Privacy Policy

About this Policy

Coaching Focus Ltd is fully committed to protecting yourpersonal data.

This notice explains how we use the personal data we hold,including the personal data we collect when you use our websites.

This notice also explains your privacy rights and how thelaw protects you including how we comply with the General Data ProtectionRegulation and other legislation that relates to the use of personal data.

It is important that you read this privacy notice togetherwith any other statements or fair processing notices we may provide on specificoccasions when we collect or process personal data so that you are fully awareof how and why we are using your data.

We also operate cookies on our websites and informationabout that is provided separately in our Cookies Policy.

1. Data Controller

Coaching Focus Ltd is the data controller and is responsiblefor the use of your personal data.

Our full details are set out below.

2. Your Obligations

It is important that the personal data we hold about you isaccurate and current. Please keep us informed if your personal data changesduring your relationship with us.

If you provide us with personal data about any other person,for example any other individuals within your organisation, then you mustensure that you have their consent to pass those details to us and for us touse those details in accordance with this privacy notice. You should also makesure that you bring this privacy notice to their attention.

3. Third-party Links

Our websites may include links to third-party websites, suchas our X(Twitter), Facebook and LinkedIn social media pages. Clicking on thoselinks may allow third parties to collect or share data about you. We do notcontrol these third-party websites and are not responsible for their use ofyour data. You should read any privacy notices on their websites carefully.

4. Data We Collect About You

Personal data means any information about an individual fromwhich that person can be identified. It does not include data which has been anonymisedsuch that a person’s identity is removed.

The following information explains the types of personaldata which we collect, use, store and transfer.

We will only use your personal data as the law allows us to.The categories of personal data that we use are listed below with examples ofthe data included:

  • Identity     and Contact Data such as names, titles and other identifiers     together with address, email address and telephone numbers.
  • Technical     Data including internet protocol (IP) address, your login data,     browser type and version, browser plug-in types and versions, access     times, operating system and platform and other technology on the devices     you use to access our websites. This may also include information about     how you use and interact with our websites.
  • Profile     Data such as username, password details, role information and     your interests or preferences.
  • Marketing     and Communications Data which includes preferences in receiving     marketing from us and your communication preferences.
  • Financial     Data such as bank account or card payment details if you make a     purchase from us.

5. How is Your Personal Data Collected?

Most of the personal data we hold is provided directly byyou, for example, by email, over the phone, or by using our websites (some ofthe technical data which we collect may be collected automatically as youinteract with our websites, for example, via the use of cookies and similartechnologies). Sometimes your data is provided by your organisation, forexample, when they ask us to give you access to our Coaching Resource Hub.

We may also obtain your data from third parties or publiclyavailable sources, such as marketing database providers.

6. Reasons For Processing

We may process your personal data for our legitimatebusiness purposes (or those of our group companies), such as to:

  • Deliver     our products and services;
  • Administer     our websites including troubleshooting, data analysis, testing, system     maintenance and support so that we can provide, enhance, personalise or     otherwise improve our websites and the products and services we offer, and     for network security;
  • Better     understand how people interact with our websites or products;
  • Improve     the effectiveness of promotional campaigns and advertising;
  • Provide     you with marketing communications such as our newsletter or other emails     about our products and services;
  • Assess     and where appropriate, deal with your application, if you express an     interest in working for us;
  • Ensure     our third-party providers can perform their obligations to us; and
  • Gather     your feedback on our products and services.

We always carefully consider your interests and yourpersonal information rights before doing this.

If you have any concerns about us processing your personalinformation for these reasons, you have the right to object.

In other circumstances, such as for certain marketingactivities, we will only use your personal data where you have provided yourconsent for us to do so. You can withdraw your consent at any time.

If you are a consumer, we may process your financial data toadminister your payment so that we can provide our services to you. This isnecessary for the performance of the contract that will be in place between us.

In addition, we may disclose information about you to theextent that we are required to do so by law or for the purpose of legalproceedings or prospective legal proceedings, in order to establish, exerciseor defend our legal rights (including providing information to others for thepurposes of fraud prevention) and where we may otherwise do so in accordancewith applicable data protection legislation.

7. Change of Purpose

We will only use your personal data for the purposes forwhich we collected it, unless we reasonably consider that we need to use it foranother reason and that reason is compatible with the original purpose. Pleasealso note that we may process your personal data without your knowledge orconsent, in compliance with the above rules, where this is required orpermitted by law.

If you would like further information about how we usepersonal data and the purpose which we might use it for, please contact ususing the contact details set out below.

