We are Barefoot Coaching Ltd (“We”, “us”, “our”). Our websites can be found at www.barefootcoaching.co.uk and www.barefootcoachingcards.co.uk (our “Website(s)”).
Here at Barefoot Coaching, we take the privacy and security of your personal data very seriously. This policy explains what personal data we collect about you, why we need it, how we use it and the rights you have regarding it. The policy applies to any personal data we collect from you, whether you provide us with that data by browsing either of our Websites, working for us as a coach, taking any of our courses or receiving personalised coaching from any of our associates.
We will be the data controller of your personal data. This means we make decisions about what data to collect from you, what we will do with that data and where we will transfer it. Many of our life coaching activities are carried out by associates, who are self-employed life coaches in their own right. This means that they will also be controllers of your personal data along with us.
This policy consists of 3 parts:
Part A: Your Personal Data
(4) WHO HAS ACCESS TO YOUR DATA?
(5) RETENTION AND DELETION OF DATA
(6) THE RIGHTS YOU HAVE REGARDING YOUR DATA
(7) THE INFORMATION COMMISSIONER’S OFFICE
Part B: Website Cookies
Part C: Contact Information
By visiting either of our Websites, you are agreeing to all of the terms in this policy, this includes (but is not restricted to) the acceptance of the use of essential cookies in accordance with the terms of this policy.
PART A: YOUR PERSONAL DATA
(1) WHAT DATA DO WE COLLECT?
We may collect any or all of the following kinds of personal data from you:
Category – Data Recorded
Contact Data – Billing address, postal address, email address, contact telephone number.
Financial Data – The last 4 digits of the card from which you have made any payment to us.
Identity Data – Title, full name, sex and gender, marital status, occupation.
Marketing and Communications Data – Your preferences regarding whether or not you wish to receive marketing material from us.
Technical Data – The internet protocol address you use to access our Website, your log-in data, browser type and version, location, operating system and device type.
Tracking Data – The clickstream that brought you to our Website, geographic data and the frequency of your use.
Transaction Data – Details about what services you or your employer have purchased from us in the past, when these services were provided and the price you paid for them.
Usage Data – Information about how you navigate our Website, how long you spend on each page and how often you visit.
Special Category Data and Criminal Convictions Data
We do not collect any data from you which is classified as “special category data.” In brief, special category data is personal information about you which relates to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We also do not collect data about criminal convictions or offences.
(2) HOW WE COLLECT YOUR DATA
We use different methods to collect data from and about you including through:
Direct Interactions
You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you purchase a course, sign up to be a coach, receive coaching from us, or correspond with us for any other reason.
Interactions with Your Employer
Where your employer has asked one of our associates to provide coaching to you and/or any of your coworkers, we may receive contact data and identity data about you from your employer directly. Where this occurs, we will only use that data to contact you about the services we are able to offer.
Automated Technologies or Interactions
As you interact with any of our websites, we will automatically collect tracking data, technical data and usage data about your device, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our cookies. Please see part 2 of this privacy policy for further details about what cookies are and how we use them.
Third Parties
We will receive personal data about you from various third parties, as further described in paragraph 4 below.
(3) HOW WE USE YOUR DATA
Generally, we do not rely on consent as a legal basis for processing your personal data. We will only use your personal data when the law allows us to. Most commonly, we will use the following legal bases when processing it:
a) Where we need to perform the contract, we are about to enter into or have entered into with you (e.g. when you become one of our associates, or purchase a course from us);
b) To protect your vital interests (e.g. if we reasonably believe that there is a risk of imminent harm);
c) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
d) Where we need to comply with a legal obligation.
Where we rely on our own legitimate interests to process your data, those interests are:
a) To administer and protect our business;
b) To market our services and target our marketing more effectively; and
c) To use data analytics as a way of improving the user experience on our Websites.
(4) WHO HAS ACCESS TO YOUR DATA?
