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We employ reasonable administrative, technical and physical measures to maintain the security and confidentiality of all of your data, including name, emails and addresses.  Any client physical notes are held in a lockable cabinet before upload to our digital systems.  All notes are shredded after upload.  Client notes about sessions are destroyed 6 months after sessions end.  (And we'll contact you to let you know this.)

 

We don't hold payment details at all.  

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All PayPal transactions are subject to the PayPal Privacy Policy.  We employ reasonable administrative, technical and physical measures to maintain the security and confidentiality of any and all PayPal data and information, including data and information about PayPal users and PayPal.

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Your privacy - the much more detailed version!

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This Privacy Policy describes how and when we collect, use, and share information when you purchase an item from us, contact us, or otherwise use our services through this site.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including Mailchimp and Apple iCloud.  But we do routinely check that their privacy policies abide by our high standards for privacy and regulations like the General Data Protection Regulations.  

Information We Collect

To fulfil your booking, you must provide us with certain information, such as your name, email address, payment information, and the details of the service that you’re ordering.  You may also choose to provide us with information that will help us in coaching you.

Why We Need Your Information and How We Use It

We rely on a number of legal bases to collect, use, and share your information, including:

• as needed to provide my services, such as when we use your information to fulfil your booking, to settle disputes, or to provide customer support;

• when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for our mailing list;

• if necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your purchases if required by tax law; and

• as necessary for the purpose of our legitimate interests, if those legitimate interests are not overridden by your rights or interests, such as providing and improving my services. I use your information to provide the services you requested and in my legitimate interest to improve my services. 

Information Sharing and Disclosure

Information about our customers is important to our business. We share your personal information for very limited reasons and in limited circumstances, as follows:

• Service providers. We engage certain trusted third parties to perform functions and provide services to my shop, such as delivery companies. We will share your personal information with these third parties, but only to the extent necessary to perform these services.  Our specific service providers are:

  • Mailchimp. We use Mailchimp as our third party provider for newsletter sign up, creation and dissemination.  ​

  • Apple iCloud.  We use Apple iCloud to back up data.  At present this does not contain any customer database but may contain details of client notes.

• Business transfers. If we sell or merge our business, we may disclose your information as part of that transaction, only to the extent permitted by law. 

• Compliance with laws. We may collect, use, retain, and share your information if we have a good faith belief that it is reasonably necessary to: (a) respond to legal process or to government requests; (b) enforce my agreements, terms and policies; (c) prevent, investigate, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of my customers, or others.

 

Data Retention

 

We retain your personal information only for as long as necessary to provide you with our services and as described in our Privacy Policy. However, we may also be required to retain this information to comply with my legal and regulatory obligations, to resolve disputes, and to enforce my agreements. We generally keep your data (excluding client notes which are deleted after 6 months after the last coaching session) for the following time period: 5 years. 

 

Transfers of Personal Information Outside the EU

 

We may store and process your information through third-party hosting services in the US and other jurisdictions. As a result, we may transfer your personal information to a jurisdiction with different data protection and government surveillance laws than your jurisdiction. If we are deemed to transfer information about you outside of the EU, we rely on Privacy Shield as the legal basis for the transfer, as Google Cloud is Privacy Shield certified.

 

Your Rights

 

If you reside in certain territories, including the EU, you have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below:

• Access. You may have the right to access and receive a copy of the personal information we hold about you by contacting us using the contact information below. 

• Change, restrict, delete. You may also have rights to change, restrict my use of, or delete your personal information. Absent exceptional circumstances (like where we are required to store data for legal reasons) I will generally delete your personal information upon request. 

• Object. You can object to (i) our processing of some of your information based on my legitimate interests and (ii) receiving marketing messages from us after providing your express consent to receive them. In such cases, we will delete your personal information unless we have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons. 

• Complain. If you reside in the EU and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local data protection authority.

 

How to Contact Me

 

For purposes of EU data protection law, I, Angharad Boyson, am the data controller of your personal information. If you have any questions or concerns, you may contact me at admin@brightrebel.co.uk. Alternately, you may mail me at:

Angharad Boyson, bright rebel coaching, 83 Ducie Street, Manchester, M1 2JQ.

 

Privacy policy updated: 31 March 2021

 

To be reviewed annually.