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 Website privacy notice

  1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.louisadaubney.co.uk

By providing us with your data, you warrant to us that you are 13 years of age or over.

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

Contact Details

Our full details are:

Full name of legal entity: Louisa Daubney trading as Louisa Daubney Coaching

Email address: hello@louisadaubney.co.uk

Postal address: Merchant House, 5 East St Helen Street, Abingdon, Oxfordshire, OX14 5EG

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 hello@louisadaubney.co.uk

  1. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through the email sign up form, contact form or meeting scheduling tool on our website, over the phone, through email, text, social media messaging, social media posting, completing an online survey or questionnaire or any other communication that you send us. We process this data for the purposes of communicating with you, improving our service offerings to match your needs and interests, for 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, communicate with you, keep records and to establish, pursue or defend legal claims.

Prospect Data that includes data relating to any enquiries made about our services (e.g. through our online contact form or our email address) such as your name and email address and that we process in order to reply to your enquiry and keep records of this, the processing is necessary in order to take steps at your request. Our lawful ground for this processing is our legitimate interests in which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claim.

Prospect Data that includes data, obtained as a result of you signing up for any of our free resources, such as your name and your email address, and that we process in order to send you those free resources, reply to your communications about said resources and keep records of this, the processing is necessary in order to take steps at your request, you have given consent to the processing for the purposes of us sending you the free resource. Our lawful ground for this processing is our legitimate interests in which in this case are to reply to your communications, to send you the free resources requested, keep records, and to establish, pursue or defend legal claim.

Customer Data that includes data relating to any purchase of our services such as your title, name, billing address, delivery address, email address, phone number, purchase details and your (credit) card details. We process this data to create a contract or agreement with you, process your order, supply the services you have purchased, respond to any enquiries related to the contract or service, inform you about any updates to the service, deal with any complaints, and keep records of such transactions. Our lawful ground for this processing is our legitimate interests which in this case is in updates to the service, the performance of a contract between you and us and/or take steps at your request to enter into such a contract, keep records and to establish, pursue or defend legal claims.

User Data that includes data that we have obtained through our analytics tracking tool about how you use our website and any other online platforms together with any data that you post for publication on our website or through other online platforms. We process this data to operate our website and ensure 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 and, to establish, pursue or defend legal claims.

In the future, we are planning to use: Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content. 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, and to establish, pursue or defend legal claims.

We may use Customer Data and User Data to deliver relevant website content. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We may also use Communications Data, Customer Data, and User Data, 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 establish, pursue defend legal claims.

Sensitive Data

We may collect the following sensitive data about you in order to deliver the services:

Information about your health

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

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 fully perform the contract (for example, to deliver 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 hello@louisadaubney.co.uk. 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.

We do not carry out automated decision making or any type of automated profiling.

hCaptcha

We use the hCaptcha security service (hereinafter “hCaptcha”) on our website. This service is provided by Intuition Machines, Inc., a Delaware US Corporation (“IMI”). hCaptcha is used to check whether user actions on our online service (such as submitting a login or contact form) meet our security requirements. To do this, hCaptcha analyzes the behavior of the website or mobile app visitor based on various characteristics. This analysis starts automatically as soon as the website or mobile app visitor enters a part of the website or app with hCaptcha enabled. For the analysis, hCaptcha evaluates various information (e.g. IP address, how long the visitor has been on the website or app, or mouse movements made by the user). The data collected during the analysis will be forwarded to IMI. hCaptcha analysis in the “invisible mode” may take place completely in the background. Website or app visitors are not advised that such an analysis is taking place if the user is not shown a challenge. Data processing is based on Art. 6(1)(b) of the GDPR: the processing of personal data is necessary for the performance of a contract to which the website visitor is party (for example, the website terms) or in order to take steps at the request of the website visitor prior to entering into a contract. Our online service (including our website, mobile apps, and any other apps or other forms of access offered by us) needs to ensure that it is interacting with a human, not a bot, and that activities performed by the user are not related to fraud or abuse. In addition, processing may also be based on Art. 6(1)(f) of the GDPR: our online service has a legitimate interest in protecting the service from abusive automated crawling, spam, and other forms of abuse that can harm our service or other users of our service. IMI acts as a “data processor” acting on behalf of its customers as defined under the GDPR, and a “service provider” for the purposes of the California Consumer Privacy Act (CCPA). For more information about hCaptcha’s privacy policy and terms of use, please visit the following links: https://www.hcaptcha.com/privacy and https://www.hcaptcha.com/terms

  1. 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 services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

We will never share your personal details with any third party for their own marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at hello@louisadaubney.co.uk at any time.

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, warranty registrations etc. 

  1. DISCLOSURES OF YOUR PERSONAL DATA

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

  • Service providers who provide IT and system administration services and marketing services.
  • Professional advisers including lawyers, bankers, auditors and insurers
  • Government bodies that require us to report processing activities.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

  1. INTERNATIONAL TRANSFERS

We are subject to the provisions of the UK General Data Protection Regulations (UK GDPR) that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

  • We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data by; or
  • If we use US-based providers that are part of a UK regulator approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or
  • Where we use certain service providers who are established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the UK government which give personal data the same protection it has in the UK.

If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

  1. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

  1. 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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

Under data protection laws you have 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.

You can see more about these rights at:

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

If you wish to exercise any of the rights set out above, please email us at hello@louisadaubney.co.uk

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 refuse to comply with your request in these circumstances.

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 you for further information in relation to your request to speed up our response.

We try 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 you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, 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). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

  1. 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.

  1. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.louisadaubney.co.uk/cookies-policy

This Privacy Notice is effective from 21st December 2023.