Privacy Policy.
The coaching and consultancy practice of People Who Thrive Ltd and this website (www.peoplewhothrive.com) are operated and owned by Kate Bonsall-Clarke (“I”, “me” and “my”).
By agreeing to start coaching or consulting with me and/or using this website and/or becoming a ‘Subscriber’ to my mailing list (see below), you consent to the collection, use, storage and transfer of your personal information under the terms of this Policy.
Overview
I take user privacy very seriously and take all reasonable efforts to protect it. I have created this Privacy Policy in order to share with you my information collection and use practices.
I will never knowingly sell or assign your personal information without your knowledge and/or approval.
I will never disclose any of your personal information to any third party except in accordance with the terms of this Policy.
Please read this Policy carefully before sharing any personally identifiable information described below.
This Policy is subject to change at any time and any changes will be posted on this page.
This Policy should be read in conjunction with my Terms and Conditions.
Statutory compliance
For the purposes of the Data Protection Act 2018 and the GDPR 2018, I, Kate Bonsall-Clarke, am registered as the Data Controller for People Who Thrive Ltd and for this website with the Information Commissioner’s Office (ICO), the UK regulatory body for data protection, and you can contact me via the email address at the end of this Policy.
I confirm that I understand the obligations on me, as Data Controller, in respect of your personal information and will take all reasonable steps to securely store it and use it only in lawful ways and for lawful purposes.
Collection of personal information
When you contact me with an interest in undertaking coaching or consultancy with me or visit this website or become a Subscriber (see below) you may be asked to, or will of your own volition, provide information to me from which you can be identified, including your name, contact details, any text you may upload, other technical data such as the IP address of the device you use, and of course all personal information you disclose to me during the coaching or consultancy sessions and associated email exchanges, questionnaires and other information exchange relating to the coaching or consultancy process.
You do not have to disclose any personal information to me but any such withholding may make it impracticable for me to provide you with coaching or consultancy. Please discuss this with me if it is a concern for you.
Use of personal information
I may use or disclose your personal information in order to:
· Send you email communications
· Provide you with coaching or consultancy
· Invoice you, collect payments and maintain my financial records (which may include the use of third party payment merchants and associated web-based payment facilities, bookkeepers and accountants)
· Maintain records of my coaching practice
· Take part in professional supervision
· Confirm certain basic details of my coaching practice to my professional body (i.e. your name and your email address, if I am asked by my professional for proof of who I have coached as part of my professional accreditation requirements)
· In the establishment or exercise of legal rights or defences against legal claims, to comply with applicable laws or regulations, to comply with a valid legal process, such as a search warrant, subpoena or court order or to investigate suspected fraud or a violation of my Terms and Conditions.
Disclosure of personal information
For coaching clients, I will never disclose any personal information about you that forms part of our coaching (including the contents of the coaching sessions and other personal information exchanged between us in connection with the coaching relationship) except:
· with your informed consent; or
· in accordance with the terms of this Privacy Policy and/or my Terms and Conditions; or
· in line with the International Coaching Federation code of ethics (which includes receiving professional supervision) that I practice under; or
· in the establishment or exercise of legal rights or defences against legal claims, to comply with applicable laws or regulations, to comply with a valid legal process, such as a search warrant, subpoena or court order or to investigate suspected fraud or a violation of my Terms and Conditions.
The information you provide to me may be accessed by or given to third parties or bodies who work with me, work for me, act for the purposes set out in this Policy or for other purposes approved by you. Those parties may process information, fulfil and deliver orders, process credit card payments and/or provide support services to me and/or to you on my behalf. My professional body may use my provision of your name and email address as part of its assessment of my practice for the purposes of my professional accreditation.
For users of this website, I may disclose your identity and contact details to (1) any third party who claims to me that any material posted or uploaded by you to my site constitutes a violation of their intellectual property rights or their rights of privacy, and (2) to other bodies, authorities, companies and organisations for the purposes of fraud protection, credit risk reduction, crime reduction and law enforcement. I may also pass aggregate information on the usage of this website to third parties but this will not include information that can be used to identify you.
If I enter into any joint venture with, or my business is sold to or merged with, another business or entity, your information may be disclosed to that other business or entity.
Transferring your personal information outside the EU
I will not intentionally transfer your personal information outside the EU without ensuring appropriate safeguards are in place. For example, I may put in place standard contractual clauses, or, if that is not appropriate, I may seek your explicit consent.
Currently, I do not knowingly transfer your personal information outside the EU.
However, I have no control over the routes emails take, and even emails exchanged between two people in the UK could appear on equipment in countries outside the EU, where they may not be protected by strong privacy or data protection laws.
You will probably not consider this an issue, but if you have any concerns please raise them with me and we can make alternative arrangements.
Deletion of personal information
I will keep your personal information for a maximum of 7 years, after which time I will securely delete it.
