In order for us to operate our business and provide our services to you, it is sometimes necessary for us to collect or process information about you.
This collected information will take one or more of the following forms:
- Information that you provide to us directly, such as when completing an online form or sending us a message via our website.
- Information that is automatically sent to us by your internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on.
- Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.
OUR COMMITMENT TO DATA PRIVACY
We are fully committed to maintaining the privacy of any information (‘personal data’) that you provide to us.
We are also committed to ensuring that such data is held securely, used appropriately and only retained for as long as is necessary.
Our systems and services are designed with privacy in mind – we will only ever ask you for the minimum amount of information required to provide our services efficiently.
We retain and maintain only the minimum information that is necessary.
We aspire to comply to the fullest extent possible with the European Union’s General Data Protection Regulation (‘GDPR’) and all other applicable data protection regulations.
WHO WE ARE
In terms of your use of this website, We, Nirvana Coaching Ltd act in the capacity of Data Controller, and should you have any questions or concerns about the data we hold about you, we can be contacted using the information below:
Data Controller: Nirvana Coaching Ltd
Correspondence address: 76 Hamilton Terrace, 76 Hamilton Terrace, London, UK, NW8 9UL
Email correspondence: firstname.lastname@example.org
DEFINITION OF “PERSONAL DATA”
By ‘personal data’ we mean any information that allows us to identify you personally. The only information we will directly seek from you is your email address – and we will always ask for your explicit consent to providing this information before we collect it from you.
We may also collect other types of information, such as your computer’s ‘IP’ address or broad geographical location which do not allow us to identify you directly. We will cover the use of such data here also.
WHO WE SHARE DATA WITH
We operate on a strict ‘need to know’ basis for all personal data that we work with.
The only people/organisations that are granted access to personal data are:
- Employees of Nirvana Coaching Ltd who provide content, marketing and support services
- Our web hosting technology suppliers (currently DreamHost and Sythesis) who provide the physical server infrastructures that our website(s) operate on.
- Our newsletter service provider Aweber which collects and stores our data in their own secure data centres.
HOW YOUR DATA IS PROTECTED
We take the security of all personal data very seriously, and that data is protected in a number of ways
- Access control: access to personal data is strictly limited in line with our policy detailed in the ‘who we share data with section’ on this page. Access is controlled by individual user accounts, where a strong password policy is enforced
- Dedicated security software: We operate dedicated security scanning and access control software on all of our websites. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.
- Data encryption: where data is stored in a cloud facility (such as the storage of website backup files), that data is encrypted both ‘in transit’ and ‘at rest’ – meaning that all data is securely obscured both during the process of transfer to the cloud provider, and then additionally when it is in storage at its final location.
- Selection of third party service providers: we use a very limited number of third party service providers, but some are essential for the provision of physical hosting environments and cloud services. One of the core factors in the selection of such providers is their ability to provide secure systems and processes.
ACCESS TO YOUR PERSONAL DATA
In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:
- You have the right to obtain from us confirmation about whether any such data is being held;
- You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
- Even if you have consented to us processing your personal data, you have the right to withdraw that permission at any time;
- You have the right to require us to rectify any incomplete or incorrect information held about you;
- You have the right to require us to erase the data held about you (the ‘right to be forgotten’);
In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies):
- You have the right to object to the legal basis upon which we are collecting this data, and we have an obligation to consider and respond to that objection;
- You have the right to request the prevention of further processing of your data while your objection is considered;
- You have the right to make a complaint to the relevant data protection authority (which, in the UK, is the Information Commissioner’s Office or ‘ICO’)
- In most circumstances, you can exercise these rights without paying a fee to us.
Types of Data Collected
WEBSITE CONTACT DETAILS
When you complete one of the contact forms on our website, we will ask you for your name AND email address. This is obviously required for us to respond to your request.
Intent to contract: Additionally, the information that you provide to us here is necessary for us to fulfil your request prior to entering into a contract.
Types of processing
- We will store the information you provide to us in our website database, and/or in our self-managed Customer Relationship Management system. Such storage allows us to efficiently access your data and respond to your requests;
- We may use this information to contact you about other of our own services that we believe may be of genuine interest to you;
- We will NOT use this data for any further purpose without your express further consent;
- We will NEVER sell your information to any third party.
We will only ask you for the minimum amount of information required to appropriately fulfil your request. This will usually be your name, one or more contact details, and any specific information about your request.
If we do not enter into a further contract or agreement with you, we will retain this data for a maximum of 12 years. If you choose to enter into a service agreement with us, we will retain the data for the length of our ongoing agreement plus a maximum of 12 years.
