At Effortless Coaching Practice, we value your privacy and take the security of your data seriously. This policy explains the data we collect, why we need it, and how we use it. It applies to all personal data collected from you, whether through our websites, courses, or coaching services.

'We,' ‘us,' and 'our' refer to Effortless Coaching Practice. 'User,' 'you,' and 'your' refer to website visitors, customers, and users. 'Personal information’, ‘personal data’, and ‘data' includes data you voluntarily provide, such as name, phone number, and email address. The term 'service' encompasses our various offerings, both paid and free.

By visiting this website, you consent to collecting and using your personal information as outlined in this Privacy Policy. This policy does not cover information collected by third parties or through linked applications or content.

Using Effortless Coaching Practice and its services means agreeing to this Privacy Policy without modification. The policy may be updated occasionally, and you will be notified of any changes on the website. By continuing to use the website after such changes, you agree to the revised terms.

DATA CONTROLLER INFORMATION

In certain circumstances, we may act as data controllers and data processors for your personal data.

LEGAL BASIS FOR DATA PROCESSING

Data protection laws mandate that we can only process your personal data when we have valid reasons to do so. These reasons encompass your consent, service performance, billing, and communication with you.

Our collection of personal information is solely for purposes directly related to our functions or activities under the Data Protection Act 2018 (DPA 2018), General Data Protection Regulation (GDPR), Privacy and Electronic Communications Regulations (PECR), Human Rights Act 1998, Investigatory Powers Act 2016 (IPA), and The UK ePrivacy Regulations. We gather this data only when necessary for or directly linked to those specific purposes.

TYPES OF PERSONAL DATA COLLECTED

We may collect various types of personal data from you, including:

Contact Data: Billing address, postal address, email address, and contact telephone number.
Personal Data: Title, full name, occupation, and business or employer's name.
Marketing Preferences: Information about whether you wish to receive marketing material from us.
Communications Data: Any communication you send us through contact forms, email, text, social media, or other channels.
Financial Data: The last four digits of the card used for payments or full billing information if authorised for automatic payments.
Transaction Data: Details of services purchased, dates of purchase, and prices paid.
Technical Data: Internet protocol (IP) address, log-in data, browser type, location, referral source, requested URL, operating system, and device type.
Tracking Data: Clickstream data, geographic and timestamp information, and frequency of website use.
Usage Data: Information on how you navigate our website, time spent on each page, and visit frequency.

We do not collect sensitive data, including race, ethnicity, religious beliefs, gender, age, sexual orientation, political opinions, health, genetic data, biometric data, or criminal convictions.

If we need to use your data for an unrelated purpose, we will inform you and explain the legal grounds for processing. In some cases, we may process your data without your explicit consent if required or permitted by law.

PURPOSES OF DATA PROCESSING

We process your personal data for marketing communications based on your consent or our legitimate interests, aiming to grow our business to serve you better.

You may receive marketing communications from us if you have purchased, requested information about our goods or services, or agreed to receive such communications without opting out.

In general, we do not solely rely on consent for processing your data; we use your information in various lawful ways, such as:

Performing agreements with you.
Providing customer care and responding to your queries.
Communicating with you and maintaining records using the email address you provide as the primary method for communication.
Offering information about events or services you may be interested in with your consent.
Enabling your use of website services.
Administering accounts, processing payments, and managing billing.
Informing you of service and price changes, offering giveaways and bonuses, and running promotions or contests.
Protecting your vital interests, legitimate interests, and fundamental rights
Providing statistical information to third parties without identifying individuals.
Complying with legal obligations and resolving enquiries or complaints related to the website.

We process your data for our and third-party legitimate interests, such as administering and securing the website, protecting our business and legal claims, notifying you about website changes and services, improving targeted marketing, and enhancing the user experience through data analytics on our websites.

If you submit personal information for publication on our website, we will use it according to the granted license.

HOW WE COLLECT YOUR DATA

We collect data about you through various means.

You can provide data directly by filling in forms on our website, registering for coaching, purchasing a course, or contacting us via phone or email.

Additionally, we gather information when you sign up, participate in competitions, promotions, or surveys, place an order, subscribe to our email, or inform us about any other matter. If you provide us with personal data about a third party, you must have obtained their express consent for disclosure and use.

If your employer engages us to provide coaching to you or your coworkers, we may receive contact and identity data about you directly from your employer. In such cases, we will only use the data to contact you about our services.

As you interact with our websites, we automatically collect tracking data, technical data, and usage data about your device, browsing actions, and patterns using cookies, server logs, and similar technologies.

Users can visit our website anonymously, and we will only collect personal identification information if voluntarily submitted. Users have the option to refuse to provide personal identification information, except if it affects certain website-related activities.

Furthermore, we may receive data from third parties such as analytics providers like Google, advertising networks like social media, and technical, payment, and delivery service providers.

