INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.martaabramska.com and the subsequent coaching process.

 

We reserve the right to modify this privacy policy at any time, so please review it frequently. It has been last updated on the 7th of September 2018. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

By providing us with your data, you warrant to us that you are over 18 years of age.

Marta Abramska is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

 

Email address: coaching@martaabramska.com
 

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at coaching@martaabramska.com 

 

WHAT DATA DO WE COLLECT ABOUT YOU AND HOW IT IS TREATED
 

Personal data means any information capable of identifying an individual. We may process the following data about you:

 

Information about you when you register an interest in our products or services via our website.

 

That includes the use of our appointment scheduling software as well as any communication that you send to us whether that be through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, arranging appointments, record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

 

Our booking system is hosted on the Wix.com platform. Wix.com provides users with the online platform that allows businesses to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. 
 

Data relating to any purchases of goods and/or services

 

This can include your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

 

 

Data about how you use our website

 

Together with any data that you post for publication on our website (e.g. blog comments) or through other online services. We process this data to operate our website and make sure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

 

Technical Data

 

We collect the Internet protocol (IP) address used to connect your computer to the Internet. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page.

 

Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

 

Marketing Data 

 

This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, contests and special offers, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.

 

If you have consented to be contacted in this way, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes by unsubscribing or emailing us at coaching@martaabramska.com.

 

Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

 

 

We need to collect the following sensitive data about you in order to provide you with the coaching you have requested from us, and to be compliant with our insurance policy.

 

• Session Data – If you take part in an introductory session or a subsequent coaching session with us, then you will be required to acknowledge that we will take notes relating to our conversation during the session. These notes may contain sensitive data that you share with us during a session.

  • The notes will be processed and retained by us by on the grounds of legitimate interests, which in this case are to provide a high level of coaching services. 

  • We will also retain the notes on the grounds of legal obligation and Article 9, Paragraph 2 (f) of GDPR which states that sensitive data can be processed when it is necessary for the establishment, exercise or defence of legal claims. Notes must be taken and retained for at least seven years for insurance purposes. 

  • Handwritten notes will be stored in a locked cabinet and subsequently digitised, and the paper copies then shredded. 

  • Session notes may also be emailed to you for your record. This means that your sensitive data will be processed by our email provider and hosting company.

  • From time to time you may be asked to provide feedback or a testimonial. Your responses will be processed on the grounds of legitimate interests, which in this case are to provide a high level of coaching services. Testimonials may be published on our website with your consent.

  • On occasion we may request your permission to record a session. This will be for our own review of the session, or to be played to supervisors for assessment/accreditation purposes. This data will be processed on the grounds of legitimate interests, which in this case is to obtain accreditation or to develop our own coaching skills. The recorded sessions will be deleted once they are no longer required.

 

• Communication Data – If you communicate sensitive data to us through other means (such as email), we will retain that data on the grounds of legitimate interests, legal obligation and Article 9, Paragraph 2 (f) of GDPR , in the same manner as the consultation data above.

 

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at coaching@martaabramska.com In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

 

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

 

HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site, via a third-party form platform such as Google based outside the EU, or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this. 

 

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

 

We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

 

MARKETING COMMUNICATIONS
 

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.

 

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

 

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 emailing us at coaching@martaabramska.com

 

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases of good and services, etc.

 

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

• Service providers who provide IT, backup and system administration services

• Professional advisers including lawyers, bankers, auditors and insurers

• Government bodies that require us to report processing activities

• Third parties to whom we sell, transfer, or merge parts of our business or our asset

 

 

DATA RETENTION
 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

YOUR RIGHTS

 

As an individual whose personal data is processed by us you have rights which have come into effect with new GDPR regulations from 25th May 2018.  Your rights are explained in detail at

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr.

 

If, at any time you want to verify, update or amend your personal data or if you have a query about the processing of your personal data please email us at coaching@martaabramska.com.

 

You also have the right to lodge a complaint about our processing with the UK’s Information Commissioner’s Office (ICO) on https://ico.org.uk/concerns.

 

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.

 

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.

 

COOKIES POLICY
 

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

 

There are two types of cookies:

 

Session (Transient) cookies: These cookies are erased when you close your browser, and do not collect information from your computer. They typically store information in the form of a session identification that does not personally identify the user.

Persistent (Permanent or Stored) cookies: These cookies are stored on your hard drive until they expire (i.e. the are based on a set expiration date) or until you delete them. These cookies are used to collect identifying information about the user, such as Web surfing behaviour or user preferences for a specific site.

 

Take a look at the table below to view which cookies Wix places on Wix sites:

 

The format of the information below is as follows: Cookie name:Life span:Purpose

 

svSession:Persistent:Identifies unique visitors and tracks a visitor’s sessions on a site

hs:Session:Security

XSRF-TOKEN:Persistent:Security

smSession:Persistent (Two weeks):Identifies logged in site members

TSxxxxxxxx (where x is replaced with a random series of numbers and letters):Persistent:Security

TSxxxxxxxx_d (where x is replaced with a random series of numbers and letters):Persistent:Security

AWSELB:Session:Used to distribute traffic to the website on several servers in order to optimise response times.