We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you how C Flanagan Ltd collects, processes and looks after your personal data when you visit our website (regardless of where you visit it from) and by using our services. It will also tell you about your privacy rights and how the law protects you.
We are C Flanagan Ltd. We are the controller and responsible for your personal data (collectively referred to as “Caroline Flanagan” “we”, “us” or “our” in this privacy notice). If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact at email@example.com
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified either directly or indirectly.
We may collect, use, store and transfer different kinds of personal data to include:
- Your identity and contact details;
- Your identity, ethnicity, language, nationality, country of birth, medical information and special educational needs and disabilities details;
- Attendance and absence information;
- Assessment information such as learning and progress data;
- Health and social care data to include your physical and mental health;
- Details about payments to and from you;
- Information about how you use our website and services;
- Technical data about your equipment, browser, browsing actions and patterns; and
- Your preferences in receiving marketing from us and our third parties and your communication preferences.
Where we need to collect personal data by law, or under the terms of a contract we have with you directly or with you as part of a contract with a third party, and you fail to provide that data when requested, we may not be able to provide our services to you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- our day to day dealings with you in providing our speaker, life, career, executive or other form of coaching and other services;
- filling in forms or by corresponding with us by post, phone, email or otherwise;
- if you complete a survey or provide us with feedback;
- as you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies;
- by using publicly accessible sources;
- third parties working on our behalf and our instruction that we may use to assist us with providing our services to you, such as self-employed persons;
- via third parties such as analytics providers and/or your bank or building society or other financial institutions when you pay for our services.; and
- the health care system for example from local hospitals, your GP, pharmacies, social workers, clinical commissioning groups, and other health and care professionals.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- For the performance of the contract for our services to you which have agreed or are about to agree;
- Where it is necessary for our legitimate interests (or those of a third party) which means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. However our legitimate interests must not override your own rights and interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
- Where we need to comply with a legal or regulatory obligation;
- It is necessary to protect your vital interests if you are physically or legally incapable of giving consent;
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. But we generally process your information in order to provide our services to you.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us on the details above.
When we process any special categories of information i.e. information revealing racial or ethnic origin, religious or philosophical beliefs; genetic data or health data, we must have a further lawful basis for the processing. This may include:
- where you have given us your explicit consent to do so;
- it is necessary in the field of employment, social security or social protection law;
- where the processing is necessary to protect your vital interests or your child’s or someone else’s vital interests; or
- is necessary for medical diagnosis.
If we process any information relating to your criminal convictions or offences, we will only do so in compliance with data protection legislation. Typically we rely on one of the following lawful bases:
- preventing or detecting unlawful acts;
- complying with our regulatory requirements in relation to unlawful acts or dishonesty or safeguarding;
- dealing with suspicions of terrorist financing or money laundering;
- where it is necessary for us to obtain legal advice or establish, exercise or defend legal rights.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may use your data to form a view on the products and services which we believe could be of interest to you. You will receive marketing communications from us if you have used our services or purchased a product from us or requested information from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside C Flanagan Ltd for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you using our services or other transactions.
DISCLOSURES OF YOUR PERSONAL DATA
As part of the services we provide to you, we may have to share your personal data with third parties such as:
- Third parties as part of our service to you such as self-employed contractors, payment processors, agents or IT providers;
- We may use third parties to assist us with our public relations, marketing, social media and to keep in touch with you;
- the health care system for example local hospitals, GPs, pharmacies, social workers, and other health and care professionals;
- the police or other law enforcement agencies if we have to by law or court order;
- professional advisers including lawyers, bankers, auditors, accountants and insurers;
- HM Revenue & Customs, regulators and other authorities; and
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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 notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your information will be held at our offices, by our service providers and in our IT provider’s data centres. We will try to make sure that these data centres are based in the UK wherever possible. In order for us to provide our services to you, from time to time we may have to share your personal data outside the European Economic Area (EEA). This could include where our service providers are based outside the EEA (for example our IT cloud services), if you are based outside the EEA, if there is an international element to the services we are providing or if one of our employees need to access our data remotely from outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and/or
- Where the transfer is not repetitive, information is limited, the transfer is necessary for our legitimate interests and those interests do not override your own and we have put appropriate safeguards in place to protect your data.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Otherwise, 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, regulatory, accounting, or reporting requirements. This is usually 6 years.
This website may include links to third-party websites, plug-ins and applications which may include social media. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please read third party’s privacy notices for further information relating to the collection or sharing of your data. We do not necessarily 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You are entitled to:
- request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- have your data corrected, updated or amended. Please note that we may ask you to verify any changes to your data such as a proof of change of address or name;
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it
- Object to and/or restrict processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Please note that in some instances we may have to stop providing our services to you but we will notify you if this is the case.
- Request the transfer of your personal data to you or to a third party, for example if you chose to use another business to provide services to you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
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 and keep you updated.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org You will not normally have to pay a fee for this, but we will let you know if we feel that it is fair to charge a fee, for example if your request is clearly unfounded, repetitive or excessive . Alternatively, we may refuse to comply with your request in these circumstances and will let you know if we feel that this is the case.
COMPLAINTS OR CONCERNS
If you have any queries or concerns about the way we process your personal data then please contact us at email@example.com We hope that we can resolve any concerns for you, but if you wish to take your complaint further you can contact the Information Commissioners Office (ICO) and further information can be found on their website www.ico.org.uk.
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