Our contact details: 

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Polly Downes 

Storm Coaching

London, SW16 

+44 79 08 66 06 11

www.stormcoaching.co.uk

pollydownes@stormcoaching.co.uk

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Date Privacy notice completed: May 2023

 

Storm Coaching does not sell your information.

We handle your data the way we would want our data handled.

Storm Coaching is committed to protecting the privacy of its users. 

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We provide a safe, secure user experience to ensure that the information you submit to me remains private and is used only for the purposes set forth herein. 

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The following reflects our commitment to you.

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The type of personal information we collect:

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Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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We currently collect and process the following information:

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1. Identity data including contacts and characteristics (for example, name and contact details)

2. Contact Data includes billing address, delivery address, home addresses, email address and telephone numbers.

3. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

4. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences although currently we do not ‘market’.

5. Special Categories of Personal Data about you – we do not collect this kind of data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). 

6. However due to our approach and specialism in working with neurodiverse individuals, specifically ADHD, we may collect and store information about your neurodiversity. 

7. We do not collect any information about criminal convictions and offences.

 

If you fail to provide personal data:

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Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested; we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

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How we collect your personal information and why we have it:

 

We use different methods to collect data from and about you including through:

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Direct Interactions:

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You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you purchase a course, sign up to be a coach, receive coaching from us, or correspond with us for any other reason.

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Interactions with Your Employer:

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Where your employer has asked one of our associates to provide coaching to you and/or any of your co-workers, we may receive contact data and identity data about you from your employer directly. Where this occurs, we will only use that data to contact you about the services we are able to offer.

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Automated Technologies or Interactions:

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If you complete a form on our website or sign a contract, we will automatically collect this data and store it in our password protected client management system. 

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Third Parties:

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We will receive personal data about you where Storm Coaching is contracted as an associate, and you have come to Storm Coaching via that third party. 

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How we use your data:

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Generally, we do not rely on consent as a legal basis for processing your personal data. We will only use your personal data when the law allows us to. Most commonly, we will use the following legal bases when processing it:

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1. Where we need to perform the contract, we are about to enter into, or have entered into an agreement with you (e.g., when you become a client, or purchase a course from me)

2. To protect your vital interests (e.g., if we reasonably believe that there is a risk of imminent harm)

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

4. Where we need to comply with a legal obligation

 

Where we rely on our own legitimate interests to process your data, those interests are:

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a)   To administer and protect our business

b)   To communicate our services and offerings appropriately via any marketing

 

Who has access to your data?

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We will never sell your personal data. However, we may share it with suppliers who provide services to our business. Below sets out the categories of service provider we use, and what personal data may be shared with them:

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Dubsado: – Password protected Client Management System stores signed contracts, proposals, completed questionnaires and some email correspondence pertaining to these.

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Customer Experience: and business support – Emma Graham accesses and administers the above system. She may from time to time interact with clients to arrange appointments.

Service providers who provide IT and cloud-based system administration services.

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Professional advisers: including lawyers, bankers, auditors and insurers.

Government bodies that require us to report processing activities.

Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

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International transfers:  

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We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

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Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

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Many of our third party service providers are based outside the European Economic Area (EEA), therefore, processing of your personal data will involve a transfer of data outside the EEA.

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Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

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• We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by

• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe

• If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

 

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

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Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

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1. Your consent. You can remove your consent at any time by contacting polly@stormcoaching.co.uk

2. We have a contractual obligation.

3. We have a legal obligation.

4. We have a vital interest.

5. We need it to perform a public task.

6. We have a legitimate interest.

 

How we store your personal information:

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Your information is securely stored. 

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We keep for the above forementioned types of data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

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For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

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In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

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We will then dispose your information by permanent deletion.

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Your data protection rights:

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Under data protection law, you have rights including:

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Your right of access - You have the right to ask us for copies of your personal information. 

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

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Please contact us at pollydownes@stormcoaching.co.uk if you wish to make a request.

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How to complain:

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If you have any concerns about our use of your personal information, you can make a complaint to us at pollydownes@stomrcoaching.co.uk.

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You can also complain to the ICO if you are unhappy with how we have used your data.

The ICOs address is:        

  

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

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Storm Coaching is a trading name of PSW coaching Ltd