PRIVACY POLICY

INTRODUCTION...

The privacy and confidentiality of our clients and visitors to www.annabutlercoaching.com (referred to as our website) are important to us, and we are committed to protecting the personal data that we obtain. We ensure that we deal with your personal data is in compliance with all current applicable data protection laws.

This privacy policy details how the data you provide us with, or that we may collect, is processed when visiting our website.

Please note that from time to time, our website may contain hyperlinks to third party websites. Any inclusion of links to third party websites are not an endorsement and such sites operate independently from our website – we cannot accept any responsibility or liability for the privacy practice of such third parties. Should you choose to visit / use any of these third party websites, you do so at your own risk and we advise you review their respective privacy policies.

INFORMATION COLLECTED...

When you visit www.annabutlercoaching.com, we may collect and process the following information which may also include your personal information:

Type of Information:

When using the “Get in Touch” (Contact) form you submit the following information which we may collect and store:

Your first and surname;
Your email address;
Your telephone number (if shared); and
Any other personal information that you may provide in a message you submit.

When using the “Booking System” you submit the following information which we may collect and store:

Your first and surname;
Your email address;
Your telephone number; and
Any other personal information that you may provide in a message you submit.

In addition, we collect the Internet Protocol (IP) address used to connect your computer to the Internet. We may also use software tools to measure and collect session information, including page response time, length of visits to certain pages, page interaction information and methods used to browse away from the page.

PURPOSE FOR THE PROCESSING AND LEGAL BASIS FOR PROCESSING...

We may legally process the personal information we collect on the basis that we have a legitimate interest (namely the proper protection of our business again risk) and / or in the performance of a contract.

Additionally we may process your data to:

Respond to your enquiries;
Provide you with information about the products, services and upcoming events we offer;
Perform our contract for sales of our products and services;
Create and maintain your own account with us;
Manage risk, prevent other illegal or prohibited activities or if necessary for compliance with legal obligation we are subject to, or in order to protect your vital interests or the vital interests of another natural person;
Obtain or maintain insurance coverage, managing risk or obtaining professional advice; and / or
Resolve issues, fix problems or make improvements to our website.

The legal basis for this is providing consent OR the performance of a contract between you and us and / or taking steps at your request, to enter such a contract.

WHO IS THIS INFORMATION SHARED WITH?

We keep your information confidential. We will not sell your information. We may disclose your information to our personnel and to third party suppliers or subcontractors (including our independent consultants, data analytics providers and cloud based data processing and hosting providers).

If we do share your information, we will only do insofar as it is reasonably necessary for the purposes set out in this privacy policy, and provided that the recipients do not make independent use of the information and have agreed to adhere to the rules set out in this privacy policy.

OUR APPROACH TO MARKETING...

Type of Information:

Our website does not contain third party advertising.

We may collect information about you in order to send you our promotional or marketing communications, such as;

Your first and last name;
Your email address; and
Any other personal information that you may provide in a message you submit to us.

PUPOSE OF THE PROCESSING AND LEGAL BASIS FOR THE PROCESSING...

Where we provide you with information about our products, services, offers (such as via our e-newsletters) or if we contact you for market research purposes (such as surveys and feedback requests), we will only use your personal information in this way in accordance with laws relating to marketing directly to individuals, and in the pursuit of our legitimate interest of marketing our business.

If you have asked to be added to our mailing list, we will provide your details to a third party company called Mail Chimp that helps us to provide and manage our newsletters. We provide these communications on the basis that you have asked and consented to receive these.

If you change your mind, you may opt-out at any time vis the unsubscribe feature that appears in our emails or by contacting us at hi@annabutlercoaching.com.

WHO IS THIS INFORMATION SHARED WITH?

We will not share with any third party the personal information that we obtain about you for the purposes of marketing, except for as stated in this policy and only where those third parties have agreed to make no independent or further use of that data and to maintain its confidentiality.

DATA SHARING WITH OTHER PARTIES...

In addition to the processing we undertake ourselves, we also use third party processors to collect, export, store and otherwise process our data, include personal data, on our behalf. The processors that we engage include (without limitation):

Dropbox (storage)
Location: EU
https://www.dropbox.com/en_GB/privacy

Google LLC (for Google Drive) (Cloud Storage)
Location: US (EU-US Privacy Shield certified)
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Google LLC (for Google Analytics) (Web Management Tools)
Location: US (EU-US Privacy Shield certified)
See above for Google LLC EU-US Privacy Shield certification link

We Transfer (Cloud Storage)
Location: EU
https://wetransfer.com/legal/privacy

Mail Chimp (Newsletters)

Location: US (EU-US Privacy Shield certified)

https://mailchimp.com/legal/privacy/

WIX (website host)

Location: Worldwide, including EU & US (EU-US Privacy Shield Certified)

https://www.wix.com/about/privacy

ABOUT COOKIES...

