Coaching Culture Ltd - Privacy Policy 

We respect and value the privacy of everyone whose data we process and we will only collect and use Personal Data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law. The procedures and principles set out in this Policy will be followed at all times by us as a company, as well as our employees, agents, sub-contractors or other parties working on our behalf. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Software. If you do not accept and agree with this Privacy Policy, you must stop using our Software immediately.

1. Definitions and Interpretation In this Policy, the following terms have the following meanings: “Client” means any individual, firm or corporate body utilising our Software; “Client Personal Data” means the data inputted and documents uploaded to the Software by the Client or its authorised users; “Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. This definition shall, where applicable, incorporate the definitions provided in the General Data Protection Regulation 2016/679 (“GDPR”) and Data Protection Act 2018 (“DPA 2018”); “Software” means the subscription based software provided by us; “User” means employees uploaded by the client to the software; “We/Us/Our” means Coaching Culture Limited a company registered in England and Wales under company number 10855629 whose registered office address is at The Old Chapel, Old Cherry Lane, Lymm, Cheshire. WA13 0TA. 

2. What Does This Policy Cover? This Privacy Policy applies to our processing of Personal Data when you become a Client of ours and when Client Personal Data is uploaded to our Software. 

3. Rights under Data Protection Laws 3.1 All data subjects have the following rights under the data protection laws, which this Policy and our use of Personal Data have been designed to uphold: 3.1.1 The right to be informed about our collection and use of Personal Data; 3.1.2 The right of access to the Personal Data we hold about you (see section 10); 3.1.3 The right to rectification if any Personal Data we hold about you is inaccurate or incomplete (please contact us using the details in section 11); 3.1.4 The right to be forgotten – i.e. the right to ask us to delete any Personal Data we hold about you (we only hold your Personal Data for a limited time, as explained in section 5 but if you would like us to delete it sooner, please contact us using the details in section 11); 3.1.5 The right to restrict (i.e. prevent) the processing of your Personal Data; 3.1.6 The right to data portability (obtaining a copy of your Personal Data to re-use with another service or organisation); 3.1.7 The right to object to us using your Personal Data for particular purposes; and 3.1.8 Rights with respect to automated decision making and profiling. 3.2 If you have any cause for complaint about our use of your Personal Data, please contact us using the details provided in section 11 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. 3.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens’ Advice Bureau. 

4. What Data Do We Collect? 4.1 We collect and process the following Personal Data in order for us to provide our Software to you as a Client of ours: 4.1.1 Name; 4.1.2 Contact information including email address, trading address, and telephone number; 4.1.3 Billing address and contact information, if this is different from your trading address; 4.1.4 Account log-in information, including all authorised users’ usernames (please note we cannot access passwords and if necessary, these will need to be reset using the link within the Software); 4.1.5 Client Personal Data relating to other data subjects that you may upload to the Software or otherwise make available to us (you will be advised when entering into a contract with us that you must first obtain the permission of any data subjects whose details you provide or make available to us and warrant that you have obtained that permission); 4.1.6 Your IP address, web browser type and version and operating system. 4.2 We collect and process the following Personal Data for Users added to the software platform by the Client: 4.2.1 Name and email address 4.2.2 User generated content in response to activities, exercises, challenges, feedback, questions, surveys, diagnostics, reports & psychometrics 

5. How Do We Use Your Data? 5.1 As administrators of the Software, we (and those authorised by us) have access to the back-end of the Software and this allows us to view all Client Personal Data that has been inputted into the Software. We warrant that all such persons with access will only process Client Personal Data to the extent necessary for us to provide our support. In any case, it will not be used for any other purpose and will not be stored other than for the purposes of providing our services to you and for making back-ups. 5.2 All Client Personal Data will be deleted from the Software within one year after and if subscription has ended to ensure any restart of the subscription service within this period allows for a smooth re-start unless otherwise agreed or requested. All other Personal Data will be retained for no longer than is necessary in light of the reason(s) for which it was first collected. 5.3 Our use of your Personal Data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your Personal Data, or because it is in our legitimate interests. Specifically, we may use your data for the following purposes: 5.3.1 Supplying our Software and support to you (as set out above, we require your Personal Data in order to enter into a contract with you); 5.3.2 Replying to emails from you; and 5.3.3 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing us directly). 5.4 Any Personal Data inputted for profiling purposes is collected to enable us fulfil our obligations to you and provide the relevant information needed to ensure you get the most out of your use of the Software. 5.5 With your permission and/or where permitted by law, we may also use your data for marketing purposes. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR, DPA 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. 5.6 You have the right to withdraw your consent to us using your Personal Data at any time, and to request that we delete it. Unless we have reasonable grounds to refuse to delete the Personal Data, we will comply with all requests for deletion within one month of receipt of your request, and will keep you informed of progress. 

6. How and Where Do We Store Your Data? 6.1 We only keep your Personal Data for as long as we need to in order to use it as described above in sections 4 and 5, and/or for as long as we have your permission to keep it. 6.2 We will only store your data in the UK, however, third party processors we use may store data elsewhere, as set out in section 7. 6.3 Data security is very important to us and to protect your data, we have taken suitable measures to safeguard and secure data collected. 

7. Do We Share Your Data? 7.1 We may sometimes contract with other third parties to supply services to you on our behalf. In some cases, these third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely and in accordance with your rights, our obligations and the obligations of the third party under the law. 7.2 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any Personal Data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under all data protection laws. 7.3 In certain circumstances, we may be legally required to share certain data held by us, which may include your Personal Data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order or a governmental authority. 

8. What Happens If Our Business Changes Hands? 8.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any Personal Data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us. 8.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. 

9. How Can You Control Your Data? 9.1 In addition to your rights, set out in section 3, when you submit Personal Data to us, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details). 9.2 Prior to uploading Client Personal Data into the Software, you are responsible for setting permissions for your authorised users within the Software. 9.3 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving. 

10. How Can You Access Your Data? You have the right to ask for a copy of any of your Personal Data held by us (where such data is held). Please contact us for more details using the contact details below in section 

11. 11. Contacting Us If you have any questions about our Site or this Privacy Policy, please contact us by email at [email protected] Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 10, above).

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The Chapel,
Old Cherry Lane,
Lymm
WA13 0TA

0161 410 0707
[email protected]

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