WHAT IS THIS?
At ATTAIN COACHING, privacy is a serious matter and we are committed to protecting it.
In accordance with the General Data Protection Regulation (“GDPR”), this policy explains when, why and how we are governed by this Regulation:
collect personal data about individuals;
use this information;
disclose this kind of data to others, when this is necessary and under certain conditions;
keep secure and confidential this personal data.
WHAT ARE THE POLICY CHANGES?
This policy may evolve over time so please check the date on this page to make sure that you have the latest version.
This policy was last updated on the 6th of June 2020.
WHO WE ARE
ATTAIN COACHING is an independent sole trader (hereafter the “Company”), the “controller” of your personal data will be the Company that decides why and how your personal data is processed.
Where this policy refers to “we”, “our” or “us” below, unless mentioned otherwise, this refers to the Company that is the controller of your personal data.
HOW AND WHAT PERSONNAL INFORMATION IS COLLECTED
We may collect and process the following personal data:
Personal data you give to us: this is information about you that you give to us, entirely voluntarily, by entering information via:
social media platforms;
corresponding with us by phone, email or otherwise.
Example: this includes information provided at the time of registering to use our websites, subscribing to the services we provide through our websites, posting material or requesting further services, managing your account online (including accessing documentation and engaging in correspondence with us by phone, email or otherwise). We may also ask you for information when you report a problem with our websites. If you complete any surveys requested for research purposes, we will collect information in such circumstances as well.
The information you give us may relate to your identification, such as your name, address, email address and phone number, or enquiry details, and may include records of any correspondence and responses to any surveys.
Personal data we collect about you: we may automatically collect the following information:
details of transactions you carry out through the websites, and your visits to our websites, including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources you access;
any personal data which you allow to be shared that is part of your public profile or third-party social network.
The remaining provisions of this policy also apply to any personal data we obtain from these sources.
WHY AND HOW WE USE YOUR PERSONAL DATA
We process your personal data lawfully for:
the purpose of handling communication and exchange of information with our website users;
the purpose of managing our customer/prospect relations; notably when processing your orders, responding to your requests or by regularly sending you news and information on our services or our initiatives that might be of interest;
any other specific purpose indicated at the time of collecting the information.
We may use and process your personal data principally:
where you have provided freely given and explicit CONSENT and for specific, determined and legitimate purposes.
You may withdraw your consent for us to use your information by contacting us at any time.
where it is necessary for us to pursue our LEGITIMATE INTERESTS as a business, provided that your interests or your fundamental rights and freedoms are not overriding, taking into consideration your reasonable expectations, based on your relationship with us.
For example, for the following purposes:
direct marketing activities (other than where we rely on your consent) as analysis to inform our marketing strategy, and to enhance and personalise your user experience;
information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access.
where it is necessary for us to COMPLY WITH A LEGAL OBLIGATION and notably:
to assist a public authority or criminal investigation body;
to identify you when you contact us under certain legal circumstances;
to verify the accuracy of data we hold about you
where it is required for the PERFORMANCE OF A CONTRACT we have with you, or because you have asked us to take specific steps before entering into a contract. This will include information that we process in order to enable you to make use of our website and the services we provide through it.
WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL DATA
Our suppliers and service providers
We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management) or advertising agencies, administrative services, credit reference agencies, credit/debit card payment processors, customer satisfaction surveys or other third parties who provide services to us and assist us in the operation of our business and website.
When we use third party service providers, we only disclose personal data that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and confidential, and not to use it other than in accordance with our specific instructions.
Third parties who provide products and services to you through us
We work closely with various third parties to bring you a range of products and services which are complementary to those which we provide.
When you enquire about or purchase one or more of these products or services through us, the relevant third party may use your details to provide you with information and to carry out their obligations arising from any contracts you have entered into with them.
Other ways we may share your personal data
We may transfer your personal data:
if we are under a duty to disclose or share it in order to comply with any legal obligation or when this disclosure is required by applicable laws, court orders or government regulations, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers;
if you have consented to the disclosure.
However, we will always take steps to ensure that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL DATA
Your information is stored either in our databases or in the databases of our service providers.
In such cases, we will take to the appropriate security and confidentiality measures to ensure that your privacy rights continue to be protected as outlined in this policy.
HOW LONG WE KEEP YOUR PERSONAL DATA
We retain your personal data for a period of time necessary to achieve the purpose for which we use that information and to fulfil our obligations under other laws. Except in specific cases, this period is specified at the time the information is collected.
We do not retain personal data in an identifiable format for longer than is necessary.
WHAT ARE YOUR RIGHTS?
Subject to applicable law and certain exemptions, restrictions or circumstances, you may have the right:
To access your personal data;
To correct, modify and update your personal data;
To erase your personal data or restrict its processing;
To withdraw your consent;
To object to our use of your personal data for automated decisions made about you;
To ask us to transfer your personal data in a structured data file to you or to another service provider if it is technically possible (data portability);
To lodge a complaint with the competent supervisory authority and seek a judicial remedy.
These rights may be exercised by written request sent to the contact details that will be provided to you at the time of data collection. A reply will be provided to you within a reasonable delay, in accordance with the applicable regulations.
HOW WE ENSURE SECURITY AND CONFIDENTIALITY OF YOUR DATA
Our aim is to keep your data as safe and secure as possible at all times. Once we have received your personal data, we put in place reasonable and appropriate technical and organisational measures and controls to prevent as much as possible any accidental or unlawful destruction, loss, alteration, or unauthorised access.
Our Privacy Correspondent is Cate Gregory. Please direct any queries about this Privacy Statement or about the way we process your personal information to email@example.com.