DATA PRIVACY AND COOKIE POLICY

This is the Data Privacy and Cookie Policy of the Universal Coaching Alliance.

We respect your privacy and are determined to protect your personal data. The purpose of this Data Privacy Policy is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how data protection law protects you.

This Data Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

1. WHO WE ARE AND IMPORTANT INFORMATION
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. HOW WE USE YOUR PERSONAL DATA
5. WHO WE SHARE YOUR PERSONAL DATA WITH
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. Changes to this notice and your duty to inform us of changes
11. QUERIES, REQUESTS OR CONCERNS

 1. WHO WE ARE AND IMPORTANT INFORMATION 

 What is the purpose of this Data Privacy Policy?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up as a member/sign up for a newsletter/purchase a product or service.

This website is not intended for children, and we do not knowingly collect data relating to children.

You must read this Data Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Data Privacy Policy supplements the other notices and is not intended to override them.

 Data controller(s)

The Universal Coaching Alliance is the controller and responsible for your personal data (referred to as the Universal Coaching Alliance, “we”, “us” or “our” in this Data Privacy Policy). Our contact details are 156a Burnt Oak Broadway, Edgware, Middlesex, United Kingdom, HA8 0AX.

For all data matters contact data@universalcoachingalliance.org

 Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not 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.

 2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name/last name/ username/.
• Contact Data includes billing address/delivery address/email address/ telephone numbers.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. however, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Data Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

Directly. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

• Apply for our products or services;
• Create an account on our website;
• Subscribe to our service or publications;
• Request marketing to be sent to you.

 4. 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

• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the 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. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting data@universalcoachingalliance.org
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party 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 at data@universalcoachingalliance.org

 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, with the legal bases we rely on to do so.

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. Please contact us at data@universalcoachingalliance.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1. Purpose/Activity – To register you as a new customer

The type of data we will record is:

1. Identity
2. Contact

The lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you
2. Purpose/Activity – To process and deliver your order including:
   1. Manage payment, fees and charges
   2. Collects and recover money owed to us

The type of data we will record is:

1. Identity
2. Contact

The lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you
2. Necessary for our legitimate interest (to recover debts due to us)
3. Purpose/Activity – To manage our relationship with you which will include:
   1. Notifying you about changes to our terms or Data Privacy Policy
   2. Asking you to leave a review or take a survey

The type of data we will record is:

1. Identity
2. Contact
3. Profile
4. Marketing and communications

The lawful basis for processing including basis of legitimate interest

1. Performance of a contract with you
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interest (to keep our records updated and study how customers use our products/services)
4. Purpose/Activity – To administer and protect our business and this website including:
   1. Troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

The type of data we will record is:

1. Identity
2. Contact
3. Technical

The lawful basis for processing including basis of legitimate interest

1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
2. Necessary to comply with a legal obligation
3. Purpose/Activity – To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you:

The type of data we will record is:

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and communications
6. Technical

The lawful basis for processing including basis of legitimate interest

1. Necessary for our legitimate interests (to study how customers use our products/services, to develop them. To grow our business and to inform our marketing strategy)
2. Purpose/Activity – To use data analytics to improve our website, deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you:

The type of data we will record is:

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and communications
6. Technical

The lawful basis for processing including basis of legitimate interest

1. Necessary for our legitimate interests (to study how customers use our products/services, to develop them. To grow our business and to inform our marketing strategy)
2. Purpose/Activity – To make suggestions and recommendations to you about goods or services that may be of interest to you:

The type of data we will record is:

1. Identity
2. Contact
3. Technical
4. Usage
5. Profile

The lawful basis for processing including basis of legitimate interest

1. Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.]

 Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Universal Coaching Alliance for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by e-mailing data@universalcoachingalliance.org at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service experience or other transactions.

Information about our use of Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies.            

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies.       

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies.           

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies.           

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

Change of purpose

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please data@universalcoachingalliance.org

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

 5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal information with any member of our group, which means any subsidiaries, any ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

• Business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
• Analytics and search engine providers that assist us in the improvement and optimisation of the Site; and
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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.

6. INTERNATIONAL TRANSFERS

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). They may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your enquiries, the processing of your payment details and/or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this Data Privacy Policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Please contact us at data@universalcoachingalliance.org if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 7. DATA SECURITY

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.

 8. DATA RETENTION

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, accounting, or reporting requirements.

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.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 9. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please-mail data@universalcoachingalliance.org

 No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

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.

 10. Changes to this notice and your duty to inform us of changes

This version was created on 8^th December 2023 and is due to be revised on 8^th December 20245.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

 11. Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact data@universalcoachingalliance.org

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.