Privacy Policy | Inca Coaching

INCA COACHING PRIVACY POLICY

1. Who am I?

I am a transformational coach, empowering women to create fulfilling and successful lives and careers.

This privacy policy explains what information I collect from you, why, and how I use it. It also explains how I store and share your information. This policy applies to all personal information that I process. Personal information is classed as any information about an individual that could be used (either in isolation or combined with other information) to identify that individual and as such includes work related information.

I am committed to respecting your privacy and ensuring that your data is appropriately secured and process all personal information in accordance with the General Data Protection Regulation (GDPR).

I may update this policy and my terms from time to time and will publish any updates on my website.

Any questions you have relating to my privacy policy should be directed to becs@incacoaching.com

2. What data do I hold?

My activities mean that I sometimes have to collect personal information about you. I limit the information I collect and only store the details I require in order to deliver one or more legitimate commercial purposes. Personal information means information that can be used to identify you as an individual and may include:

· Basic personal information – such as name, email address and telephone number

· Digital footprint information – such as your IP address, location coordinates and location when you interact with our website

· Professional Information – such as your job role, organisation and sector

For some client work, I need to obtain certain special categories of information that are used for specific and limited purposes. In such cases I will only process this information when you have given your specific consent to do so. This may include:

· Racial or ethnic origin

· Physical characteristics

· Behavioural information and personal history

Further detail on the conditions for processing this information are provided in section 4.

3. Where did I get your data?

Your information is collected from a range of sources depending on the relationship I have with you. It includes:

· Information you have provided to me

· Information your employer has provided for the purposes of completing a specified project

· Information that I obtain as a result of my relationship with you

· Information obtained as a result of the technology you use to interact with me (such as your IP address)

· Information that I may receive from third parties who provide a service to me (where permitted by
law and where appropriate consents have been provided by you)

4. What is the lawful basis for processing your data?

The lawful basis for processing your data will depend upon the service I am providing to you and at least one of the following will apply:

· Contractual necessity – where processing your data is necessary for me to fulfil contractual
obligations in the provision of a product or service

· Consent – where I am processing your data for a specific purpose and you have provided me with
your explicit consent to do so

· Legitimate Interests – where processing your data is necessary for my legitimate business
interests, where this does not override your interests, rights and freedoms

4.1 Conditions for processing special category data

I only process special category data in order to fulfil contractual obligations in the delivery of a product or service, such as completing a psychometric assessment for a client. In addition to the specified lawful basis for processing, the condition for processing this data is:

- Where “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes”

5. How do I process your data?

I comply with my data processing obligations under the GDPR by ensuring that your data is stored securely, kept up to date and only retained for the relevant period. I maintain appropriate technical and procedural measures to protect your data against loss, disclosure or misuse.

5.1 Processing of data outside of the European Economic Area(EEA)

Some of my supplier services may result in your data being stored outside of the EEA as a result of our usage of cloud based services.I only work with third party providers who meet the appropriate EU directive and have the appropriate protection under UK law in place.

6. How do I use your data?

I use your information in order for use to complete my business activities. The way in which your information is used will depend on the reason why I hold your data and the lawful basis for me doing so. It is only ever used for the stated and specific purpose. These include:

- For billing purposes, such as invoicing for products and services

- For the completion of services for which I have been contracted to provide

- To process sign-ups via my website or to other services offered digitally

- To ensure website functionality

- To provide you with information on products and services where you have consented for me to do so

- To support and improve the day-to-day running of my business

- To provide news and information about developments that are directly related to the services and products that you use

- To develop my relationship with you

- To provide client care and support

6.1 What I don’t do with your data

Your relationship with me is valuable and I take your data security and rights seriously:

- I do not sell your data to third parties

- I do not transfer your data to anyone other than those circumstances described in 6.2

- I do not use your data for any purpose other than those agreed to

-I do not use any automated decision-making software relating to your personal data

6.2 Third Parties

I do not share your information with third parties except:

- When I am required to do so in order to fulfil our contractual obligation for a specific product or service

- When third parties are providing a service to me whereby they act as processors of your personal information on my behalf

- When third parties are acting as sub-contractors or agents acting on my behalf

7. How long do I retain your data?

I only retain the personal data we hold for as long as is relevant for the purpose or purposes for which it was provided. This will vary as a result of different contractual requirements and data types. In determining the appropriate ‘relevant’ period to apply I consider several factors:

- Contractual requirements

- DPA guidelines

- Legal or accounting requirements

8. Your Rights

You have clearly defined rights in relation to the personal information that I process about you. Dependent upon the lawful basis upon which we are processing your data, you have the right to access, correct and delete or object to or restrict our processing of your information. If you wish to exercise these rights you can do so by contacting me at becs@incacoaching.com

Your rights are as follows:

· The right to be informed – this privacy policy is the primary mechanism that I use to inform you of how I process your information, why
and who I will share it with

· The right of access – you have a right to access the personal information I hold about you. To do so, please contact me at
becs@incacoaching.com with the subject line ‘Subject Access Request’

· The right to rectification – if you believe that information I hold about you is inaccurate you can request that we restrict the processing
of that information and to rectify the inaccurate information that I hold about you

· The right to erasure – You have a right to request that I remove all of the data that I hold about you, if you believe that:

· My processing of your data is not lawful

· The purpose for which I originally required the information is no longer valid

· I have asked for permission to process your personal information and you wish to withdraw your consent

· The right to restrict processing – you can ask that I restrict the processing of your data if:

· My processing of your data is not lawful

· You believe that information I hold about you is inaccurate you

· The purpose for which I originally required the information is no longer valid

· The right to data portability – in cases where you have provided me with consent to process your personal information or a contract
for a contract or service exists you have the right to request a copy of your information in a portable format or request that I transfer
that information directly to a third party

· The right to object – you have the right to object to me processing your personal information unless I can provide legitimate grounds
for that processing

· The right to withdraw consent – you have the right to withdraw your consent at any time in circumstances where I have asked your
permission in order to process your personal information

· The right to complain – you have the right to lodge a complaint with the Information Commissioners Office (ICO). Their Helpdesk
number is 0303 123 1113

Please note that in some cases, if you choose to restrict the way in which I process your data it may not be possible for me to fulfil my contractual obligations for certain products and services.