I am the data controller and I am responsible for your personal data. It is very important that all the information I hold about you is accurate and up to date.
Please let me know if, at any time, your personal data information changes by emailing me at firstname.lastname@example.org.
What personal data I collect and why I collect it
While you are on my website
While you are on my website, I may collect information about you, such as your IP address, details about your browser (i.e. Safari, Chrome, Firefox), the amount of time you spend on the pages of my website, the 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 I use called Google Analytics. I process this data to analyze your use of my website to administer and protect my business and website, to deliver relevant website content and advertisement to you, and to understand the effectiveness of my advertising.
I do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, 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 or offenses.
I may receive data from third parties, such as analytics providers like Google based outside of the EU, advertising networks such as Facebook based outside of 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 as a result of other transactions, such as purchases of online products or coaching services.
If you like me to remove your information from my mailing list, please send an email to me email@example.com and I’ll arrange for your information to be removed.
If you are a coaching client
I will collect the following data from you;
• your name,
• email address,
• Skype name/account,
• home address, and
• telephone number
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 context of our coaching work together.
If you signed up to my mailing list
Your email address and name will be stored in an email system called ActiveCampaign. I use this information to contact you via ActiveCampaign for the purposes of sending you emails.
You will not be added to any other email lists within ActiveCampaign 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 you can email me at firstname.lastname@example.org.
If you leave comments on my blog posts
When you’re commenting on any of my blog posts, I collect the data shown in the comments form, and also your IP address and your browser user agent string to help spam detection.
Before any comment is published on the site, I always read through it to help reduce spam. After approval of your comment(s), your Gravatar, if you have set up the Gravatar service, is visible next to your comment(s) for everyone to see.
How I use your data
I store all personal data securely and in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).
I use your data to provide the best possible products and services to you. This includes:
• providing and managing your access to my site
• personalizing and tailoring your experience on my site
• supplying my products and services to you
• personalizing and tailoring the products and services for you
• responding to communication from you
• supplying you with email newsletters, alerts, etc. that you have subscribed to (you may unsubscribe or opt-out at any time by following the opt-out links in my emails sent to you or you can email me at email@example.com)
• market research
• analyze your use of my site and gathering feedback to enable me to continue to improve my site and your user experience
In some cases, the collection of data may be a statutory or contractual requirement and I may be limited in the products and services I can provide you without your consent for me to be able to use such data.
Once you’ve submitted your data, I use your data for marketing purposes which may include contacting you by email, telephone, text message with information, news and offers on products and services. However, I will not send you any unsolicited marketing or spam and I will take all reasonable steps to ensure I fully protect your rights and that I comply with my obligations under the GDPR and the Privacy and Electronic Communication (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
How I store your data
Under GDPR, I will ensure that your personal data is processed lawfully, fairly and transparently, without adversely affecting your rights. I will only process your personal data if at least one of the following basis applies:
• you have given me consent to the processing of your personal data for one or more specific purposes
• processing is necessary for the performance of a service (for example coaching service) which you have purchased or requested to purchase by taking related steps as part of the order process
• processing is necessary for compliance with legal obligations to which I am 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 purpose of the legitimate interested pursued by me or by a third party, except where such interest are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data is subject to a child.
I keep your data for as long as I need to in order to use it as described in previous section (“How I use your data”) and/or as long as I have your permission to keep it. In any event, your data will be deleted if you notify me via firstname.lastname@example.org requesting for it to be deleted.
Data security is of great importance to me and to protect your data, I have put in place suitable physical, electronic and managerial procedure to safeguard and secure data collected through my site.
Notwithstanding the security measures that I 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 me via the internet.
Transfer and storage of data outside of the EU
Some or all of your data may be stored or transferred outside of European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland nad Liechtenstein). You are deemed to accept and agree to this by using my site and submitting information to me.
Many of my third parties service providers (such as Paypal, ActiveCampaign and Bluehost) are based outside of the EEA so their 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 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. I do this 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 code 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 may have the right to withdraw this consent at any time.
My usage of Third Party suppliers
From time to time, I may work with third party applications in order to provide you with the best service on the Site. These organisations may collect personal information from you in order to provide you with these services including your name and contact information.
The third party suppliers I’m currently using are listed below. I’ve included links to their Privacy Policies to ensure you are comfortable using them.
AcuityScheduling (via Squarespace): https://www.squarespace.com/privacy,/p>
Embedded content from other websites
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.
How long I keep your data
I only keep your personal data for as long as necessary to fulfill the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time to keep the data for, I look at its amount, nature and sensitivity, the potential risk of harm for unauthorized 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 my clients.
In some circumstances I may anonymize your personal data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.
If you leave a comment on my site, the comment and its metadata is retained indefinitely. This is so I can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
What rights you have over your data
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 portability of data (where the lawful ground of processing is consent) and to withdraw consent.
If you wish to exercise any of the rights set out above, please email me at email@example.com.
Cost for requesting your data
You don’t have to pay a fee to access your personal data or to exercise any of the other rights and I will comply with your request as soon as administratively possible. However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive and I may reserve my rights to 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 the other rights.
Processing time for obtaining your data
I’ll do my very best to respond to all legitimate requests within 30 days of receiving the request. If, for any reason, it will take me longer than 30 days (if your request is particularly complex or you have made a number of requests), I will notify you in advance of the expiration of the 30 days.
If you have complaints on how I handle your data
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 Commmissioner’s Office (ICO), the supervisory authority for data protection issues. I would be grateful if you contact me first if you do have a complaint so that I can try to resolve it for you. Please contact me at firstname.lastname@example.org.
For more information about the cookies I use, please continue to read this section.
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 me about my products or services or (ii) you agreed to receive marketing communications and where you in each case have not opted out of receiving such communication 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 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 analyze traffic and for advertising and marketing purposes.
Cookies are used by nearly all website and do not harm your system.
If you want to check or change what type 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 allow all cookies (including essential cookies), you may not be able to access all or parts of my site.
As mentioned earlier in this section, you may deny consent to the placing of cookies, however certain features of my site may not function fully or as intended. You can deny consent by exiting from my website.
All cookies used by an on my site are used in accordance with relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015.
The different types of cookies I use
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.
Persistent cookies: is stored as a file on your computer and it remains there when you close your 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.
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 your website cannot be provided. These cookies do not gather information about you that could be used for marketing. These cookies also don’t remember where you have been on the internet.
Performance cookies: these cookies enables 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 may have requested such as viewing a video or commenting on a blog post. The information these cookies collect is usually anonymized.
My site uses analytical services provided by Google. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling me to better understand how people uses the site. This, in turn, enables me to improve my site and the products and services offered through it.
You don’t have to allow me to use the cookies and services offered through it, however whilst my use of them does not pose any risk to your privacy or your safe use of my site, it does enable me to continually improve the site, making it a better and more useful experience for you.
SUMMARY OF YOUR RIGHTS UNDER GDPR
Under the GDPR, you have
• the right to request access to, delete of or correction of, your personal data held by me
• the right to complain to a supervisory authority
• be informed of what data processing is taking place
• the right to restrict processing
• the right to data portability
• object to processing of your personal data
• rights with respect to automated decision-making and profiling
If you have any questions about my site or these policies, please contact me via email on email@example.com. Please ensure that your query is clear, particularly if it is a request for information about the data I hold about you (under section “What rights do you have over your data”).
I recommend that you check this page regularly to keep up-to-date.