Privacy Policy

Who we are

Refresh Coaching and Training Ltd, the Data Controller. Company Registration Number 10674460. Registered address is C/O Dragonfly (Accounting & financial Planning Management) 52 High Street, Tottenham, Cambridgeshire, CB24 8SA. Website address https://refreshcoachingandtraining.com. Email address rosanna@refreshcoachingandtraining.com

What is personal data?

Personal data is information that can be used to identify an individual. For example your name, email address, home address, birth date, photograph and even IP address. We may collect certain information about you in the course of our dealings and through transactions with you.

Your rights over your data

You have certain rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. We pledge our best efforts and intention to fully comply with the requirements of the Data Protection Act 1998.

What is a Privacy Policy?

This document aims to be clear and transparent. We need to inform you about what you can expect from us, how we operate our business and the basis upon which we offer our service to you in relation to your personal data. The service we offer dictates that we process your information. This document has been created to convey to you the methods and means by which we do that and with what outside support. In it we detail which companies we share your data with. In short we aim to cover and define your rights and our responsibility to you in the processing of your confidential data.

We may update this privacy policy with changes from time to time. We advise that visiting and using the website and our services indicate that you are in agreement with our Privacy Policy. We may share your data according to the terms of this Privacy Policy. Your use of this website and our services infers that you are in agreement with our policies. Please do not use the website or our services unless you are satisfied with and in agreement with our policies, terms and conditions.

If you ever need reassurance at any time or in the unlikely event that you feel you have grounds for a complaint then we welcome an opportunity to hear about your experience, discuss your point of view and resolve matters for you to your satisfaction. If you have any doubts about our compliance or wish to exercise any of your rights under the General Data Protection Regulations, please email rosanna@refreshcoachingandtrainng.com.

If you are still not satisfied with any aspect of how we collect and use your data, following our response and resolution offer then you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). For more information on how they handle any concerns. Please click on this link https://ico.org.uk/how-we-handle-concerns/

The key points of your rights in relation to our business are covered in this document. You can see more about your rights in general at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Why do we collect Data?

This is for the purpose of providing our services to you. In particular, private coaching consultations and holistic therapy treatments may involve the recording and processing of your private and personal history in order for exemplary results and outcomes to be achieved with great results, within shorter time lines. We have always regarded your privacy and security very seriously and aim to continue to do our upmost to operate a high level of security at all times.  We will treat your personal data as confidential and will only use it in the pursuit of our legitimate interests in establishing and growing our business and for the purpose of insurance, taxation and in accordance with General Data Protection Regulations and Privacy and Electronic Communication Regulations.

We will collect information about you when you contact us, register with us, use our services online or in person and by any means of contact be it, by post, e-mail, telephone, social media, website contact page, or as a member of our website education and holistic support academy.

How will we use the information we collect about you?

  • securely store and use it to respond to your interest, requests and enquiries
  • to provide you with any services which you order from us either online, in person, in private or in a group workshop or retreat environment.
  • to maintain good service relations
  • to provide evidence of and to maintain good record keeping of our business
  • to report to the I.C.O
  • for accounting purposes and to report to and provide records to HMRC
  • to improve and develop the services we offer by analysing your information including information related to your usage of our website
  • on the basis of our legitimate interests to provide you with valuable levels of follow up and to further our business. We will send you information about products and services which we deem to be of interest to you following on from our previous interactions or in response to specific requests.
  • Seek your agreement to receive automated email marketing. Email marketing is used with respect to your right not to be bombarded with emails. It is conducted solely to offer you value. We seek only to bring value in the form of information, special offers, competitions or to notify you of new services in line with your previous indication of interest and our service provision to you. However provision to easily unsubscribe from any email marketing campaign will be clearly visible in all automated marketing.

Who we share your data with

Any company outside of the E.U doing business with us are expected by the I.C.O to take GDPR compliancy as seriously as we do. We are satisfied that the companies who support us to manage our business and have access to your data including those outside the E.U, share our intent and ethos to be GDPR compliant.

