8 June 2020
Who are we
This policy covers Coaching Confidential which is a trading name of Amano Marketing Ltd
Registered address: Enterprise House, Beeson’s Yard, Bury Lane, Rickmansworth, Herts. WD3 1DS
Data Controller: Andrea McKay, Director
Phone 07724 406667
We wish to provide you with a choice of the information you receive and will request your consent to use your identity, title, organisation type, usage and profile data to share products and services that may be of interest to you. You can ask us not to use your data for marketing by
- not ticking the relevant boxes on our forms
- advising us at email@example.com
- clicking the link at the bottom of any email we send you.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase or part of the product/service experience.
We will never sell or rent your data.
What we may collect
We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the EU Regulation 2016/679 General Data Protection Regulation (“GDPR”) and the law.
We will only process your personal data if at least one of the following applies:
- you have given consent to the processing of your personal data for one or more specific purpose.
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract.
- processing is necessary for compliance with a legal obligation to which we are 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.
We require some personal data to be shared for the effective provision of our services and failure to do so may restrict the level of services that can be provided.
- Personal data may include
- first and last name, username, gender
- title, company name
- personal address, company address, billing address
- telephone numbers and email address
- details about payments made to and from you and details of products and services you have purchased from us
- Number of hours coached and payment terms
- Any correspondence between us including invoices
- Any meeting notes made to provide services
- Any notes made during the provision of coaching services or in relation to the services provided.
- Any photography taken in workshops and programmes that may show multiple attendees. In attending workshops, attendees agree to the use of photography on coachingconfidential.co.uk or amanomarketing.co.uk and social media.
- Marketing and communication data including your preferences in receiving marketing from us.
- We do not actively collect special categories of personal data about you (this includes ethnicity, race, religious or philosophical beliefs, sexual orientation, political opinions, health) We may however become aware of such data through the provision of coaching services.
- Details of your visits to our site, pages viewed and the resources you used
- Comments made on our blog posts or social media.
- Information about your computer (e.g. your IP address, browser, operating system, technology you use to access this website, referring site, time, date and length of usage and location) for system administration, usage trends and to report aggregate (non-personal) information for internal use or other lawful purposes.
Personal data of children:
Our website, resources and services are targeted at persons over the age of 18. By providing us with your data, you warrant to us that you are over 18 years of age. Should it become apparent that we are holding data of someone under the age of 18, the information will be deleted immediately.
How we collect data
- We collect information about you when you are filling in online forms or by email, phone or post. You may provide us with personal data when you
- complete an enquiry form on the website,
- when you request information on our programmes, services, newsletters and other marketing communication,
- complete a quiz, survey, poll or competition,
- give us feedback or contact us,
- during the provision of coaching services.
- When provided by your company to carry out coaching services effectively
- Via cookies. Cookies are files placed on your computer to collect standard internet log information and visitor user information. This information is used to track visitor uses for the website and provide statistical reports on website activity and help us provide the best experience to you whilst visiting our site and inform our marketing strategy. This does not include personal data about you.
You can remove cookies from your browser and you can check with your browser provider how to do this. Deleting cookies in a few cases may mean some of our features do not function.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- analytics providers such as Google based outside the EU;
- advertising networks such as Facebook based outside the EU
- Identity and Contact Data from publicly availably sources such as LinkedIn based outside the EU, Companies House and the Electoral Register based inside the EU.
Unfortunately, the transmission of data via the internet cannot be completely secure and any transmission is at your own risk.
How we use what we collect
We use information about you to:
- Present site content effectively to you.
- To provide information, make suggestions and recommendations to you about goods or services that may be of interest to you
- Carry out our contracts with you
- Carry out company administration, accounting and auditing including sharing with professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
We may contract with third parties to supply services to you on our behalf. These may include search engine facilities, advertising and marketing agencies. In some cases, the third parties may require access to some or all of your data. These are the third parties that may have access to your information:
- Mailchimp (data management and email services)
- Modern Methods Marketing which operates WBECS.com and AccessCoach (Quiz)
We make every effort to ensure that third party providers process your data for specific purposes and in accordance with our instructions.
We are allowed to disclose your information in the following cases:
- We can disclose it to other businesses in our group, namely Amano Marketing Ltd.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties to whom we sell, transfer, or merge parts of our business.
Where we store your data
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
How long will we hold your data
- We will only hold personal data relating to a client and/or coachee as long as reasonably necessary to complete the coaching services provided, including any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if you have clearly indicated you may wish to have further coaching services provided within 12 months of the completion of the contracted coaching services.
- ICF (International Coaching Federation requires us to hold a coaching log for the purposes of accreditation which includes contact details, coachee details, dates of coaching programme, number of hours and whether it is paid or pro bono work. This data will not be disclosed to the ICF however should an audit be carried out, Coaching Confidential may contact the commissioning party to verify the coaching hours. When this audit is passed/concluded or a coaching log is no longer required, its contents will be deleted.
- In some cases, we may anonymise personal data (so it no longer is associated with you) for research or statistical information or in use within case studies in which case we may use this information indefinitely without further notice to you.
In any event, we will conduct a review every 24 months to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
Access and changes to the information we hold
- You have a right to request a copy of the information that we hold about you. If you would like a copy of this information please email firstname.lastname@example.org. Please allow one month for us to handle your request. There is no fee for this service unless the request is unfounded, repetitive or excessive in which case we will request a reasonable fee or could refuse to comply with your request.
- Please keep us up to date if any of your data changes during your relationship with us
- Changes to your name, address or preferences may be made by emailing email@example.com or by clicking the link at the bottom of any email we send you.
Further security checks may be made to ensure your personal data is not disclosed to any person that does not have a right to receive it.
All coaching services will be paid for with bank transfers. No credit card information will be used or stored.
Coaching Confidential is committed to handling sensitive data with care, confidentiality and information security. We use computer safeguards such as firewalls and restricted access to paper files.
Changes to this policy
We regularly review the contents of this policy and will place any updates on this webpage.
Updated: 8th June 2020
How to contact us