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Privacy Notice
This privacy notice tells you what to expect Hamish Renton Coaching to do with your personal information.
Contact details: hamish@hamishrenton.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
- Names and contact details
- Addresses
- Gender
- Pronoun preferences
- Occupation
- Date of birth
- Marital status
- Payment details (including card or bank information for transfers and direct debits)
- Usage data (including information about how you interact with and use our website, products and services)
- Video recordings
- Audio recordings (eg calls)
- Website user information
We may also collect or use the following special category information to provide and improve products and services for clients. This information is subject to additional protection due to its sensitive nature:
- Religious or philosophical beliefs
- Health Information
We collect or use the following personal information for the operation of client or customer accounts:
- Names and contact details
- Addresses
- Purchase or service history
- Account information, including registration details
- Information used for security purposes
- Marketing preferences
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
- Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- 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. Read more about the right to data portability.
- Your right to withdraw consent - When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:
To respond to enquiries from people interested in coaching, manage communications with prospective clients and improve the services offered. This involves using only the personal information necessary to respond to requests and provide relevant information. Individuals would reasonably expect their details to be used for these purposes when contacting the business, and their privacy rights are respected.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Where we get personal information from
Directly from you
How long we keep information
We only keep personal information for as long as necessary for the purpose for which it was collected.
Enquiry information is normally retained for up to six months after our last contact. Client contact details and coaching records are generally retained for up to two years after the coaching relationship ends, unless a longer period is required for legal, insurance or professional reasons. Financial records are retained in accordance with applicable tax and accounting requirements. When information is no longer needed, it is securely deleted or anonymised.
Who we share information with
Data processors
Wix
This data processor does the following activities for us: Wix provides website hosting, online booking and contact form services. It collects, processes and stores personal information submitted by visitors, including names, email addresses, contact details and booking information. This enables Hamish Renton to respond to enquiries, arrange coaching consultations and manage appointments.
Google Workspace (Google LLC)
This data processor does the following activities for us: Google Workspace provides business email, calendar and cloud storage services. It processes and stores personal information, including names, email addresses, correspondence and appointment details, to enable Hamish Renton to communicate with prospective and existing coaching clients, manage appointments and securely store relevant business information.
Others we share personal information with
Professional or legal advisors
Organisations we’re legally obliged to share personal information with
Sharing information outside the UK
We use trusted third-party providers, including Wix and Google Workspace, to operate our website, manage bookings and communicate with clients.
These providers may process or store personal information outside the UK. Where this happens, appropriate safeguards are used to protect personal information in accordance with UK data protection law. These may include transfers to countries recognised as providing adequate data protection, or approved contractual safeguards.
Further information about these arrangements is available on request.
Organisation name: Wix.com Ltd
Category of recipient: Website hosting, online booking and data storage provider.
Country the personal information is sent to: Country the personal information is sent to: Israel and potentially other countries where Wix and its authorised sub-processors operate.
How the transfer complies with UK data protection law: Personal information is initially transferred to Wix.com Ltd in Israel, which is recognised by the UK as providing an adequate level of data protection. Where Wix transfers information onwards to countries without an adequacy decision, it uses appropriate contractual or other safeguards in accordance with applicable data protection law.
Organisation name: Google LLC (Google Workspace)
Category of recipient: Business email, calendar and cloud storage provider.
Country the personal information is sent to: United States and potentially other countries where Google and its authorised sub-processors operate.
How the transfer complies with UK data protection law: Google Workspace provides business email, calendar and cloud storage services. Personal information may be processed in the United States and other countries where Google or its authorised sub-processors operate. International transfers are subject to the safeguards set out in Google’s applicable data-processing terms, including adequacy arrangements or approved contractual safeguards, as appropriate.
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: hamish@hamishrenton.com
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
ICO Head Office
4th Floor, No.3 Circle Square
5 Hawkshaw Street
Manchester
M1 7BL
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
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