Privacy Policy
This website is owned by Potential To Be Limited, company number 10516455 (‘I’, ‘my’, ‘we’, ‘our’, or ‘us’).
My registered address is at 36 Scotts Road, Bromley, England, BR1 3QD.
If you have any concerns about this notice or your privacy please tell me. You can contact me through this website.
Introduction
This notice describes how I collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.
In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.
I am committed to protecting your privacy and the confidentiality of your personal information. I undertake to preserve the confidentiality of all information you provide to me and hope that you reciprocate.
Personal data I process
How I obtain personal data
The information I process about you includes information:
- You directly provide to me
- I collected as a result of monitoring how you use this website
Types of personal data I process directly
When you book or attend a coaching session, you may disclose personal data to me. This may include:
- Personal identifiers, such as your first and last names
- Contact information, such as your email address, your telephone number and your postal address
- Your personal circumstances and your beliefs
- Information about work colleagues, where relevant to the coaching session
In addition, when you use my services, I process:
- Transaction information, including about bookings, payments or communications to and from you
- Other types of personal data communicated in messages sent through this website, by email, by online communication software and or in telephone conversations
Types of personal data I collect from your use of my website
When you visit my website, I process:
- Technical information about the hardware and the software you use to access this website, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
- Usage information, including the frequency you use this website, the pages that you visit, whether you receive messages from me and whether you reply to those messages
Use of aggregated information
I may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.
However, if I combine or connect aggregated information with your personal data so that it can identify you in any way, I treat the combined information as personal data, and it will be used in accordance with this privacy policy.
Special personal data
Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data. It also includes information about criminal convictions and offences.
In the course of working with you, you may disclose to me information that falls into the types classed as special category data.
If I process special category data relating to you then I ensure that additional care is given in safeguarding it.
If you do not provide required personal information
Where I need to collect personal information by law, or in order to be able to provide my services under a contract I have with you, and you fail to provide that information when requested then I may not be able to perform that part of or all of that contract. If so, I will notify you of this at the time.
The bases on information about you is processed
The law requires me to determine under which of six defined bases I process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which I process your personal information is no longer relevant, then I shall immediately stop processing your data.
If the basis changes, then if required by law I shall notify you of the change and of any new basis under which I have determined that I can continue to process your information.
Information processed under a contract
In order to provide my services, or in situations where you have requested that I provide my services, I must collect and record your personal data.
For example, when you book a coaching session, I reasonably presume you do so with intention to enter into a contract. In this situation, your personal data, which includes personal identifiers and contact information, is processed on the basis of contractual obligation.
I continue to process this information until the contract between us ends or until I am otherwise no longer required to keep it.
Information I process with your consent
Through actions when otherwise there is no contractual relationship between us, such as when you contact me through my website, you provide your consent to me to process personal data that includes personal identifiers, contact information and technical information.
I continue to process your information on this basis until you withdraw your consent, or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by telling me. However, if you do so, you may not be able to use this website or my services further.
Information I process for the purposes of legitimate interests
I may process personal data on the basis there is a legitimate interest, either to you or to me of doing so.
Where I process your information on this basis, I do so after having given careful consideration to:
- Whether the same objective could be achieved through other means.
- Whether processing (or not processing) might cause you harm
- Whether you would expect me to process your data, and whether you would, in the round, consider it reasonable to do so
For example, I may process your information on this basis for the purposes of:
- Record-keeping for the proper and necessary administration of my business
- Protecting and asserting the legal rights of any party
- Insuring against or obtaining professional advice that is required to manage business risk
- Protecting your interests where I believe I have a duty to do so
Information I process because I have a legal obligation
Sometimes, I must process your information in order to comply with a statutory obligation.
For example, I may be legally required to disclose personal data by a court of law. This may include your personal information.
Your rights
The law requires me to tell you about your rights and my obligations to you in regard to the processing and control of your personal data.
I do this now, by requesting that you read the information provided at https://www.knowyourprivacyrights.org
Delivery of services using third party communication / software
With your consent, I may communicate using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype or Teams) or Zoom Video Communications (Zoom).
Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software comply with all applicable privacy laws, rules, and regulations, including the GDPR.
If you have any concerns about using a particular software for communication, please tell me.
My business is based in England. The headquarters of my website hosting provider are in the UK and as such is considered to offer an adequate level of protection for the personal information of UK and EU Member State residents.
Control over your own information
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal information changes.
At any time, you may contact me to request that I provide you with the personal information I hold about you.
When I receive any request to access, edit or delete personal identifiable information I shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Please be aware that I am not obliged by law to provide you with all personal data I hold about you, and that if I do provide you with information, the law allows me to charge for such provision if doing so incurs costs for me. After receiving your request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.
I remind you that I am not obliged by law to delete your personal data or to stop processing it simply because you do not consent to me doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which I may process it, I may do so on that basis.
Communicating
When you contact me, whether by telephone, through this website or by email, I collect the information you have given to me in order to reply.
I may keep personal information associated with your message, including your Identity and Contact Information so as to be able to respond to you.
Complaining
If you are not happy with this privacy policy or if you have any complaint, then you should tell me.
When I receive a complaint, I record all the information you have given to me.
I use that information to resolve your complaint.
If your complaint reasonably requires me to contact some other person, I may decide to give to that other person some of the information contained in your complaint. I do this as infrequently as possible, but it is a matter for my sole discretion as to whether I do give information, and if I do, what that information is.
If a dispute is not settled, then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration.
If you are in any way dissatisfied about how I process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. However, I would appreciate that if you have a concern, you raise it with me before complaining to the ICO.
Retention period for personal data
I keep your personal information only for as long as required:
- To provide you with the services you have requested
- To comply with other laws, including for the period demanded by tax authorities
- To support a claim or defence in court
Compliance with the law
My privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).
Review of this privacy policy
I may update this privacy policy from time to time as necessary.