PRIVACY POLICY
INTRODUCTION
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We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our Site, those Site visitors who contact us directly by email and our coaching clients. We promise only to collect and use your personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
We are obliged to ask you to opt-in to our privacy and cookie policy ('Policy') and we will take no personal data from you until you have. This means that, until you have agreed to the Policy, we cannot offer any substantive help or advice.
You can opt-in to the Policy:
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if you are on the Site, by checking the Privacy Policy opt-in box when subscribing to our mailing list or sending us a message through the Site;
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if you contact us by email, by sending us an email saying that you accept our Policy; or
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if you become a coaching client, by signing the coaching agreement, which references your acceptance of this Policy.
1) DEFINITIONS AND INTERPRETATION
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To make the Policy easier to read, we have defined certain terms, as follows:
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Cookie: means a small text file placed on your computer or device by the Site when you visit or use certain parts of the Site. Details of the Cookies used by the Site are set out in Part 12 below
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Cookie Law: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any replacement of it
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Data Protection Legislation: means General Data Protection Regulation (EU Regulation 2016/679) and the Data Protection Act 2018
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Data Protection Officer: means 'Bindiya Parmar'. Email: bindiya@themindboss.com
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Site: means www.themindboss.com
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We, Us, Our: means Bindiya Parmar, Executive, Career & Life Coach at The Mind Boss
2) WHAT DOES THIS POLICY COVER?
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This Policy applies to any personal data you provide through your use of the Site and/or as a coaching client. Please note that this Site may contain links to other websites. We have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
3) WHAT IS PERSONAL DATA?
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Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified.
Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Some personal data may be sensitive in its nature. That includes health records, criminal convictions and other similar data.
4) WHAT ARE MY RIGHTS?
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Under the Data Protection Legislation, you have the following rights:
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The right to be informed about our collection and use of your personal data.
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The right to access the personal data we hold about you. Part 11 will tell you how to do this.
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The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
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The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
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The right to restrict (i.e. prevent) the processing of your personal data.
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The right to object to us using your personal data for a particular purpose or purposes.
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The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
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The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
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Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
To exercise any of the above rights, please email the Data Protection Officer.
You can always contact us for more information about your rights and we will do our best to help you. The Citizen’s Advice Bureau is also a valuable source of help.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please tell us.
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Please always contact us if you are not happy with the way we are using your personal data and we will do our best to resolve any problem. If you are not happy with any solution we offer, you have the right to lodge a complaint with the Information Commissioner’s Office.
5) WHAT DATA DO YOU COLLECT AND HOW?
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We receive, collect and store any information you enter on our Site or provide us in any other way (for example, information you provide as a coaching client). Depending on the information provided, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods set out in the table. Please also see Part 12 for more information about our use of Cookies and similar technologies.
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Data Collected:
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​Identity information including name.
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Contact information including address, email address and telephone number.
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Payment information including bank account details.
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Technical information including IP address, browser type and version.
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How We Collect the Data: We collect data using the Site or directly from you, from coaching sessions, from completed forms and otherwise.
Our Site is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our services to you. Data you enter on the Site may be stored through Wix.com’s data storage, databases and the general Wix.com applications. Wix.com store your data on secure servers behind a firewall.
6) HOW DO YOU USE MY PERSONAL DATA?
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Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
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Where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt out at any time.
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Third Parties (including payment service providers, those collecting anonymised data and others who provide services to us) may use third-party Cookies, as detailed below in Part 12. Please refer to Part 12 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
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We do not use automated systems for decision making or profiling.
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We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.
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If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7) HOW LONG WILL YOU KEEP MY PERSONAL DATA?
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We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
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Identity information including name: 6 years 6 months
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Contact information including address, email address and telephone numbers: 6 years 6 months
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Payment information including bank account details: 6 months from last use
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Technical information including IP address, browser etc.: 6 months from last use
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8) HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?
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In terms of personal data you enter on this Site, it may be stored through Wix.com’s data storage, databases and the general Wix.com applications.
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Wix can store your data in a number of locations. Your personal information may be stored in data centres located in the United States of America, Ireland, South Korea, Taiwan and Israel. Wix may use other jurisdictions as necessary for the proper delivery of their services and/or as may be required by law.
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Wix is a global company that respects the laws of the jurisdictions it operates within. The processing of your data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection.
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Any transfer to a third country, outside the European Union, that does not ensure an adequate level of protection according to the European Commission, will be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Appendix 1 of the Wix Data Processing Agreement.
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The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
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limiting access to your personal data to those employees, agents, contractors and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
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having procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
9) DO YOU SHARE MY PERSONAL DATA?
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We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
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If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Policy.
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In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10) CAN I WITHHOLD INFORMATION?
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You may access certain areas of the Site without providing any personal data at all. However, to use all features and functions available on the Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies.
11) HOW CAN I ACCESS MY PERSONAL DATA?
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If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and emailed to the Data Protection Officer.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
12) HOW DO YOU USE COOKIES?
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The Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of the Site and to provide and improve our services.
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By using the Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on the Site for analytic purposes. For more details, please refer to the table below. These third-party Cookies are not integral to the functioning of the Site and your use and experience of the Site will not be impaired by refusing consent to them.
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All Cookies used by and on the Site are used in accordance with current Cookie Law.
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Before non-essential Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to such non-essential Cookies. By giving your consent to the placing of such non-essential Cookies, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of non-essential Cookies; however certain features of the Site may not function fully or as intended.
Certain features of the Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary” or “essential”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that the Site may not work properly if you do so.
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The following first-party Cookies may be placed on your computer or device:
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The following third-party Cookies may be placed on your computer or device:
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In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access the Site more quickly and efficiently including, but not limited to, login and personalisation settings.
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It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13) CHANGES TO THIS PRIVACY AND COOKIE POLICY
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We reserve the right to modify this Policy at any time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be posted on the Site and will take effect immediately. We recommend that you check this page regularly to keep up-to-date.
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This Privacy and Cookie Policy was last updated in July 2022
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