1.1ActionCOACH is committed to safeguarding the privacy of our website visitors and customers/guests.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of (our website users and retreat guests), in other words, where we collect personal data of any kind.
1.4 In this policy, “we”, “us” and “our” refer to ActionCOACH Marlene Powell the company.
2. How we use your personal data
2.1 In this Section we have set out:
· (a) the categories of personal data that we may process
· (b) the purposes for which we may process your personal data
· (d) the legal bases of the data processing
2.2 We may process data about your use of our website https://marlenepowell.actioncoach.com/and services (usage data). This usage data may include the following: your IP address, your geographical location, browser type and version, operating system, length of website visit, referral source, page views and website navigation, as well as information about timing, frequency and the pattern of your service use. The source of the usage data is our website analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is so that we may monitor and improve the user experience of our website and our services.
2.3 We may process your (booking data) which may include your name and email address. The source of this booking data is you (upon booking a service with us). This data may be processed for communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.4 We may process your personal information included in your booking on our website (“profile data”). The profile data may include the following: your name, address, telephone number, email address, gender, date of birth. The profile data will be processed for the purposes of providing you with the best possible experience when using our service. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.5 We may process information contained in any enquiry or email you submit to us regarding our services (“enquiry data”). The enquiry data may be processed for the purposes of modifying our website information to ensure better user experience and clearer information. The legal basis for this processing is to improve user experience.
2.6 We may process information relating to transactions, including purchases of our services and paying balances (making donations) through our website (“transaction data”). This transaction data may include the following: your contact details, your card details and the details of the transaction itself. The transaction data may be processed for the purpose of fulfilling the booked services and keeping proper transaction records. The legal basis for this processing is the deliverance of services and proper administration of our website and business.
2.7 We may process information that you provide to us for the purpose of subscribing to our email updates and/or newsletter (“notification data”). The notification data may be processed for the purposes of sending you the relevant updates regarding your retreat and/or newsletters (if subscribed). The legal basis for this processing is consent.
2.8 We may process information relating to any communication that you send to us via our website or directly via email (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. (When using the website contact forms, our website will generate the metadata associated with any communications made.) The correspondence data may be processed for the purposes of communicating with you and your party and accurate record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with guests/subscribers.
2.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of any legal claims against ActionCOACH or it’s partners, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, specifically the protection and assertion of our legal rights, your legal rights and the legal rights of all others involved.
2.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance, managing associated risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, specifically the proper protection of our business (and our guests) against risks.
2.11 In addition to the above specific purposes for which we may process your personal data set out in this Section 2, we may also process your personal data where it is necessary for compliance with a legal obligation to which we are subject, or in order to protect yours or other guests/customers vital interests.
2.12ActionCOACH asks that you do not supply any other person’s personal data to us, unless we prompt you to do so (for example when booking an service).
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers where it is deemed reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing associated risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out of court procedure.
3.2 We may disclose your booking data to third party activity providers, hotels or subcontractors insofar as reasonably necessary for your participation in an service being provided by ActionCOACH.
3.3 Financial transactions relating to your booking through our website are almost always handled by our nominated payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your deposits, and payments, refunding payments and for dealing with complaints or queries relating to payments and refunds.
3.4 In addition to the specific disclosures of personal data mentioned in this Section 3, we may disclose your personal data where it is necessary for compliance with a legal obligation to which we are subject, or in order to protect yours or any other parties vital interests. We may also disclose your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out of court procedure.
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with legal obligations in relation to the retention and deletion of your personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that particular purpose or those purposes.
4.3 We will retain your personal data as follows: 4.3.1 All data collected shall be retained at least until the end of your booked retreat and following for a maximum of 2 years after your booked retreat.
4.4 Not withstanding the other provisions of this Section 4, we may retain your data where such retention is necessary to comply with a legal obligation to which we are subject, or in order to protect yours or another parties’ vital interests.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3 We may notify you of changes to this policy by email.
6. Your rights
6.1 In this Section 6, we have summarised your rights under data protection law. Some of the rights are complex, and not all the details have been included in our summary. You should therefore read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2 Your principal rights under data protection law are:
· (a) the right to access;
· (b) the right to rectification;
· (c) the right to erasure;
· (d) the right to restrict processing;
· (e) the right to object to processing;
· (f) the right to data portability;
· (g) the right to complain to a supervisory authority; and
· (h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether we process your personal data and, where we do, access to this personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. To obtain a copy of your personal data simply email us at firstname.lastname@example.org and we will begin the process of supplying this data to you.
6.4 You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data. Those circumstances include: the personal data is no longer necessary for the purposes of which it was collected or otherwise processed, you withdraw consent to consent-based processing, you object to the processing under certain rules of applicable data protection law, the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information, for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances include: you contest the accuracy of the personal data, processing is unlawful but you oppose erasure, we no longer need the personal data for the purposes of our processing but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose immediately.
6.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.10 To the extent that the legal basis for our processing of your personal data is:
· (a) consent; or
· (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.11 If you believe that our processing of your personal information infringes data protection laws, you are legally within your right to lodge a complaint with a supervisory authority responsible for data protection in your jurisdiction.
6.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.13 You may exercise any of your rights in relation to your personal data by written notice to us.
7. About cookies
7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by that browser. The identifier is then sent back to the server each time the browser requests a page from the server.
7.2 Cookies may be “persistent” cookies or they may be “session” cookies. A persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before this expiry date. A session cookie on the other hand, will expire at the end of the user session, when the web browser is closed.
7.3 Cookies do not typically contain any information that would personally identify a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
8. Cookies that we use
9. Cookies used by our service providers
10. Managing cookies