We will never sell your personal data. However, we may share it with suppliers who provide services to our business. The table below sets out the categories of service provider we use, and what personal data may be shared with them:
Services Provided | Explanation/Example | Data Disclosed |
|---|---|---|
Associates | Our life coaches are often self-employed individuals. | All data, except for tracking data,
transaction data and usage data. |
Professional Advisors | Accountants, lawyers and other suppliers of professional services – we use Xero for many of our back-office accounting needs. | All personal data necessary for the
provision of the service requested. |
IT Services | Our web host is Nublue. Other IT
functions are provided by Saint Associates. We use industry standard software for the storage of documents and email – namely Microsoft 365 and SharePoint. | All data. |
Marketing and SEO | Tracking data and usage data – though note that Google may
combine the personal data we disclose with other data it already
has. | |
Payment Providers | Contact data, identity data, transaction data. |
Examples from the table above should not be regarded as an exhaustive list of all the suppliers we use within a given category. However, whenever we share your data with any third party, they will be subject to a contract which imposes strict obligations of confidentiality and compliance with UK data protection laws on them. If any of them are based outside the UK or a safe destination under data protection law, we will ensure that suitable contracts are put in place with them to keep your personal data secure whilst it is in their possession.
Please note that we may disclose your personal data to a third party where:
a) We need to do so to comply with any applicable law, regulation, legal process or governmental request;
b) We believe, in good faith, that we need to disclose personal data about you in order to prevent harm to any person;
c) We need to do so to investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud, safeguarding or security issues;
d) To establish or defend legal claims; or
e) If we sell, transfer or merge our business or any part of it. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
(5) RETENTION AND DELETION OF DATA
As a general rule, our data retention periods are intended to ensure that we never keep personal data we no longer need.
We will retain your personal data as follows:
All personal data collected in accordance with para 2 of this part will be retained for a minimum period of 7 years following the date of collection.
It is not always possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the purpose for which we collected that data originally. However, we may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
(6) THE RIGHTS YOU HAVE REGARDING YOUR PERSONAL DATA
Under certain circumstances, you have rights under data protection law in relation to your personal data. You have the right to:
a) Request access to the personal data we hold about you;
b) Request corrections to any of the personal data we hold, if it is inaccurate;
c) Ask us to erase your personal data;
d) Object to the way in which we process your personal data; or
e) Request transfer of your personal data in a commonly-used file format.
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 could refuse to comply with your request in these circumstances. If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your
request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
(7) THE INFORMATION COMMISSIONER’S OFFICE
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues. Details of how to do this can be found on their website, which you can access by clicking here. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
PART B: WEBSITE COOKIES
(1) ABOUT COOKIES
Our Websites use local storage (such as cookies) to provide you with the best possible experience and to allow you to make use of certain functionality.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree.
Cookies serve to distinguish you from other users of the Website. They may allow us to remember that you have visited our Website before, or to tailor it for use on your device. They also help us understand our visitors better (e.g. by letting us analyse how visitors are directed to our Website, what the most popular pages are, and what devices are used most often to browse the Website). If you would like to learn more about cookies and how they work, you can click here for more information.
(2) COOKIES OUR WEBSITE USES
Whilst visiting either of our websites you accept and consent to the use of the following cookies and terms.
Our website uses a range of different cookies:
has_js – www.barefootcoaching.co.uk
_gid – .barefootcoaching.co.uk
_gat – .barefootcoaching.co.uk
_ga – .barefootcoaching.co.uk
__stid – .sharethis.com
pxcelPage_c010 – .t.sharethis.com
pxcelBcnLcy – .t.sharethis.com
__stid – .sharethis.com
__stid – .sharethis.com
(3) MANAGING YOUR COOKIES
You can block certain types of cookie on your browser directly. To learn how to do this, please visit the page which corresponds to the browser you are using:
If your browser is not included in the list above, please consult its documentation directly.
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
By blocking all cookies, it will have a negative impact upon the usability of many Websites, including our own. If you block cookies, you will not be able to use all the features on our Websites.
To opt-out of most Marketing Cookies used by services such as Google and Facebook, then visit the below links and follow the instructions on screen:
PART C: CONTACT INFORMATION
FOR GENERAL CONTACT
If you have any queries regarding our Privacy and/or Cookie Policy, then please feel free to get in touch using one of the contact methods below:
Telephone Number: 01332 863641
Email Address: info@barefootcoaching.co.uk
Mailing Address: Unit 6E, Boundary Court, Willow Farm Business Park, Castle Donington, Derbyshire, DE74 2NN
FOR DATA CONTACT
If you would like information on the data, we currently store on yourself, this includes any requests for updating, deleting or supplying the data. Then please get in touch using the below details, please note any requests for data interaction will carry a 10 GBP administrative charge.
Telephone Number: 01332 863641
Email Address: info@barefootcoaching.co.uk
Mailing Address: Unit 6E, Boundary Court, Willow Farm Business Park, Castle Donington, Derbyshire, DE74 2NN
This policy was last updated on [24/01/2022]