DATA SHARING

We are committed to protecting your privacy and will never share, disclose, sell, rent, or provide your personal information to other companies for their marketing purposes. However, we may share generic aggregated demographic information not linked to personal identification with trusted affiliates, business partners, and advertisers for the abovementioned purposes.

Please be aware that in certain situations, we may disclose your data to third parties for limited purposes, including:

Complying with applicable laws, regulations, legal processes, public authorities, or governmental requests, including national security or law enforcement requirements.
Investigating, detecting, preventing, or taking action against illegal activities, suspected fraud, safeguarding or security issues.
Carrying out legal proceedings or prospective legal proceedings to establish, exercise, or defend our legal rights.
Addressing violations of our Terms of Service or any other agreements related to our services.
Reporting potential threats to the physical safety of individuals.
Assisting in marketing, sales, and advertising campaigns.
Additionally, if we sell, transfer, or merge our business or any part of it, the new owners may use your personal data in the same manner as outlined in this Privacy Policy.

We may need to share your data with the following parties:

Service providers who offer IT and system administration services.
Professional advisers such as lawyers, accountants, bankers, auditors, and insurers.
Government bodies requiring us to report processing activities.
Payment providers.
Marketing and SEO companies and tools that assist us in promoting our business or managing activities on our behalf, such as email service providers, coaching administration software, Google, and social media, often registered outside of the UK.

We prioritise data protection and uphold strict confidentiality when sharing data with third parties. When these third parties are located outside the UK or in countries recognised as safe under data protection law, data transfers will be completed in compliance with relevant Data Protection Legislation.

In 2023, countries with an adequate level of data protection include European Union (EU) Member States, Iceland, Liechtenstein, Norway, Switzerland, Canada, New Zealand, Australia, Japan, and Uruguay.

When transferring personal data from the UK to the US, we rely on other legal mechanisms, such as Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs), to ensure compliance with UK data protection laws during data transfers. These mechanisms offer suitable safeguards to protect the rights and privacy of individuals whose data is transferred internationally, in line with UK law.

DATA SUBJECT RIGHTS

Under UK and EU data protection laws, you have several rights regarding your personal data. These rights include the right to object to our use and processing of your data, request access, correction, erasure, data portability, and the right to withdraw consent if the legal basis for processing is consent. This is also known as the 'right to be forgotten'. We honour these rights for all members of our community, including those outside the UK and EU.

It's important to note that the 'right to be forgotten' is not an absolute right and may be subject to legal, regulatory, or legitimate grounds for data retention.

If your personal information requires correction or updating, please let us know as needed. Alternatively, occasionally we may contact you to verify and update your information, including but not limited to your name, address, title, phone number, and email address.

You have the right to opt out of marketing communications. We will not contact you for marketing purposes without your prior consent. You can change your marketing preferences at any time by using links within marketing emails or contacting us directly.

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, taken programmes and courses, etc.

You will not be charged a fee to access your personal data or exercise your rights, except in clearly unfounded, repetitive, or excessive requests, where we may charge a reasonable fee or refuse to comply.

To protect your data, we may need to verify your identity and ask for further information related to your request, ensuring it is not disclosed to unauthorised individuals.

We strive to respond to all legitimate requests within one month. It may take longer in complex cases or multiple requests, but we will notify you accordingly. Please be aware that certain exceptions to these rights may apply, and while we aim to address your concerns to your satisfaction, there may be situations where we cannot fulfil your request.

If you have concerns related to data protection, you have the right to lodge a complaint with the relevant supervisory authority responsible for data protection issues.

We collect only the necessary information required to enter into a contract with you. Consent for unnecessary processing is not a condition for engaging in a contract with us. In the event of a personal data breach that risks individuals' rights and freedoms, we must notify the Information Commissioner's Office (ICO) and, in certain cases, the affected individuals.

DATA RETENTION

Generally, our data retention periods are designed to ensure we do not retain personal data for longer than necessary. While we may not always be able to specify exact retention periods in advance, we determine the retention period based on the original purpose for collecting the data, including legal, accounting, or reporting requirements.

For tax purposes, we are required by law to retain basic customer information, including Contact, Identity, Financial, and Transaction Data, for six years after the end of the relevant tax year. However, in certain circumstances, such as a complaint or the possibility of litigation, we may retain personal data related to our relationship with you for a longer period.

It's important to note that there is an exception in data protection laws that allows personal data to be retained for legal or regulatory reasons, even if an individual requests its deletion. This is known as the 'legal obligation' or 'compliance with a legal obligation' ground for processing personal data. This legal obligation to retain tax records overrides the individual's 'right to be forgotten'.

Regarding coaching sessions, all related records, including communications, print and digital documents, and data, will be retained for the duration of the coaching engagement. After the retention period has lapsed, we ensure secure disposal or deletion of the information to protect sensitive data and confidentiality.

Anonymous or anonymised information, such as website visits without identifiers, may be stored for service improvement purposes.

When determining the appropriate retention period for data, we consider factors such as the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the processing purposes, and whether these purposes can be achieved by other means. We adhere to legal requirements and ensure that personal data is not retained longer than necessary, and it is deleted or anonymised when the retention period expires and there are no longer legal grounds for processing.

