Privacy Policy
1. Introduction
This Privacy Policy describes how Off the Mark Coaching ("Off the Mark Coaching," "we," "us," or "our") collects, uses, discloses, and protects the personal data of individuals who visit our website or otherwise interact with us. We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
2. Data Controller
For the purposes of the GDPR, the Data Controller (as described in the GDPR) is:
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Name: Mark Edward Hamilton
Business Name: Off the Mark Coaching
Contact Information:
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Mailing Address:
Off the Mark Coaching
Unit 1-94
39 Ludgate Hill
London
EC4M 7JN
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As the data controller, Mark Edward Hamilton is responsible for determining the purposes and means of processing personal data, ensuring compliance with applicable data protection laws, and safeguarding the rights of individuals regarding their personal information. If you have any questions about how your data is handled or your rights as a data subject, please contact Mark Edward Hamilton using the information provided above.
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3. Collection of Personal Data
We may collect personal data directly from you when you voluntarily provide it to us, such as when you fill out forms on our website, contact us via email or phone, or request information about our life coaching services. The types of personal data we may collect include your name, email address, phone number, and any other information you choose to provide related to your coaching needs.
We may also collect personal data automatically when you interact with our website. This may include your IP address, device information, browser type, log and usage data, and browsing behaviour. We use cookies and similar technologies to collect this information to improve your experience and tailor our services. Please refer to our Cookie Policy for more details.
In some cases, we may request additional information such as your physical address or billing information, transactional information, and payment details (for example, payment method and credit card information) to facilitate the payment process for our services. We may also request additional authentication information (such as copies of your government-issued ID, passport, or driving licence) as permitted by applicable laws to ensure the security of transactions and compliance with relevant regulations.
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4. Use of Personal Data:
We use the personal data we collect for the following purposes:
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a) Providing websites: To deliver and maintain our life coaching services, including responding to your inquiries and fulfilling your requests for information.
b) Marketing Communications: To send you marketing communications, updates, and promotional materials if you have opted to receive them.
c) Website Analytics: To analyse and understand how our website is used, diagnose technical issues, and improve functionality and performance.
d) Legal Compliance: To comply with applicable laws, regulations, and legal obligations relevant to our services.
e) Protection of Rights: To protect our rights, property, and safety, as well as the rights, property, and safety of our users and the public.
f) User Communication: To communicate with you about activities on our website, including policy changes and service updates.
g) Payment Processing: To process your financial information and payment details for services purchased.
h) Security Measures: To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activities, and take action against those responsible.
i) Research and Development: To undertake research for technological development and demonstration in enhancing our services.
j) Website Improvement: To improve, upgrade, or enhance our website’s features and functionality.
k) Quality Control: To ensure internal quality control of our services and processes.
l) Identity Verification: To verify your identity and prevent fraudulent activity.
m) Error Debugging: To identify and repair errors that may impair the intended functionality of our services.
n) Policy Enforcement: To enforce our terms and policies regarding service usage.
o) Customised Materials: To provide you with tailored materials about offers, products, and services that may be of interest to you, including new content and services.
p) Vital Interests: To protect your vital interests or as may be required for the public good.
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We will only use your personal data for the purposes for which we collected it, unless we reasonably determine that we need to use it for another compatible reason. If you wish to understand how the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis for doing so. Please note that we may process your personal data without your knowledge or consent, where permitted by law.
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5. Legal Basis for Processing Your Personal Data:
Where relevant under applicable laws, all processing of your personal information will be justified by a "lawful ground" for processing. In the majority of cases, processing will be justified on the basis that:
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a) Consent: You have provided your consent for us to use your personal information for a specific purpose, such as receiving marketing communications or other tailored content.
b) Contractual Necessity: Our use of your personal information is necessary to perform a contract with you or take steps to enter into a contract, for example, to provide the life coaching services you have requested.
c) Legal Compliance: The processing is necessary to comply with a relevant legal or regulatory obligation we have, such as obligations related to fraud prevention or data protection.
d) Legitimate Interests: The processing is necessary to support our legitimate interests as a business, such as improving our services and enhancing user experience, provided that such processing is conducted in a manner that respects your interests and fundamental rights and is proportionate to the benefits we seek to achieve.
