you have requested;
- Where we need to perform the contract between us;
- To maintain our own accounts and records;
- Contacting and responding to you as necessary in accordance with the services you have requested;
- Contacting you via surveys to ascertain your opinions on the service you received from us;
- Providing and managing your account;
- Providing and managing your access to our sites;
- Personalising and tailoring your experience on our sites;
- Personalising and tailoring our products and services for you;
- Supplying you with email newsletters, new products and services, free resources or alerts that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the link at the bottom of this correspondence;
- Analysing your use of our sites and gathering feedback to enable us to continually improve our sites and your user experience;
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on our products, offers and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
7. How and Where Do We Store Your Data?
7.1 We only keep your data for as long as we need to in order to use it as described above in section 6 and to fulfil our legal requirements. In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
7.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using our sites and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR.
7.3 Data Security is of great importance to us. 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 such data. 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.
7.4 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data to us via the internet.
7.5 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
7.6 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Our Data Retention Policies are:
Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using our sites and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR.
Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.
In certain circumstances, we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8. Cookies and analytics services
9. Links to Other Web Sites
10. Access to Your Personal Information
You are entitled to access the personal information that we hold on. Email your request to firstname.lastname@example.org We try to respond to all legitimate requests within one month. Occasionally it may 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.
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 may refuse to comply with your request in these circumstances. Because, you know, we’re busy too.
11. Updating Your Personal Information and Unsubscribing
You can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our newsletters.
12. Your Consent
If you have any questions or concerns about our collection, use or disclosure of your personal information, please drop us a line at email@example.com If you are not happy with any aspect of how we 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, we really hope you don’t feel the need to do that. Please come to us first. We’re very friendly and always want you to be happy and we’ll endeavour to work with you to resolve any concerns.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org
Phew. Well done you. You made it to the end! Thanks for your time.