DATA SECURITY

We adhere to accepted ISO standards for storing and protecting personal data. To safeguard your information, we take reasonable precautions to prevent accidental loss, unauthorised access, alteration, disclosure, or use. All data collected from you is stored in a secure environment, both technically and physically.

Online, we employ SSL encryption to protect sensitive information. Offline, we implement measures to ensure the security of user information.

In the event of a suspected personal data breach, we shall ensure that our obligations under applicable data protection laws are complied with where necessary. If required by law, we will inform you and relevant regulators about the breach.

MINORS

To access or use our coaching services, you must be 18 years old or older, possess the necessary mental capacity, and have the authority to enter into this Privacy Policy.

Please note that this website is not intended for individuals under the age of 18, and we do not knowingly collect, request, market, provide services, or sell products to children under 18 years of age.

If you are under 18, you may only use our website with the explicit permission and active involvement of a parent or legal guardian. If you are a minor, please refrain from providing any personal information to us or other website visitors, and do not use this website.

Should we become aware that we have inadvertently collected personal information from a minor under 18, we will promptly delete this information and attempt to obtain parental consent. If you suspect that we might have unintentionally gathered data from a minor, please inform us by sending an email.

By providing us with your data, you confirm that you are at least 18 years old and meet the required age criteria.

ABOUT COOKIES

Our website uses local storage, such as cookies, to enhance your browsing experience and enable specific functionalities. Cookies are small files of letters and numbers that we store on your browser or device's hard drive if you agree to it. They help us distinguish you from other website users and enable us to tailor the website to your preferences and device.

Cookies assist us in understanding our visitors better by providing insights into how users are directed to our website, the most popular pages, and the devices most commonly used to browse the website. Additionally, they track your prior visits to our website and other websites on the internet, which allows us to serve you with targeted ads.

Our website uses both 'session' cookies and 'persistent' cookies to provide a personalised experience. Session cookies keep track of your activities while navigating the website and are deleted when you close your browser. Persistent cookies, on the other hand, remain stored on your computer until deleted or reached a specified expiry date.

You have the option to adjust your browser settings to refuse all or some cookies or to receive alerts when websites set or access cookies. However, please be aware that disabling or refusing cookies may make certain parts of the website inaccessible or malfunction improperly.

We may also use Google Analytics to analyse website usage. Google Analytics employs cookies to generate statistical information about the website's use, and Google will store this data. You can find Google's privacy policy at: http://www.google.com/privacypolicy.html.

Automated tracking methods may also be used on our websites, in communications with you, and in our products and services to measure performance and engagement.

Please note that there is no consistent industry understanding of how to respond to "Do Not Track" signals, so we do not alter our data collection and usage practices when we detect such signals from your browser.

THIRD-PARTY LINKS

We may occasionally promote special offers, products, and services from third-party entities and provide links to websites owned and/or controlled by such third parties.

Please note that this Privacy Policy solely pertains to the use and disclosure of information collected from you on our website. Any other websites accessible through our website, whether via links or other means, have their own privacy policies and practices. We have no control over these third-party websites and are not responsible for their privacy policies or practices.

Our website may include links to third-party websites, plug-ins, and applications. Clicking on these links or enabling such connections might allow third parties to collect or share your data.

When you navigate away from our website, we encourage you to review the privacy notice of each website you visit. This ensures you are aware of their data handling practices and how they protect your personal information.

LIABILITY

While we implement strict procedures and security features to prevent unauthorised access, misuse, or disclosure of your information after receiving it, it is essential to recognise that no internet transmission or electronic storage method is entirely secure.

As a result, we cannot guarantee the absolute security of data transmitted to our website, and any transmission is done at your own risk. We take no responsibility for circumventing privacy settings or security measures on our website, including illegal acts committed by third parties, such as criminal hacking.

While we make every effort to protect the personal information you voluntarily share with us through our website, you acknowledge that there is a possibility that a third party may access or tamper with such information.

By using our website, you agree that we are not liable for any intercepted information shared through our website without our knowledge or permission. You release us from any and all claims related to the use of such intercepted information in an unauthorised manner.

We reserve the right to update this Privacy Policy at any time. In such cases, we will indicate the revised date at the bottom of this page. We encourage Users to check this page regularly to stay informed about how we safeguard the personal information we collect. You acknowledge and agree to review this Privacy Policy periodically and remain informed of any modifications.

Your acceptance of these terms

By using this website, you indicate your acceptance of this policy and the terms of service. If you disagree with this policy, please refrain from using our website. After posting changes to this policy, continued website use will be deemed your acceptance of those changes.

CONTACT INFORMATION

If you have any inquiries about this Privacy Policy, the practices of this website, your removal from it, or any other dealings with it, please feel free to contact us at: effortless@erinandreacraske.com. We are here to assist you and address any concerns you may have.

DATE

September 2023

PRIVACY POLICY