Updated 21 May 2018

PURPOSE OF THIS PRIVACY POLICY

We are committed to protecting your personal information and to being transparent about the information we hold about you. Using personal information allows us to service and develop a better understanding of our clients, and in turn to provide you with relevant and timely information about the work that we do.

The purpose of this policy is to give you a clear explanation about how we collect and process your personal information through your use of our website, including any data you may provide through this website and when you sign up to our newsletter, download material or buy our services.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information. This privacy policy supplements our other policies and is not intended to override them.

We will use the information that we collect about you in accordance with:

The Data Protection Act 1998
The Privacy and Electronic Communications (EC Directive) Regulations 2003
The EU General Data Protection Regulation (Regulation EU 2016/679), (‘GDPR’) which becomes effective from 25 May 2018

This policy explains:

Who we are
Information we may collect about you
How we collect your data
How we may use your information
Disclosure of your details to third parties
Security of your personal information
Data retention
Your legal rights
Notification of changes to our privacy policy
Contact details and further information

If you have any questions, please contact the Data Controller at Alchemy Business Coaching Limited using the contact details at the end of this policy.

1. WHO WE ARE

Alchemy Business Coaching Ltd is a privately owned company registered in England and Wales, number 7270950. We also use the trading names Alquimia Coaching and Development and Confident in 90 Days.

Our income comes from selling our coaching programmes and packages, training courses and workshops to companies and individuals.

2. INFORMATION WE MAY COLLECT ABOUT YOU

Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

We may collect, use, store and transfer different kinds of personal information 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, date of birth and
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey
Usage Data includes information about how you use our website, products and
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication This also includes us making a note of conversations we have had with you in person and/or communications you sent to Kiln Theatre. This helps us to manage our relationship with you and ensures you only receive communications from us that are relevant and timely.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

In delivering our coaching services we may collect Special Categories of Personal Data about you (this 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, information about criminal convictions and offences.) We only collect this data if you choose to reveal it to us and only in order to allow us to deliver our coaching and training services effectively.

If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. 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.

3. HOW WE COLLECT YOUR DATA

We collect different information about you in a number of ways:

Information you give us

When you create an account on our website, buy a service or product, sign up to our newsletter, request marketing materials or give us feedback, we will store the personal information you give to us such as your name, email address, postal address, telephone number and card details. We will also keep a record of your purchases.

We will keep notes of your coaching and training sessions in hard copy and electronically. Written notes will be taken during our sessions. Afterwards, we scan these notes and store them in Dropbox or OneDrive so that we can easily find them and review them before each session. Our Dropbox and OneDrive passwords are changed frequently. The paper notes are kept securely in our office for the duration of your coaching engagement. Once the engagement is over, the paper notes are shredded, and the scanned notes are held in Dropbox or OneDrive for a maximum of 6 years, in accordance with Association for Coaching guidelines, when they will be deleted. You may have a copy of your notes at any time.

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Information from third parties

We occasionally receive information about you from third parties as set out below:

Analytics providers such as Google
Advertising networks such as Facebook or LinkedIn
Search information providers such as Google AdWords

HOW WE MAY USE YOUR INFORMATION

We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those
Where we need to comply with a legal or regulatory
Where we have your explicit consent before using your personal information in that specific situation. However, generally we do not rely on consent as a legal basis for processing your personal information and you have the right to withdraw consent to marketing at any time by contacting us. You will find the relevant contact details at the end of this

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. 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

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your purchase including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(f) Special Categories

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us and be able to coach you effectively)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing and communications with you, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to

inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing communications

We aim to communicate with you about the work that we do in ways that you find relevant, timely, respectful, and never excessive. To do this, we use data that we have stored about you, such as which services you have used in the past, as well as any contact preferences you may have told us about.

We use our legitimate organizational interest as the legal basis for communications by post and email. In the case of postal mailings, you may opt out of receiving these at any time using the contact details at the end of this policy or by updating your contact preferences in your online account with us.

In the case of email, we will give you an opportunity to opt out of receiving electronic communications during your first purchase with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we send you subsequently. Alternatively, you can use the contact details at the end of this policy or update your contact preferences in your online account with us.

As part of our service to you, we may contact you by email or telephone to provide essential information related to your purchase.

4. DISCLOSURE OF YOUR DETAILS TO THIRD PARTIES

There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:

To our service providers who process data on our behalf and on our instructions (for example our online booking software provider). We require all third parties to respect the privacy of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our
Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).

We may share anonymised personal information with other organisations, such as the Association for Coaching or the International Coaching Federation purely for the purposes of accreditation or registration of our coaches.

We do not sell personal details to third parties for any purpose.

5. SECURITY OF YOUR PERSONAL INFORMATION

Your debit and credit card information

If you use your credit or debit card to purchase from us, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). You can find more information about this standard (https://www.pcisecuritystandards.org/pci_security/). We give the option for you to store your card details safely for use in future transactions. This is carried out in compliance with PCI-DSS and in a way where none of our staff members can see your full card number. We never store your 3 or 4-digit security code.

Security of your personal information

We have put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same and that they will only process your personal information on our instructions. The third parties will also be subject to a duty of confidentiality.

We use reputable providers of cloud storage and online services and we will make every effort not to transfer, process or store your data anywhere that is outside of the European Economic Area, unless we have a contractual agreement in place that is of an equivalent standard to GDPR.

6. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

7. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows:-

1. Request access to your personal informationYou have a right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right, or any of the rights listed below. If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, i.e. the Information Commissioner’s Office.
2. Request correction of your personal informationYou have the right to request that we correct the personal information we hold about you, although we may need to verify the accuracy of the new information you provide to us.
3. Request erasure of your personal information
  You have the right to request that we delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for erasure if there are specific legal reasons- which will be notified to you at the time of your request.
4. Object to processing of your personal informationYou have the right to object to the 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 want to object to processing on this ground as you feel it 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.
5. Request restriction of processing your personal informationYou have the right to request that we suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request transfer of your personal informationYou have the right to request that the personal information we hold about you is transferred to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please 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.
7. Right to withdraw consentIn circumstances where we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. 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.

Please also note the following:-

No fee usually required

You will not have to pay a fee to access your personal information (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.

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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 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.

8. NOTIFICATION OF CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time. We will always communicate any changes to our clients where we have accurate contact details and where they would expect to receive communications from us. Please visit this section of our website periodically in order to keep up to date with changes in our privacy policy.

9. CONTACT DETAILS AND FURTHER INFORMATION

Please get in touch with us if you have any questions about any aspect of this privacy policy, and in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.

Please also contact us if you have any questions about the information we hold about you, or to change your contact preferences with us:

Email us: jackie@alchemybusinesscoaching.biz

Call us: 07485 248 353

Write to us:

Jackie Fitzgerald, Data Controller
Alchemy Business Coaching Ltd
Harwell Innovation Centre
Harwell
OX11 0EZ