Privacy

Acuity Coaching Limited (Acuity Coaching/we/us/our/the Company) is committed to protecting and respecting your privacy.

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). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed, stored and disclosed by us. This policy applies to data collected from both our end users (Clients) and our associates or coaches (Coaches).

The Site is owned and operated by Acuity Coaching Limited (Company No. 04726068) of 130 Helmshore Road, Holcombe Village, Bury, Lancashire, BL8 4PB (our Company Address). Acuity Coaching processes personal data as a both a Data Controller and aData Processor, as defined in the Directive and the General Data Protection Regulation (GDPR).Our Data Protection Officer (DPO), who is responsible for matters relating to privacy and data protection, is Simon Coops, and he can be reached at simon.coops@acuitycoaching.com.

This Site contains links to and from third party websites.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.acuitycoaching.com(the Site) or using any services offered through or associated with our Site (the Services), you are deemed to have accepted and consented to the practices described in this policy.

1. Data We Collect About You

We collect and process personal information so we can provide our Services to you. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect and process about you is explained in the sections below.

1.1 Data You Give Us

You give us information about you by filling in our forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide: when you request information about our Services, when you fill in or send us forms or other documents, when you subscribe to our marketing database or report a problem with the Site. If you’re a Client, this also includes information you provide when you request a quote, information you provide during the client onboarding process and information provided on a Coach Request, Coaching Agreement or Evaluation. If you’re a Coach, this includes information you provide on our questionnaires or other forms (including our WWA and NDA), or information you provide for your coaching profile (via your CV, LinkedIn profile or otherwise).

The information you give us includes your name, email address, phone number, location data and behavioural data. We also collect business information from our Clients, and education and employment information from our Coaches.

This data is necessary for our legitimate interests and for us to fulfil our contractual obligations to you, and we rely on this as a lawful basisto use and process the data described above.

1.2 Data We Automatically Collect

Each time you visit or use our Site, we automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform;
  
  
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our Services (including by developing new products and services). Because we collect, use and share this information in the aggregate, it does not identify any individual.

1.3 Data We Receive from Third Parties

We use third parties such as LinkedIn to collect information about you and your business.For more information on how third parties handle your personal data, please refer to their privacy policies. If you’re a Client, please also note that our Coaches share information about you with us.

This data is necessary for our legitimate interests and for us to fulfil our contractual obligations to you, and we rely on this as a lawful basisto use and process the data described above.

2. How We Use Your Data

We use your data to carry out our Site and Services in the following ways:

• To to administer and manage your account, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
• To enable us to match Coaches to Client projects and to enable Coaches and Clients to contact us and each other to provide details on project process.
• To ensure that content from our Site is presented in the most effective manner for you and for your device.
• To respond to communications from you and to provide you with information about our Services.
• To notify you about changes to our Site or Services.

We also use your data to make our Site and Services better in the following ways:

• To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• As part of our efforts to keep the Site safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.

We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.

You can ask us 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 us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing or by email at coaches@acuitycoaching.com.  

3. How We Secure Your Data

All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect.

Our storage and security systems are delivered and managed by Invenias. Invenias Servers are protected by dedicated CISCO firewalls, a Virtual Private Network (VPN) which encrypts all information sent and received to and from the server, user authentication, SSL encryption, a unique hosted Microsoft SQL Server database only accessible by us, and an anti‐virus solution powered by Sophos. The following third parties are also utilised in our system:

• Dropbox, which provides file access designed with multiple layers of protection across a distributed, reliable infrastructure. Dropbox is fully compliant with the GDPR and with ISO standards, and is one of the first cloud-based systems to be awarded ISO 27001.
• Smartsheet, which provides secured collaboration and work management systems. Smartsheet utilises rigorous infrastructure and administrative procedures, as well as around-the-clock monitoring combined with physical security, data encryption, and user authentication. Smartsheet’s data center facilities are AICPA SOC 1 examined and tested, and ISO 27001 Certified. Smartsheet does not access your data except to respond to customer support requests, to prevent fraud, abuse, and violations of its policies and agreements, or as otherwise required by law.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.

