Privacy Policy
Last updated: 29th September 2024
I respect your privacy and I am committed to protecting your personal data. This privacy policy will inform you about how I look after your personal data when you visit my website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please read the whole of this policy carefully as it contains important information about who I am and how and why I collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact me, or supervisory authorities, in the event you have a complaint.
From time to time, I may need to change my privacy statement because of changes in my organisation, legislation or in my attempts to serve your needs better. I will use reasonable efforts to publish any changes to my privacy statement.
I collect, use and am responsible for certain personal information about you. When I do so, I am subject to data protection laws which apply across the European Union and the United Kingdom and I am responsible as ‘controller’ of that personal information for the purposes of those laws. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
By providing me with your data, you warrant to me that you are over 13 years of age.
1. Important information and who I am
Purpose of this privacy policy:
This privacy policy aims to give you information on how I collect and process your personal data through your use of this website, including any data you may provide through this website when you fill in my contact form, sign up to receive information from me, or purchase my services.
This website is not intended for children and I do not knowingly collect data relating to children.
It is important that you read this policy together with any other privacy policy or notice or fair processing notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy policy supplements the other policies and notices and is not intended to override them.
Controller:
‘Data Controller’ is the term used to describe the person / organisation that collects, stores, and has responsibility for people’s personal data. In this instance, the data controller is me, Beth Clare McManus (referred to as “I”, “me”, or “my” in this privacy policy).
I am registered with the Information Commissioner’s Office (ICO) - reference ZB48609
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact me using the details set out below.
Contact details:
My full details are:
Beth Clare McManus
c143 Pollard Yard, Pollard Street East,
Manchester M40 7QX
You have a right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
However, I care deeply about your data protection rights and I would appreciate the chance to deal with your concerns before you approach the ICO. Please contact me using the details above in the first instance.
Your duty to inform us of changes:
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and I am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy policy or notice of every website you visit.
2. The data I collect about you
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).
I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender identity
Contact Data includes billing address, delivery or postal address, email address and telephone numbers
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 that you have purchased from me
Technical Data includes internet protocol (IP) address, your log-in data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on devices you use to access this website
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
Usage Data includes information about how you use my website, products or services
Marketing and Communications Data includes your preferences in receiving marketing from me and our third parties, and your communication preferences
I also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage or users accessing a specific website feature.
Sensitive Data
Sensitive Data refers to data that 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, and criminal convictions and offences.
If you become a coaching or supervision client, and because coaching and supervision can be broad-ranging in its scope, sensitive data may form part of session notes, which must be kept for five years as per the terms of my insurance. I require your explicit consent for processing sensitive data, so when you sign our Coaching Agreement; Supervision Agreement; or Group Supervision Agreement, I will ask you to confirm your explicit consent to this processing.
3. How is your personal data collected?
I use different methods to collect data from and about you, including through:
Direct interactions. You may give me your Identity, Contact, and Financial Data by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you (where applicable):
Apply for my products or services;
Create an account on my website;
Subscribe to my services or publications;
Request marketing to be sent to you;
Enter a competition, promotion, or survey, or;
Give me some feedback or contact me.
Automated technologies or interactions. As you interact with my website, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies and other similar technologies. Please see my cookie policy for more details
Analytics. I may receive technical personal data about you from analytics providers such as Google
I may receive Contact, Financial, and Transactional Data from providers of technical, payment, and delivery services such as PayPal or Stripe
4. How I use your personal data
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
Where I need to perform the contract I am about to enter or have entered into with you
Where is it necessary for my legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests
Where I need to comply with a legal or regulatory obligation
To keep you updated about my products and services where you have consented to this. I shall send this information to you by email. You have the right to withdraw consent to marketing at any time by contacting me and by clicking on the unsubscribe button in my emails
Purposes for which I will use your personal data
I have set out below a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.
Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data.
To register you as a new customer
Type of data:
(a) Identity
(b) Contact
Lawful basis for processing:
(a) Performance of a contract with you
To process and deliver your order, including: (a) managing payments, fees and charges, and (b) collect and recover money owed to me
Type of data:
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Lawful basis for processing:
(a) Performance of a contract with you
(b) Necessary for my legitimate interests (to recover debts due to me)
To mange my relationship with you, which will include: (a) notifying you about changes to my terms or privacy policy, and (b) asking you to leave a review or take a survey
Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Lawful basis for processing:
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary to my legitimate interests (to keep my records updated and to study how customers use my products / services)
To enable you to partake in a competition or complete a survey
Type of data:
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Lawful basis for processing:
(a) Performance of a contract with you
(b) Necessary for my legitimate interests (to study how customers use my products / services, to develop them, and to grow my business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing
(a) Necessary for my legitimate interests (for running my business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you, and measure or understand the effectiveness of advertising I serve to you
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Lawful basis for processing
(a) Necessary for my legitimate interests (to study how customers use mym products / services, to develop them, to grow my business, and to inform my marketing strategy)
To use data analytics to improve my website, products / services, marketing, customer relationships and experiences
Type of data
(a) Technical
(b) Usage
Lawful basis for processing
(a) Necessary for my legitimate interests (to define types of customers for my products and services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Lawful basis for processing
(a) Necessary for my legitimate interests (to develop my products / services and grow myI business)
Marketing
I strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. My lawful ground for processing your personal data to send you marketing communications is either your consent or my legitimate interests (namely to grow my business).
Under the Privacy and Electronic Communications Regulations, I may send you marketing communications from me if (i) you made a purchase or asked for information from me about goods or services, or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, I may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from me at any time.
Promotional offers from me
I may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which products, services and offers may be relevant for you (I call this marketing).
You will receive marketing communications from me if you have requested information from me or purchased goods or services from me and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
I do not share your personal data with any third parties.
Opting out
You can ask me or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting me at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to me as a result of a product / service purchase, warranty registration, product / service experience, or other transactions.
Cookies
You can see your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies I use, please see my cookie policy.
Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose.
Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
I may have to share your personal data with the parties set out below for the purposes set out in Clause 4 above:
External Third Parties such as service providers, professional advisers, HMRC and regulators; and
Third parties to whom I may choose to sell, transfer, or merge parts of my business or my assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy policy.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes, and in accordance with my instructions.
6. International transfers
To deliver services to you, it is sometimes necessary for me to share your personal information outside the European Economic Area (EEA) or the UK, e.g., with my service providers located outside the EEA.
These transfers are subject to special rules under European and UK data protection law.
Whenever I transfer your personal data outside of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, recognised by the UK government
Where I use certain service providers, I may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, as recognised by the UK government
If you would like further information, please contact me using the contact details in Clause 1 above.
7. Data Security
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.
I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so.
8. Data retention
How long will you use my personal data for?
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. I may retain your personal data for a longer period in the event of a complaint, or if I reasonably believe there is a prospect of litigation in respect of my relationship with you.
To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, and the potential risk to harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data, and whether I can achieve those purposes through other means, and the applicable legal requirements.
By law I have to keep basic information about my customers and clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
If you are not a customer or client, I shall retain your data for 2 years following your last engagement with us.
In some circumstances, you can ask me to delete your data: see ‘Request erasure’ below for further information.
In some circumstances I may anonymise your personal data (so that it can be no longer associated with you) for research or statistical purposes, in which case I may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing of your personal data
Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact me.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, I may refuse to comply with your request in these circumstances.
Changes to this privacy policy
I continually review my privacy practices and may change this privacy policy from time to time - when I do, an amended privacy notice will be placed on my website at https://www.bethclaremc.com/privacypolicy
My privacy notice was first published on 15th January 2021 and last updated on 29th September 2024.