8. Research and Development

If you volunteer to participate in market research projectsbeing undertaken by us or our group companies, this will involve us processingyour personal data.

Typically, this will be personal data such as your name,email address, age, job role and details regarding your education. Any personaldata you share for the purpose of your participation will only be accessible tomembers of the team who are involved in market research activities. We may alsouse third parties to support our market research activities, such as hostingonline surveys or for technical support. Personal data will only be shared withthird parties to the extent necessary to fulfil these contracted services. Wedo not allow third parties to use your personal data for their own purposes.

9. Children

We do not knowingly collect personal information relating tochildren under the age of 16. If you are a parent or guardian of a child underthe age of 16 and think that we may have information relating to that child,please contact us. We will ask you to prove your relationship to the child, butif you do so you may (subject to applicable law) request access to and deletionof that child’s personal information.

10. Disclosure of Your Personal Data

We may disclose personal data to:

  • Third     parties we use to help deliver our products and services to you, such as     payment service providers;
  • Other     third parties we use to help us run our business, such as marketing     agencies, website hosts, customer relationship and sales platform     providers, survey tool providers and website analytics providers;
  • Our     professional advisors (such as lawyers and other advisors), in which case     the recipient of the information will be bound by confidentiality     obligations; and
  • Law     enforcement agencies, courts, tribunals and regulatory bodies to comply     with our legal and regulatory obligations.

In these circumstances your personal data may be transferredoutside the UK and the European Economic Union (UK & EEA). Whenever wetransfer your personal data outside the UK & EEA, we ensure a similardegree of protection is afforded to it by ensuring that at least one of thesafeguards permitted by law is in place.

We require all third parties to respect the security of yourpersonal data and to treat it in accordance with the law. We do not allow ourthird-party service providers to use your personal data for their own purposesand only permit them to process your personal data for specified purposes andin accordance with our instructions.

11. Data Security

We have put in place appropriate security measures toprevent your personal data from being accidentally lost, altered, disclosed orused or accessed in an unauthorised way. In addition, we limit access to yourpersonal data to those employees, agents, contractors and other third partieswho have a business need to know it. They will only process your personal dataon our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspectedpersonal data breach and will notify you and any applicable regulator of abreach where we are legally required to do so.

12. Data Retention

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

To determine the appropriate retention period for personaldata, we consider the amount, nature, and sensitivity of the personal data, thepotential risk of harm from unauthorised use or disclosure of your personaldata, the purposes for which we process your personal data and whether we canachieve those purposes through other means, and the applicable legalrequirements.

In some circumstances, we may anonymise personal data (sothat it can no longer be associated with you) for research or statisticalpurposes in which case we may use this information indefinitely.

13. Your Legal Rights

Under certain circumstances, you have rights under dataprotection laws in relation to your personal data. Please contact us if youwould like to exercise any of them.

You have the right to:

  • Request     access to your personal data (a “subject access request”). This means you     can receive a copy of the personal data we hold about you.
  • Request     correction of your personal data: This enables you to have any incomplete     or inaccurate data we hold about you corrected, though we may need to     verify the accuracy of the new data you provide to us.
  • Request     erasure of your personal data. You can ask us to remove personal data     where there is no good reason for us continuing to process it. You also     have this right where you have successfully exercised your right to object     to processing, where we may have processed your data unlawfully or where     we are required to erase your personal data to comply with law. We may not     always be able to comply with your request where there are particular     legal reasons.
  • Object     to processing of your personal data where we rely on a legitimate interest     basis and if the processing impacts on your fundamental rights and     freedoms. You can also object to direct marketing. In some cases, we may     demonstrate that we have grounds to process your data which override your     rights and freedoms.
  • Request     restriction of processing. You can ask us to suspend the processing of     your personal data: if you want us to establish the data’s accuracy; where     our data use is unlawful but you do not want us to erase it; where you     need us to hold the data even if we no longer need it, to establish,     exercise or defend legal claims; or you have objected to use of data but     we need to verify whether we have overriding legitimate grounds to use it.
  • Withdraw     consent at any time where we rely on consent to process your personal     data. This will not affect the lawfulness of processing carried out before     you withdraw your consent.

You also have the right to lodge a complaint with theInformation Commissioner’s Office (ICO).

14. Contact Us

If you have any questions about this privacy notice,including any requests to exercise your data privacy rights, please contact ourcustomer support team:

Emailenquiries@coaching-focus.com

Address: Coaching Focus Ltd, Ada House, Pynes Hill, Exeter, Devon, EX25AZ.