What non-personally identifiable information do I collect and how is it used?
I collect and track certain non-personally identifiable information, including, but not limited to, IP numbers and browser type, access times, domain names, usage habits and other information which does not specifically identify any individual.
Automated decision making
I provide a very personal service in my coaching practice and do not make any decisions which could have a legal effect, or other significant effect on you, based solely on automated processing of your personal data.
Mailing list and Subscribers
I maintain a mailing list of those who have subscribed via the “Keep in Touch” facility on this website (“Subscribers”).
I will periodically send out a Newsletter via email (hereinafter "Newsletter") to Subscribers (unless they have subsequently opted-out). In these Newsletters, I may inform you about new features on this website or Product and Services that I and/or my associates provide and about upcoming events or special promotions.
I may, from time to time, send or post surveys or requests for your feedback in order to help me make this website and services better. Any responses I receive from you will be used only to evaluate this website and services and no personally identifiable information from respondents will be shared with those who do not work for me except that information provided in the Feedback/Comments areas.
If you are chosen for a promotion or as a winner in a contest, I will not disclose any details until I request your permission to use your name, image and other information about you, for sharing purposes.
You may choose to unsubscribe from Subscriber status at any time by sending an email to me via the email address at the end of this Policy.
Do I use cookies?
Cookies are small text files that a website can write to your computer. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. I use cookies to identify you and allow you to log in once to my website and search or post without having to log in again and again. Cookies are also used by my affiliates or links to identify you as a user of this website.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
I do not use Cookies to store information such as credit card numbers, telephone numbers or other personal information you may provide.
This Privacy Policy only covers the use of Cookies by me. It does not cover the use of Cookies by any third parties or advertisers.
Merchants and advertisers
This website may contain links to various third party websites and the external websites of advertisers and/or third party partners. Each of these websites may have a privacy policy that differs from that of this Policy. This Policy does not cover the privacy policies of other websites. I urge you to check the privacy policies of each website that you may visit or interact with.
The only voluntary information that may be shared between me and one of my partner websites is that which pertains to information used in the furtherance of tracking an order and providing you with correct information regarding same.
Order information, including order numbers and amounts, may be available to me, to affiliate merchants and to third party affiliates and associates, for accurate tracking purposes. I will not release this information to any other parties unless you request it.
I may put banner and other advertising on this website from Google and other third parties that may place and read cookies on your browser, or use web beacons to collect information in the course of advertisements being served. If you are concerned about your privacy regarding these advertisements, please refer to Google’s (or other third parties’) own privacy policies.
Data security
I keep your personal data secure and safe using modern and regularly updated firewalls and anti-virus software. I employ security measures to protect, so far as reasonably possible, your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.
I keep very few details of what is discussed during our coaching sessions. When having professional supervision I do not disclose your full name or any details that could obviously be used to identify you.
I require that any advertisers and partners I may work with must ensure the security of the data that you provide to them. However, in the event of a breach of their security measures, I am not liable for any losses or damages and in using this website and/or undertaking coaching with me you agree to this.
Unfortunately, the transmission of information via the Internet is not completely secure. Although I will do my best to protect your personal data, I cannot guarantee the security of your data transmitted to my site. Any transmission to me of your personal data is at your own risk.
Access to the information I collect about you
You are entitled to see the personal data about you that I hold, to ask me how, why and where I process and store it, and to ask me to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do any of this, please contact me via the email address at the end of this Policy.
I do not charge for providing you with details of the information I hold about you, but I may charge you where such a request is manifestly unfounded or excessive, in particular if they are repetitive in character. In such circumstances I may either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or refuse to act on the request.
Opt-out
You have the right to ask me to restrict or stop using your personal information for any purposes (including marketing) and to ask me to delete some or all of it (including my records relating to the coaching). You may also choose to opt-out of being a Subscriber. If you wish to do any of these things, please send me an email via the email address at the end of this Policy.
I am not responsible for removing your personal data from any third party partner or advertiser who has previously been provided your information in accordance with this Policy.
Location
I am based, and primarily practice as a coach and consultant, in and from Leeds, United Kingdom.
This website is maintained in the United Kingdom. If you are located outside of the United Kingdom, by using the website you agree to and authorise the import of your information and its use, as specified in this Policy.
Changes to this Privacy Policy
I reserve the right to amend this Policy at any time in the event that this becomes necessary. I will not personally notify you of any amendments to this Policy. You should check this Policy frequently in order to determine whether any changes have been made. By using this website you understand and agree to the terms of this Policy, as it may be amended from time to time.
Spy ware
I will never use or install spyware on your computer.
Contact
All comments, queries and requests relating to my use of your information are welcomed and should be addressed to me at peoplewhothrive@outlook.com.
If you have a complaint, please contact me as soon as you can. You can, of course, make a complaint at any time to the ICO.
This Privacy Policy became effective on 17 September 2020.