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6. Disclosure of Personal Data:
We may share your personal data with third parties in the following circumstances:
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a) Website Providers and Partners: With service providers and business partners who assist us in delivering our life coaching services and operating our business, subject to appropriate confidentiality and security measures to protect your information.
b) Legal Compliance: With competent authorities, law enforcement agencies, or other third parties when required by law or necessary to protect our rights, property, or safety, or the rights, property, or safety of others.
c) With Your Consent: With your consent or at your direction, for specific purposes related to our services.
d) Business Transactions: With third parties in the event of a merger, acquisition, or sale of all or a portion of our assets, where your personal data may be transferred as part of that business transaction.
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Otherwise, we do not sell, rent, or trade your personal data to third parties for their marketing purposes. Your privacy and the security of your personal data are important to us.
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7. Data Retention:
We will store your personal data for as long as it is reasonably necessary to achieve the purposes set forth in this Privacy Policy, including providing our life coaching services to you. This retention period encompasses the duration during which you use our website and services.
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Additionally, we will retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Once your personal data is no longer needed for these purposes, we will securely delete or anonymise it in accordance with applicable laws and regulations.
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8. Data Security:
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include, but are not limited to, encryption, access controls, and secure storage solutions.
However, please note that no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security. It is important for you to take precautions when sharing your personal information online and to use secure methods of communication whenever possible.
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9. Your Rights:
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are outlined below:
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a) Right to be Informed: You have the right to be informed about the collection and use of your personal data.
b) Right of Access: You have the right to request access to your personal data that we hold about you.
c) Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data.
d) Right to Erasure: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected.
e) Right to Restrict Processing: You have the right to request the restriction of processing your personal data under certain conditions.
f) Right of Data Portability: You have the right to request the transfer of your personal data to another organisation, or to you, under certain conditions.
g) Right to Object to Processing: You have the right to object to our processing of your personal data.
h) Right to Withdraw Consent: You have the right to withdraw consent to processing your personal data at any time where we rely on consent as the legal basis for processing.
i) Right to Make a Complaint: You have the right to make a complaint to the data protection authorities if you believe your rights have been violated.
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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. Alternatively, we may refuse to comply with your request in these circumstances.
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We may 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. We may also contact you to ask for further information in relation to your request to expedite our response.
We aim to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made several requests. In such cases, we will notify you and keep you updated on the progress.
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10. International Data Transfers:
We may transfer your Personal Data to countries outside the European Economic Area (EEA) or the United Kingdom (UK) when necessary for the purposes outlined in this Privacy Policy. By providing your Personal Data, you consent to such transfer.
In the event of an international transfer of Personal Data, we will ensure that appropriate safeguards are in place to protect your Personal Data and ensure compliance with data protection laws. Such safeguards may include:
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a) Standard Contractual Clauses: We may use standard contractual clauses approved by the European Commission or the UK Information Commissioner's Office (ICO) for transfers of Personal Data to third countries.
b) Binding Corporate Rules: If applicable, we may rely on Binding Corporate Rules (BCRs) adopted by us for transfers within our group of companies.
c) Adherence to Approved Codes of Conduct or Certification Mechanisms: We may transfer Personal Data in accordance with approved codes of conduct or certification mechanisms, where applicable.
d) Consent: Where necessary, we will obtain your explicit consent for the transfer of your Personal Data outside the EEA or the UK.
e) Legitimate Interests: In certain circumstances, we may rely on our legitimate interests to transfer Personal Data internationally, provided such interests do not override your rights and freedoms.
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You have the right to request further information about the safeguards used by us for international data transfers, as well as to obtain a copy of any relevant documentation by contacting us using the details provided in the "Contact Us" section below.
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Please note that transfers of Personal Data outside the EEA or the UK may be subject to different data protection laws and regulations, which may not provide the same level of protection as those within the EEA or the UK. However, we will take all reasonable steps to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.
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11. Third-Party Links:
Our website may contain links to third-party websites that are not operated by us. If you click on these links, you will be directed to the third-party website. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services.
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As such, we cannot be held liable for the protection and privacy of any information you provide while visiting such websites, as they are not governed by this Privacy Policy.
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We encourage you to review the privacy policy of every website you visit, including those linked to from our site, to understand how your information will be handled by those third parties.
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12. Changes to This Privacy Policy:
We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our website or by other available means, and you will have the opportunity to review the revised Privacy Policy.
By continuing to access or use the website after those changes become effective, you agree to be bound by the revised Privacy Policy.
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13. Contact Us:
If you have any questions or concerns about our privacy practices or this Privacy Policy, you can contact us by email at offthemarkcoaching@hotmail.com. Please provide as much detail as possible in your message to help us address your enquiry or issue effectively.
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We strive to respond to all enquiries promptly and within a reasonable timeframe.