Effective date: 1st December 2021
Leah Tomlin Executive Coaching (“we”, “us” and “our”) respects your privacy and is committed to taking reasonable steps towards protecting your privacy online and managing your information responsibly, in order to best understand the products and services that are most useful to you.
Leah Tomlin Executive Coaching is keen to strike a fair balance between your personal privacy and ensuring that you obtain full value from the services it provides, while ensuring that it complies with all protection the Data Protection Act ('the Act') and the General Data Protection Regulation (‘GDPR’) affords to you. We will hold your personal data securely in accordance with the Act, under which it is fully registered and the GDPR. The GDPR protects the rights of individuals by setting out certain rules as to what organisations can and cannot do with information about people. A key element to this is the principle to process individuals’ data lawfully and fairly. In order to meet the fairness part of this we need to provide information on how we process personal data.
How we collect Personal Data
We may collect personal data from Users in a variety of ways, including, but not limited to, when Users visit our site, purchase a service, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site (or on other websites that we operate or from other services that we provide). Users may be asked for, as appropriate: name, email address, occupation, mailing address, phone number. Users may, however, visit our Site anonymously. We will collect personal data from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal identification information; however, this may prevent them from engaging in certain Site related activities.
We may automatically log information about you, your computer or mobile device, and your activity occurring on or through the Sites, such as:
Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing our site, and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
How do we use your data?
We use information about you in the following ways:
To provide our coaching services
To provide customer care, including responding to your requests if you contact us with a query
To provide you with information about our services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
To enable us to review, develop and improve the website and services
To administer accounts, process payments and keep track of billing and payments
To notify you about changes to our website and services;
We will keep your personal data for the duration of the period you use Leah Tomlin Executive Coaching services. We shall retain your data only for as long as necessary in accordance with applicable laws.
Who has access to your personal data?
We process your data for administration, support and the provision of services. For the avoidance of doubt, we do not and never shall sell your personal data to third parties for marketing or advertising purposes. We may pass your personal data to third parties for the provision of services on our behalf (for example processing your payment). However, we will only ever share information about you that is necessary to provide the service and we have specific agreements in place, which ensure your personal data is secure and will not be used for any marketing purposes. We may share your personal data if we are under a duty to disclose data in order to comply with any legal obligation or to protect the rights, property, or safety of Leah Tomlin Executive Coaching, our customers or others.
Other uses of Personal Data
For research and development. We may use your personal information for research and development purposes, including analysing and improving the Service and our business.
To create anonymous data. We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including analysing and improving the Service and promoting our business.
To comply with laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorised, unethical or illegal activity, including cyber attacks and identity theft.
With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Leah Tomlin Executive Coaching aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at [email protected] indicating “GDPR Privacy Rights” in the subject field of your email.
In certain circumstances, you have the following data protection rights:
The right to access, update, or to delete the information we have on you. We will give you access to review, update or request the deletion of your Personal Data should you request that of us, see contact information above or at the bottom of the page, and we will be happy to assist.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Leah Tomlin Executive Coaching relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Links to other sites
Leah Tomlin Executive Coaching may provide links to third party sites. Since we do not control those websites, we encourage you to review the privacy policies of these third party sites. Any information that is supplied on these sites will not be within our control and we cannot be responsible for the privacy policies and practices of these.
Where we store your personal data
We follow accepted ISO standards to store and protect the personal data we collect, including the use of encryption if appropriate. All information you provide to us is stored on our secured servers within the EEA.
Handwritten notes taken during coaching sessions are stored in a private cabinet.
We agree to take reasonable measures to protect your data in accordance with applicable laws.
In the event of a data breach, we shall ensure that our obligations under applicable data protection laws are complied with where necessary.
Your right to make a complaint
For more information about your rights, visit the Information Commissioners Office’s (ICO) website https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You have the right to make a complaint about how we process your personal data to the Information Commissioner: https://ico.org.uk/concerns/
Please e-mail any questions or comments you have about privacy to us at [email protected]