Privacy Policy for Your Inside Coach (www.yourinsidecoach.com)
The privacy of our visitors is of extreme importance to us. This document outlines the types of information received and collected by www.yourinsidecoach.com and how it is used.

Your Inside Coach (www.yourinsidecoach.com) is governed by the following Privacy Policy.

We respect your privacy and are committed to protecting it. The purpose of this Privacy Policy is to inform you what information we may collect and how it may be used. This statement only applies to this Website.

INTRODUCTION

1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?

Personal data means any information capable of identifying an individual. It does not include anonymised data.

• Personal information is collected directly from the User via email, the website (www.yourinsidecoach.com) or via the booking system (Acuity Scheduling). In some cases information will be transferred from the website or email to the Acuity Scheduling system. This is usually when requested by the customer. Some personal and sensitive information will also be collected on paper based forms used in consultations or where the customer does not use online versions. This information is kept in paper form in a locked filing cabinet. We use personal information to manage the standard operations Your Inside Coach coaching sessions, classes and courses. In addition to notify customers of changes to the services offered as well as updates on new services. 
• Information You Voluntarily Send To Website: We may collect personal information from you such as your name or email address from the website. For example, you may voluntarily submit information to the Website by leaving a comment, subscribing to a newsletter, requesting a freebie, signing up to Your Cookbook or submitting a contact and/or booking form. Personal Data will only be used in ways that are in line with why it was originally provided. For example, we will not contact someone designated as your emergency contact for marketing purposes.
• Sensitive Data: When a customer signs up to a particular service, class or course, we will request information on current health, injuries and recent medical history as deemed relevant to the service to be provided. This information is collected in order to ensure that the customer is able to take part in a particular service, class or course, to personalise the service as required and to be in compliance with Your Inside Coach’s insurance policy. 
• Information We Collect from Others: We may receive information about you from other sources. For example, if you use a third-party software through the site, they may transfer information to us for fulfillment.
• Automatically-Collected Information: We automatically collect certain information about you and the device with which you access the Website. For example, when you use the Website, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect information about actions you take when using the Website, such as links clicked.
• Cookies: We may log information using cookies, which are small data files stored on your browser by the Website. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.

HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
  • order our products or services;
  • create an account on our site;
  • subscribe to our service or publications;
  • request resources or marketing be sent to you;
  • enter a competition, prize draw, promotion or survey; or
  • give us feedback.
• Technical Data from the following parties:
  • analytics providers such as Google based outside the EU;
  • advertising networks based inside OR outside the EU; and
  • search information providers based inside OR outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as PayPal based outside the EU].
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

HOW YOUR INFORMATION MAY BE USED

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• 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.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at laura@yourinsidecoach.com.

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at laura@yourinsidecoach.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests for running our 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 content and advertisements to you and measure and understand the effectiveness of our advertising	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests to develop our products/services and grow our business

In addition it maybe used to,

• send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
• send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
• respond to your comments or inquiries;
• provide you with user support;
• track and measure advertising on the Website;
• process payment for purchases you make through the Website; or,
• protect, investigate, and deter against unauthorized or illegal activity.

Marketing communications

You will receive marketing communications from us if you have:

• requested information from us or purchased goods or services from us; or
• if you provided us with your details where the use of them for marketing communications is explicitly communicated
• in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you or OR by emailing us at laura@yoursinsidecoach.com at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at laura@yoursinsidecoach.com.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

THIRD-PARTY USE OF PERSONAL INFORMATION

We may share your information with third parties when you explicitly authorize us to share your information.

Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The Website currently uses the following third-party service providers:

• Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.
• Covert Kit – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications. Convertkit are themselves GPRP compliant.
• AdThrive – this service is used to manage our display advertisements. To provide personalized advertising options, AdThrive may track your IP address or location. This information is not stored on the Website. The Website uses AdThrive to manage all third-party advertising on the Website. AdThrive serves content and advertisements when you visit the Website, which may use cookies. AdThrive may collect IP addresses and location to serve personalized ads.

In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

At this time, your personal information is not shared with any other third-party applications. This list may be amended from time to time in the Website’s sole discretion.

Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

DATA MAY BE PROCESSED OUTSIDE THE EUROPEAN UNION

This website is hosted in the United Kingdom.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America or in Australia.

We use the following safeguards with respect to data transferred outside the European Union:

The processors we use such as Google and Convertkit are themselves GPRP compliant – you can directly contact Convertkit to view and remove the information we hold on you for example.

ANONYMOUS DATA

From time to time, we may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.#

DATA SECURITY

We 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, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

RETENTION

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us, to provide you with the services you have requested, to comply with other law, including for the period demanded by our tax authorities and to support a claim or defence in court.

Sensitive data from customers will be retained for a maximum of 1 year from the last use of the services of Your Inside Coach. Paper copies of data will be shredded and electronic copies deleted from all sources. 

Some personal information may be retained for legal or legitimate business purposes. For example, a customers payment history, class attendance will be retained for analysis of business performance.

PUBLICLY VISIBLE INFORMATION

If you create a user profile on the Website or leave a comment, certain information may be publicly visible.

USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

You can set 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.

We use cookies in the following ways:

1. 1. to track how you use our website
   2. to record whether you have seen specific messages we display on our website
   3. to keep you signed in our site
   4. to record your answers to surveys and questionnaires on our site while you complete them

Further information about cookies can be found within this link www.allaboutcookies.org.

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

ADVERTISING

Display Ads
We may use third-party advertising companies to serve content and advertisements when you visit the Website, which may use cookies. No personally identifiable information is shared with the Website’s ad providers.

Retargeting Ads
From time to time, the Website may engage in remarketing efforts with third-party companies, such as Google, Facebook, or Instagram, in order to market the Website. These companies use cookies to serve ads based on someone’s past visits to the Website.

Sponsored Content Tracking Pixels
This Website may engage in sponsored campaigns with various influencer networks, brands, and agencies. All sponsored content is duly disclosed in accordance with the FTC’s requirements. From time to time, these sponsored campaigns utilize tracking pixels (aka web beacons), which may contain cookies to collect data regarding usage and audience. This information is collected by the sponsoring company to track the results of the campaign. No personally identifiable information collected by the Website is used in conjunction with these tracking pixels.

Newsletters
On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.

RIGHTS RELATED TO YOUR PERSONAL INFORMATION

Opt-out – You may opt-out of future email communications by following the unsubscribe links in our emails or you can directly contact Convertkit to view and remove the information we hold on you. In addition you may also notify us at laura@yourinsidecoach.com to be removed from our mailing list.

Access & Amend – A customer can request to view and update the data held by Your Inside Coach. You can make such requests by emailing laura@yourinsidecoach.com. We may require you to verify your identity before disclosing any personal information and will attempt to comply with the request within a reasonable period of time. This is important to safeguard your information.

Erase/forget – In certain situations, you may request that we erase or forget your personal data. To do so, please submit a request to laura@yourinsidecoach.com. This may limit the service we can provide to you.

Please note that we may need to retain certain information for record keeping purposes or to complete transactions, or when required by law.

HOW YOU CAN COMPLAIN

If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is laura@yourinsidecoach.com.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

Complaints regarding content on our website

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

AFFILIATE & BUSINESS PARTNER INFORMATION

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

CHILDREN’S INFORMATION

We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian

The Website does not knowingly collect any personally identifiable information from children under the age of 18. If a parent or guardian believes that the Website has personally identifiable information of a child under the age of 16 in its database, please contact us immediately at
laura@yourinsidecoach.com and we will use our best efforts to promptly remove such information from our records.

UPDATES TO THIS POLICY

We reserve the right to change this Privacy Policy from time to time. We encourage you to periodically review this document for the latest information about how we handle personal information and ensure privacy. If we make material changes to this Privacy Policy, we will notify Users via email or another method that is reasonably likely to reach the User.

Continued use of the Service will constitute acknowledgement and acceptance of the Service.

Our Data protection officer and Data controller are Laura Wooding.

CONTACT INFORMATION

At any time, please contact us at laura@yourinsidecoach.com for questions related to this Privacy Policy.

Last updated: 16/04/20