A cookie is a file containing an identifier a string of letters and numbers that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

MANAGING COOKIES...

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Please note, blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you may not be able to use all features on our website.

COOKIES USED ON OUR WEBSITE...

(Answers will follow the format : Cookie Name – Duration – Purpose)

Strictly Necessary Cookies…

ForceFlashSite – Session – When viewing a mobile site (old mobile under m.domain.com) it will force the server to display the non-mobile version and avoid redirecting to the mobile site
hs – Session – Security
smSession – Persistent (Two days or two weeks) - Identifies logged in site members
XSRF-TOKEN – Session – Security

Functionality Cookies…

svSession - Persistent (Two years) - Identifies unique visitors and tracks a visitor’s sessions on a site
SSR-caching – Session - Indicates how a site was rendered.
smSession – Persistent (Two weeks) - Identifies logged in site members

Third Party Cookies…

TS* - Session – Security
TS01******* - Session – Security
TSxxxxxxxx (where x is replaced with a random series of numbers and letters) - Session – Security
TSxxxxxxxx_d (where x is replaced with a random series of numbers and letters) - Session – Security

OTHER SERVICE PROVIDERS...

Our website uses website analytics, including Google Analytics, to evaluate and improve our website, personalise your experience and to offer the best, most accessible service possible to all of our customers.

To find out more about Google Analytics and to learn how to opt out, please visit:

When you visit our website, these analytics service providers may collect the following data, which will almost always be anonymised and aggregated before reporting back to us:

number of visitors to our website;
pages visited while at our website and time spent per page;
page interaction information, such as scrolling, clicks and browsing methods;
websites where visitors have come from and where they go afterwards;
page response times and any download errors;
date and time of the visit; and / or
other technical information relating to end user device, such as IP address, access status/HTTP status code, your operating system and interface or browser plug-in.

We process this information to understand how visitors use our website and to compile statistical reports regarding that activity (for example, your IP address is used to approximate the country from which you access our website, and we aggregate this information together so we know that, for example, whether most of the visitors to our website come from the EU or from elsewhere).

This processing is crucial to the running of our online business and we therefore undertake such monitoring in the pursuit of our legitimate interests in improving our website to provide a better service and source of information to visitors.

This information is not used to develop a personal profile of you.

YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE PROCESS...

You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest:

to ask for a copy of data we are processing about you and have inaccuracies corrected;
to ask us to restrict, stop processing, or to delete your personal data;
to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/

To make a request in relation to any of the aforementioned rights, please email hi@annabutlercoaching.com

UPDATING INFORMATION...

Please let us know if the personal information that we hold about you needs to be corrected or updated.

CHILDREN...

We do not knowingly use our website to solicit data from or market to children under the age of 13 or sell any of our products or services directly to children.

If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us or has been otherwise interacting with us via our website without consent of a parent or guardian, we ask that this be brought to our immediate attention. We will make it our priority to address this situation and delete information relating to a child as soon as practicable.

HOW LONG DO WE KEEP YOUR INFORMATION FOR?

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary. Once the purpose for which information has been collected has been fulfilled, we will either permanently delete your personal information or remove all identifiers within it so that it is no longer personal data. We may use such anonymised data for research and/or business analysis purposes.

Where you have provided us with personal information in order to set up an account with us, we will retain those details for as long as your account remains active.

Where you have signed up to our mailing list, we will retain your details for as long as you remain on that list. If you unsubscribe, we will remove your details from the list.

Where we obtain your personal data in relation to the use or purchase of our services or products, including VAT or invoicing information, we are obligated by law to keep this for a minimum of 6 years.

INTERNATIONAL DATA TRANSFERS...

Our servers are hosted by WIX and the information that we collect directly from you will be stored on their servers (which are located all over the world, including Europe and the US), as well as back up servers. We may also transfer your personal data to our third party service providers, many of whom may be located outside of the EU, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EU.

There are agreements in place to ensure that any international transfers of personal data to our affiliates or third party service providers have appropriate safeguards that meet the requirements of EU data protection laws.

Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses. Alternatively, where personal data is transferred to the US, many of those US third party service providers are certified under the EU-US Privacy Shield framework approved by the European Commission.

To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

To find out more about the EU-US Privacy Shield certification, please visit: https://www.privacyshield.gov/Program-Overview

If you would like to find out more about these safeguards or about our international transfer of data, please let us know by contact us at hi@annabutlercoaching.com

AMENDMENTS TO THE PRIVACY POLICY...

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

We will notify you of significant changes to this policy by email or through a notice on our website.

CONTACT...

This website is owned and operated by Anna Butler. Questions, comments and requests in relation to this privacy policy are welcome – you can contact by:

Using our website contact form; or
Email (hi@annabutlercoaching.com).