4. How Long We Store Your Data

We only keep your personal information for as long as it’s necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it. We will delete your personal information when you delete your account with us by notifying the nominated person authorised to remove your details from our systems immediately.

1. Confirming the identity of the Data Subject submitting the request
2. Validating the request is lawful
3. Processing the request in our storage system, Invenias
4. Confirming with the Data subject that their request has been completed

We delete your personal data in compliance with ICO best practices. We avoid keeping paper records, but if a Client requires that we keep paper records, these are deleted using a secure document disposal service and we obtain a certificate of destruction. With regards to electronic records, our IT system will only allow authorised personnel to delete records and deleted records are automatically logged in the deleted personal data register. Our deletion process is audited bi-annually, which includes ensuring that logged items have been deleted and unnecessary items are no longer kept on the system.

5. Disclosure to Third Parties

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We use third parties such as Invenias (store and manage storage of records), Dropbox (cloud-based file storage), Smartsheet (collaboration and work management) and Newzapp (email marketing automation). These third parties have access to data we share with their platforms.

The onlyother circumstances under which we would share your personal data are:

• If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
• If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

6. International Transfers

The data that we collect from you is in extremely rarely and in very specific circumstances, transferred to, and stored at, a destination outside the European Economic Area (EEA). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the Contact paragraph below.

7. Your Rights

7.1 Legitimate Bases

We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:

• You have given your clear consent to the processing of your personal data for a specific purpose.
• Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
• Processing is necessary for our compliance with the law.
• Processing is necessary to protect someone’s life.
• Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
• Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.

7.2 Data Subject Rights

Under the GDPR, you have the right to:

• Withdraw your consent to the processing of your personal data at any time.  Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
• Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
• Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
• Correct or supplement any information we hold about you that is incorrect or incomplete.
• Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
• Object to the processing of your data.
• Obtain your data in a portable manner and reuse the information we hold about you.
• Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
• Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if  you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us at the Company Address, via email at coaches@acuitycoaching.comor by unsubscribing using the links contained in the marketing emails.

You may revoke your consent for us to use your personal data as described in this Privacy Policy at any time by emailing us atcoaches@acuitycoaching.com and we will delete your data from our systems. To enforce any of the above rights, please contact us at our Company Address or via email at coaches@acuitycoaching.com 

We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.

Cookies

A cookie is a small file of letters and numbers that we store on your browser. Cookies contain information that is transferred to your computer's hard drive (or the hard drive of another relevant device). We use cookies to distinguish you from other users on the Site, to tailor your experience to your preferences, and to help us improve the Site.

Some of the cookies we use are essential for the Site to operate. If you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site.

Before any non-essential cookies are placed on your device, you will be shown a pop-up message requesting your consent to setting those cookies. By default, most internet browsers accept cookies, but you can choose to enable or disable some or all cookies via the settings on your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. For further details, please consult the help menu in your internet browser.

We use the following cookies:

• Strictly necessary cookies.These cookies are required to save your session and to carry out other activities that are strictly necessary for the operation of the Site. They include, by way of general example, cookies that enable you to log into secure areas of the Site, use a shopping cart, or make use of e-billing services.  These cookies are session cookies, which means they’re temporary and will expire when you close your browser.
• Analytical/performance cookies.These cookies allow us to recognise and count the number of visitors and to see how visitors move around the Site when they’re using it.  These cookies help us improve the way the Site works by, for example, ensuring that users are finding what they’re looking for easily.
• Targeting cookies.These cookies record your visit to the Site, the pages you visit, and the links you follow.  We use this information to make the Site and the advertising displayed on it more relevant to your interests. We also share this information with third parties for the same purpose.
  
  

Changes To Our Privacy & Cookie Policies

Any changes we may make to our Privacy & Cookie Policies in the future will be posted on this page and, where appropriate, notified to you by email. You will be deemed to have accepted the terms of the updated Privacy & Cookie Policies on your first use of the Site following the alterations. Please check back frequently to see any updates or changes to our Privacy & Cookie Policies.

Contact

Questions, comments and requests regarding this Privacy & Cookie Policy are welcomed and should be addressed to our Company Address or to our email at coaches@acuitycoaching.com.