Privacy Notice

INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.incompass-coaching.com

Maria Earle-Gal is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

If you need to email us about anything related to this privacy notice, you can email us at info@incompass-coaching.com or you can write to us at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

If any of your personal information changes, please email us at the above email address and let us know how it has changed. From time to time we may email you to check that the personal data we hold for you is accurate and up to date.

WHAT PERSONAL DATA WE COLLECT ABOUT YOU

We may collect the following data about you:

Your name
Your email address
Your address
Your phone number
Your date of birth
Your business name
Your financial details
Any personal data you post on our website
Data about how you use our website
Technical data such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website
Your marketing and communication preferences
Any other information that you directly provide to us whether through our contact form, over the phone, by email or otherwise, such as when entering a competition or completing a survey
Photographs of you at events
CV and application forms
Credit information from third parties

HOW WE MAY USE YOUR DATA

We will use your data in order to:

Process financial transactions to enable you to purchase our goods our products or services
Send you customer communications about enhancements to products or services you have bought
Enable us to perform a contract with you and process orders, respond to enquiries related to the order and deal with complaints
Reply to any enquiries you make about our products or services
Send you marketing communications where we are allowed by law to do so
Personalize your experience on our website
Monitor the use of our website and online services
Ask you to complete surveys or invite you to enter into competitions or prize draws
Keep records of orders placed and communications in relation to such orders
Keep records of communications
Analyse your use of our website and other online services
Administer and protect our business and website
Deliver relevant website content and advertisements to you
Understand the effectiveness of our advertising
Carry out credit checks
Bring legal claims against you if you breach a contract or fail to make payment
Comply with any legal obligations we are subject to or as required by a government authority
Obtain or maintain insurance policies
Manage our business
Obtain professional advice

OUR LAWFUL GROUND OF PROCESSING

Under the UK General Data Protection Data Regulations, we are only legally able to process your personal data if we have a lawful ground for doing so.

Our lawful grounds of processing are:

In relation to Customer Data that we have obtained in relation to you placing an order with us that we hold for the purpose of fulfilling that contract, informing you about updates to the product or service and keeping records of the contract, the processing is necessary for the performance of a contract to which you are subject and for our legitimate interests in informing you about updates to the product or service, record keeping and to establish, pursue or defend legal claim as responsible business operations
In relation to Prospect Data that we have obtained when you enquired about our products or services (whether that be through our website or otherwise) and that we process in order to reply to your enquiry and keep records of this, the processing is necessary in order to take steps at your request prior to entering into a contract and for our legitimate interests in record keeping and to establish, pursue or defend legal claim
In relation to Prospect Data that we have obtained when you signed up for any of our free resources and that we process in order to send you those free resources, reply to your communications about the resources and to keep relevant records, you have given consent to the processing for the purposes of us sending you the free resource and it is in our legitimate interests to reply to your communications and to keep records for our business.
In relation to Marketing Data that we have obtained when you told us your marketing preferences, when you consented to us sending you details of our products and services, for the purposes of us sending you marketing communications, enabling you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising, the processing is necessary for our legitimate interests which in this case are to study how customers and users use our products/services, to develop them, to grow our business and to decide our marketing strategy.
In relation to User Data that we have obtained through cookies on our website or other online services for the purposes of operating our website, ensuring relevant content is provided to you, ensuring the security of our website, maintaining back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business, the processing is necessary for the purposes of our legitimate interests which in this case are to enable us to properly administer our website and our business.
In relation to Technical Data (that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website), we process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
In relation to your data that we process in order to comply with legal requirements or as required by a government authority, the processing is necessary for compliance with a legal obligation to which we are subject.
In relation to keeping records, this processing is either necessary for compliance with a legal obligation that we are subject to or for our legitimate interests in responsible business operations or defending, pursuing or establishing a legal claim.
In relation to obtaining professional advice and insurance, this processing is necessary for our legitimate interests in order to protect and grow our business.

We 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, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We do not collect any information about criminal convictions and offences.

We do not carry out automated decision making or any type of automated profiling.

HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

We may receive data from third parties such as analytics providers such as Google based outside the UK, advertising networks such as Facebook based outside the UK, such as search information providers such as Google based outside the UK, providers of technical, payment and delivery services, fraud detection agencies and data brokers or aggregators.

We may also receive data from publicly availably sources such as Companies House and the Electoral Register (or their equivalents) based inside or outside of the UK.

MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may only send you email or text marketing communications 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.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at info@incompass-coaching.com We also have unsubscribe buttons on the bottom of all of our emails.

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, warranty registrations etc.

DISCLOSURES OF YOUR PERSONAL DATA

We 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 lawyers, bankers, accountants, auditors and insurers.
Government bodies that require us to report processing activities or otherwise disclose your personal data.
Market researchers and fraud prevention agencies.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We are subject to the provisions of the UK General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

We may transfer your personal data to countries that the United Kingdom authorities have approved as providing an adequate level of protection for personal data by; or
If we use US-based providers that are part of a privacy framework (such as the successor to the US Privacy Shield), we may transfer data to them, as they have equivalent safeguards in place; or
Where we use certain service providers who are established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the United Kingdom authorities which give personal data the same protection it has in the UK.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, 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 us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we 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 portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@incompass-coaching.com

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 or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

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.

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). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

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