For some website functionality, we will need to create for you a user account that allows you to login to the site to ensure that only authorised individuals can access your data and that functionality. Examples include when you make an online purchase via the site, or when you have a role in administering or contributing towards the website content (such as a blog author). The purpose of these user accounts is to protect your personal data behind login security, and to protect the integrity of our site and the servers that run it.
Protecting your interests: Website accounts are strictly necessary for the purpose of providing the functionality that you have requested, and we consider that protecting the integrity and security of your data is protecting your interests under the GDPR.
Our Legitimate interests: The protection of your personal data is a vital part of the protection that we apply to your personal data, and to the services that we offer. We consider that it is in our legitimate interest to process your account data to this end.
Types of processing
- We will store the information you provide to us in our website database, as this data is strictly necessary for the website account to function when you visit the site;
- We will NOT use this data for any further purpose without your express further consent;
- We will NEVER sell your information to any 3rd party.
We will only ask you for the minimum amount of information required to appropriately fulfil your request. We will only use mandatory/required fields where it is necessary to do so.
We will retain this data for as long as you maintain an active account, plus a maximum of 12 months.
When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical ‘IP’ address that is associated with your device and the browser type and version that you are using.
Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behaviour (such as repeated malicious attempts to access a system).
IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.
Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of ‘personal data’, and accordingly we do not seek your consent to collect it.
In the event that such anonymous data is considered to fall within the scope of the applicable data protection regulations, the legal basis for processing such data is:
Our Legitimate interest: The integrity, security and performance of our systems and infrastructure is a vital part of the services that we offer. We consider that it is in our legitimate interest to maintain and protect our systems to this end.
Types of processing
- We will store the information you provide to us in our website server logs
- For the purpose of maintaining the integrity of our systems, we may also store this data in infrastructure backups
- We will NOT use this data to attempt to identify an individual person
Server logs are automatically rotated on our systems, and are retained for a maximum of 12 months following the closure of the relevant log file.
We have included cookies, web beacons and similar technologies into one section because they all perform similar functions even if, from a technical perspective, they work slightly differently.
All of these technologies allow us to better understand how users are using our website and other related services. They can also be an essential part of providing certain online functionality. They are all essentially small data files placed on your computer (or other device) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website.
These technologies are used by most websites as they provide useful insight into how the services are being used, as well as improving speed, performance and security, and enabling us to improve our personalisation of your experience.
Cookies are small text files placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:
- Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
- Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
- First-party cookies are set by the site you are visiting.
- Third-party cookies are set by a third party site separate from the site you are visiting.
There are a number of ways that you can influence how cookies are used on your particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet Explorer, Firefox etc) allow you to set preferences for whether to allow or block website cookies.
They will also provide tools that allow you to remove any cookies that have already been set. Using the ‘Help’ functionality of your browser, or an internet search, will help you to understand how to use these features for your particular browser.
We use Google Analytics to better understand what people look at on our website.
When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) is sent in an anonymous form to Google Analytics (which is controlled by Google).
The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from the data.
We ensure that no personally identifiable information is ever contained within the data sent to our analytics providers, and we also perform a process which partially obscures your IP address information.
As analytics information is not personal data, we do not specifically ask for your prior consent.
Other Google Services
n addition to Google Analytics, we use a number of industry-standard Google services to provide particular pieces of website content. These include:
- Google Fonts: We may use one or more of Google’s web fonts to ensure that our website content is displayed in a clear and consistent fashion across all of the different types of devices and browsers.
- Google Maps: We may use the Google’s mapping services to provide dynamic geographic maps on our website
- Google Recaptcha: We may use Google’s Recaptcha service (which provides the ‘I Am Not A Robot’ functionality) on our web contact forms. This is a security measure to prevent the abuse of our contact forms by automated programs.
Each of these services involve our website making a connection to one or more Google servers, and may result in Google placing cookies on your device.
Like the vast majority of commercial websites, we use social media cookies from Facebook on our site. The cookies are placed by Facebook, and we use them to understand the effectiveness of social media campaigns that we operate.
If you are not logged into Facebook when you view our site, then it is not possible for any personal information about your visit to be collected, and therefore we do not specifically ask for your prior consent.
If you are logged into Facebook when you view our site, then Facebook will know when you visit us. We do not have any access to the detail of that personal data, as you have consented to share it with Facebook, not us. We just get to see anonymised data about the numbers of people who have responded to our advertising or other social media activity.
Your Individual Rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
We handle subject access requests in accordance with the GDPR.
Email Marketing Messages & Subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal date” above. Any email marketing messages we send are done so through a email marketing service provider (EMS). An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time.
See any marketing messages for instructions on how to unsubscribe or manage your preferences.
Our EMS provider is Aweber. We hold the following information about you within our EMS system;
- Email address
- I.P address
- Subscription time & date