- We are the "data controller" of your personal data. This means that we determine the purposes for which, and the manner in which, the personal data we collect is processed.
Name: Dave Thompson FOA: Trust Keith (DPO)
Email address: firstname.lastname@example.org
Postal address: 6 New St Square, New Fetter Ln, London EC4A 3BF
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.
The Data we collect
We may collect the following personal data about you:
- Identity Data: including your name; date of birth/age; gender; username or similar identifier, job title and profession;
- Contact Data: including your email addresses;
- Demographic Data: such as your region, preferences and interests;
- Feedback Data: information you provide about your experiences;
- Technical Data: including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this Website; and
- Marketing and Communications Data: including information about your marketing preferences.
Other than where you have provided your express consent for us to use your feedback in relation to your use of the services and how this has impacted your health, we do not collect any 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). Nor do we collect any information about criminal convictions and offences.
This Website is not intended for children and we do not knowingly collect data relating to children.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a relationship we have with you, and you fail to provide that data when requested, we may not be able to perform the services we are to provide to you.
How we collect Data
We may collect your personal data from you when you:
- contact us through the Website, by telephone, post, e-mail or through any other means;
- when you register with us and set up an account;
- when you complete surveys or provide feedback that we use for research purposes (although you are not obliged to respond to them);
- when you elect to receive marketing communications from us;
- when you use services we provide;
- when we run events.
we may collect personal data about you from the following third parties:
- your employer/the entity which grants you access to our services;
- Simplybook.me, when you booking sessions and other third parties where feedback is provided;
We may collect personal data through automated technologies or interactions:
- when you visit the Website. This information helps us to make improvements to Website content and navigation.
- we will collect your personal data automatically via cookies, in line with our [cookies policy].
Our use of personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an express opt-in or soft-opt-in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
Who we share Data with
We may share your personal data with the following third parties:
- approved practitioners who provide services on our behalf;
- third party service providers, such as IT providers or third party resources ;
- our professional advisers acting as processors or joint controllers including our DPO, lawyers, accountants and insurers;
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets and therefore would require this information to continue the business. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;
Keeping Data secure
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 the following technical and organisational measures in place to safeguard your personal data:
- 2FA is used on all of our systems where applicable.
- Our booking, scheduling and payment system is ISO 27001 compliant. Furthermore, the privacy of all internet communication between users and our customers and our system is secured by TLS 1.2.
- access to your account is controlled by a password and a username that is unique to you.
- we store your personal data on secure servers.
- payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
If you suspect any misuse or loss or unauthorised access to your personal data, please let us know immediately by contacting us via this email address: email@example.com.
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.
You have the following rights in relation to your personal data:
- Right to access - the right to request copies of the information we hold about you at any time. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct - the right to have your personal data rectified if it is inaccurate or incomplete.
- Right to erasure - the right to request that we delete or remove your personal data from our systems. 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.
- Right to 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: (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.
- Right to data portability - the right to request that we move, copy or transfer your personal data.
- Right to object - 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.
- Withdraw consent at any time- where 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.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your personal data, please contact us via: firstname.lastname@example.org.
Links to other websites
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.