Privacy policy
Introduction
This Privacy & Cookie Policy is provided by The Awareness Academy Limited, a company registered in England and Wales under company number: 14222618 with registered office Flat 3, 78 Castellain Road, W91EX, London, UK (‘we’, ‘our’ or ‘us’) for use of our our website.
We take your privacy very seriously. Please read this privacy and cookie policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data) and what cookies we use to make our website available to you.
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
What this policy applies to
This privacy policy relates to your use of our website only.
Our website may link to or rely on other apps, websites, APIs or services owned and operated by certain trusted third parties. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
Identity data you input into our website under ‘contact’
Your name
Your email address
Other data the website collects automatically when you use it
We also use a number of cookies (please see the section below on Cookies for more information)
If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent our website from working properly.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
Sensitive Data
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
If, however, you do submit sensitive data to us, such as if you make this sensitive data available to other users of the website (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.
How your personal data is collected
We collect personal data from you directly when you submit a “contact” form on our website, contact us directly or reach out to us via social media, make submissions via the website when a forum element is available, or indirectly, such as your activity while using the Website.
At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of a notification on our website, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies section.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
What we use your personal data for
Our reasons
Providing website functionality
we use your information where you have contacted us to make an enquiry so that we can give you the information you requested
To enforce legal rights or defend or undertake legal proceedings
Depending on the circumstances:
to comply with our legal and regulatory obligations
in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the website or service or other important notices
Depending on the circumstances:
to comply with our legal and regulatory obligations
in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
to comply with our legal and regulatory obligations
in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We intended to use email marketing to inform you of our services such as promotions and new materials which become available for purchase.
We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:
contacting us at unsubscribe@thewhoamicoach.com
using the ‘unsubscribe’ link included in all marketing emails you may received from us
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities on our website, including developers, cloud storage providers, Squarespace, Convertkit and Google. We exert no control over Squarespace, Convertkit and Google’s Privacy Policy and we therefore recommend that you consult their privacy policies for further information on how they protect personal data.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
How long your personal data will be kept
We will keep your personal data for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims.
Following the end of the aforementioned retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK
At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:
The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Your rights
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
Access to a copy of your personal data
The right to be provided with a copy of your personal data.
Correction (also known as rectification)
The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situations.
Restriction of use
The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use
The right to object:
at any time to your personal data being used for direct marketing (including profiling)
in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by our website
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please complete a request form—available on our website at [insert link] or email , call or write to us—see below: ‘How to contact us’. When contacting us please:
provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
Cookies
A cookie is a small text file which is placed onto your device (e.g. your smartphone or other electronic device) when you use our website. When we use cookies on our Services, you will always be informed by a pop-up on our website.
Cookies help us to recognise you and your device and allow us to store some information about your preferences or past actions, including your location data (for more information, please see our Privacy Policy).
For example, we may monitor how many times you use our website, which parts of the website you go to, location data. This information helps us to understand the use of our website by our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.
For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
Consent to use cookies
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to allow you to remain logged-in to the website as you navigate it and to keep your chat active so you can return later).
Our use of cookies
The table below provides more information about the cookies we use and why:
Most of the cookies we may collect via our application are essential in providing our service over the internet to you, our users. Without these cookies, certain features won’t be accessible to deliver the app experience requested by you. We have further categorised the cookies we use below:
Strictly Necessary Cookies
Without these cookies, our website won’t work or certain features won’t be accessible to you, so it is not possible to turn these cookies off. For example, we may need to remember data you’ve inputted from one page to the next in a single session.
Performance Cookies
Performance cookies collect information about your use of the website in order for us to provide the services requested by you. We collect information about how you interact with the website. This information helps us identify patterns of usage on the website, collect analytics data, identify issues you may have had on the website and make changes to provide our service to you.
Functional Cookies
We use functional cookies to improve your experience on our website and make things more convenient for you. These cookies personalise your experience on our website based on your preferences, by remembering your details such as your login details or region.
Security cookies are a type of functional cookie, which assist with website and user account security. Load balancing session cookies are used for the duration of the session to distribute user requests across multiple servers to optimise website speed and capacity. We may also use user interface customisation persistent cookies to store a user’s preferred version of our website.
How to turn off all cookies and consequences of doing so
If you do not want to accept any cookies, you may be able to change your device settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website and of other Servicess you use on your device. For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
Changes to this policy
This policy was published on 25th April 2023 and last updated on 25th April 2023. We may change this privacy & cookies policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.
How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
susanna@thewhoamicoach.com
+44 7562 234 271