  • Mailchimp Mailing List Subscription
    If you choose to subscribe to our mailing list, the data you enter during the signup process will be sent to Mailchimp (The Rocket Science Group, LLC), which we use to manage email marketing subscriber lists and send emails to our subscribers. Click the link below to read their privacy policy. Please note that this will take you to their website.

https://mailchimp.com/legal/privacy/

  • GoDaddy – Our membership site database is securely stored on https//:www.refreshcoachingandtraining.com and hosted with GoDaddy. It is only accessed by the Data Controller and those parties listed here or those otherwise enlisted to perform a task or tasks under contract from time to time and under the discretion and authority of Refresh Ltd. Please click on the link below to read Go Daddy’s privacy policy.

https://uk.godaddy.com/privacy

  • Payment Processing with Paypal and Yorkshire Bank – Refresh do not store financial information in the process of payment, nor do we share such information. All payments are administered and processed via Paypal and Yorkshire Bank. Should transaction provision change, the changes will be updated and transparently reflected in the privacy policy. Please click on the links below to read the privacy policies of Paypal and Yorkshire Bank.

https://secure.ybonline.co.uk//legal-privacy/

https://www.paypal.com/uk/privacy-full

  • Neos Technology

Delegate access to https//:www.refreshcoachingandtraining.com is provided to Neos Technology for the purpose of supporting Refresh with website GDPR compliance and general site maintenance and improvements in functionality. Please find their privacy policy below.

Privacy Policy

  • Others

From time to time we may use other adhoc business support services or business partners in our legitimate interests for business growth and service improvement. These connections will be subject to contractual agreements. We will only work with companies or individual partners who we are satisfied hold our values towards GDPR compliancy and who are considered to operate with integrity and fairness as we do.

We will never share or sell your information to third party marketeers.

We will share your information with government officials or agencies upon their request, or contact them, in the interests of alerting them to any protection/fraudulent issue/activity which may arise.

We may share information in order to sell or purchase business assets in our legitimate interests to manage and grow our business.

Can you update your information?

Yes. You can inform us of any changes and we will update them for you. In the case of your online membership to this site, you may update your information by editing it yourself in your membership account area or failing this, by contacting us by email. Please help us keep your personal data up to date by notifying us of any changes as soon as possible. This helps us to help you keep your information safe and confidential.

Can you ask for a copy of the information we hold?

Yes. We aim to deal with all requests within 48 hours wherever possible, however we have 3o days to comply with your request dependent upon our capacity to respond weighed against the extent of your request.

For instance, should the request involve technical expertise in relation to cookies or online membership activity; this may be a delegated task for our technical experts/website support partners. Response times may be restricted by workload, holiday and sickness.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or even refuse to comply with your request in extreme circumstances. This will be considered in each individual circumstance and charges may apply at our discretion but will be waived for mitigating and justifiable reasons where possible.

We need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, security purposes or on the basis of our legitimate interests.

Membership of Our Online Academy, Refresh & Rise

  • Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

  • Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

  • Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Completing a contact form sends email directly to rosanna@refreshcoachingandtraining.com. Refresh Coaching & Training uses Outlook email. Email is directed to Outlook via Godaddy servers.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

For more on Cookies. Please see our Cookie policy.

Analytics

By default WordPress does not collect any analytics data.

How long we retain your data?

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Data processing arising from personal consultation or therapy will be kept in accordance with UK Taxation Law, for insurance purposes and research purposes. As a general rule information will be kept for no longer than 6 years from the last date of enquiry or service interaction unless otherwise deemed necessary. Any reasons to hold information for longer periods due to extenuating circumstances will be weighed against best practice, due diligence and compliance with U.K law.

Where we send your data

All transfers of site data outside the European Union is intended to be safeguarded to European data protection standards. This includes web hosting, cloud storage, or other third party services.

European data protection law requires data about European residents which is transferred outside the European Union to be safeguarded to the same standards as if the data was in Europe. We have created this site with your security in mind. There is anti spam software, Macaffee Security and SSL Certificates.

Visitor comments may be checked through an automated spam detection service.

How we protect your data

We assure you of our best efforts and precautions to ensure that all transactions are safe and private. This website is McAfee Protected and Secure.

All information recorded by hand during 1-2-1 consultations is stored in a locked and secure location.

All communications are conducted using hardware that is password protected, updated and secure.

What data breach procedures we have in place

The security of our website is monitored by McAfee, GoDaddy and at Refresh director level.

Our internal paper based processing is limited to Refresh Coaching & Training Ltd and monitored at director level.

Hardware i.e. any computer, mobile phone, iPad used to access clients’ personal data is regularly monitored, maintained and checked for viruses.

Any breach discovered will be reported to the I.C.O and to those individuals who are thought to have been affected at the earliest opportunity and within 24 hours of discovering the breach.

What third parties we receive data from?

We do not receive any third party data

What automated decision making and/or profiling we do with user data

We do not operate any automated decision making or profiling software

Additional information

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. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

If you have any further queries at all then please do not hesitate to contact rosanna@refreshcoachingandtrainng.com at any time.