March 2021

The privacy of our website visitors and clients is very important to us, and we are committed to safeguarding it. In offering an international service we endeavour to adhere to applicable data protection regulations recognising that these vary between countries and regions by following the General Data Protection Regulations (GDPR) in place in the Europeran Union.

1.0 Collecting personal information

The following types of personal information may be collected, stored, and used as poart of our services:

1. information about your computer including your IP address, geographical location, browser type and version, and operating system;
2. information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
3. information, such as your email address, that you enter when you fill in a contact page on our website;
4. information that you enter while using the services on our website;
5. information that is generated while using our website, including when, how often, and under what circumstances you use it;
6. information relating to any services you use, through our website, which includes your name, address, telephone number, email address, and credit card details;
7. information that you post to our website with the intention of publishing it on the internet, which includes your username, profile pictures, and the content of your posts;
8. information contained in any communications that you send to us by email or through our website, including its communication content and metadata;
9. in using on-line video conferencing tools for coaching, our clients sometimes request a recording of the session. Any video recordings will require specific consent which can be confirmed at the start of the recording or through the completiuon of the GDPR consent form at the attached Link
10. any other personal information that you give us.

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy

2.0 Using your personal information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:

1. administering our website and business;
2. enabling your use of the services available on our website;
3. supplying services described on our website;
4. sending statements, invoices, and payment reminders to you, and collecting payments from you;
5. sending you non-marketing commercial communications;
6. sending you email notifications that you have specifically requested;
7. sending you email newsletters, if you have requested it (you can inform us at any time if you no longer require the newsletter);
8. sending you marketing communications relating to our business (you can inform us at any time if you no longer require marketing communications);
9. dealing with inquiries and complaints made by or about you relating to our website; 10. keeping our website secure and prevent fraud;
11. verifying compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service); and
12. other uses.

3.0 Disclosing personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information;
1. to the extent that we are required to do so by law;
2. in connection with any ongoing or prospective legal proceedings;
3. in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) and
4. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

4.0 International data transfers

1. Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
2. Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China, Hong Kong SAR and India.
3. Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
4. Our coaching services are moslt offered as an on-line service using proprietary video conferencing software like Zoom or Google Meet. These platforms will have their own policies about data they track in offering these on-line facilities which can be viewed at the respective service providers web sites. The link below is for Zoom which is our most frequently used medium. https://zoom.us/terms

5.0 Retaining personal information

1. Our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.
2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. Notwithstanding the other provisions of this Section G, we will retain documents (including electronic documents) containing personal data:
- to the extent that we are required to do so by law;
- if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

6.0 Security of your personal information

1. We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
2. We will store all the personal information you provide on our password protected laptops.
3. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. laptops.

7.0 Amendments

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.

8.0 Your rights

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the following:

- the payment of a fee to cover associated costs; and
- the supply of appropriate evidence of your identity. (we will usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address).

We may withhold personal information that you request to the extent permitted by law. You may instruct us at any time not to process your personal information for use in any case studies or research. In practice, you will usually either expressly agree in advance to our use of your personal information for case studies or research purposes.

9.0 Third party websites

Our website includes hyperlinks to, and details of, third party websites. These links are provided to deliver a better user experience and the relevant sites will have their own cookie privacy policies. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10.0 Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated. We may update this Privacy Policy from time to time to reflect changes in either GDPR or to reflect other developments in data privacy practice. Any updates will be notified to our current clients.

11.0 Cookies

Our website uses cookies. 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 the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “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 the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use both session and persistent cookies on our website.

1. This web site uses Google Analytics on our website to recognize a computer when a user visits the website / track users as they navigate the website / analyze the use of the website / administer the website / prevent fraud and improve the security of the website.
2. Most browsers allow you to refuse to accept cookies the steps to do this can be found on your browser companies web site or a range of third party web sites. Blocking all cookies could have a negative impact upon the usability of this website.
3. You can delete cookies already stored on your computer and information on the steps to do this can be found on your browser companies web site or a range of third party web sites. Deleting cookies may have a negative impact on the usability of the websites.