Jaz Broughton is referred to as “I” or “me” in this policy.
Maintaining the security of your data is a priority for me, and I am committed to respecting your privacy rights. I am also dedicated to being transparent about what data I collect about you and how I use it.
This policy provides you with information about your data. This includes what personal data I collect, how I use your data, how I ensure your privacy is maintained and your legal rights relating to your personal data.
What personal data do I collect?
I may collect the following information about you:
- Name, age/date of birth and gender;
- Your contact details, postal address including billing and delivery addresses, telephone numbers and email addresses;
- Purchases made by you;
- Your web browsing activities on my website;
- When you make a purchase, your card payment details;
- Your communication and marketing preferences;
- Your interests, preferences, feedback and survey responses;
- Your location;
- Your correspondence and communication with me; and
- Publicly available personal data including information shared on social media platforms such as Twitter, Instagram and Facebook.
My website is not intended for children and I do not knowingly collect data relating to children.
This list is not exhaustive and in specific instances, I may need to collect additional data for the purposes set out in this policy. Some of the above personal data is collected directly, i.e. through online sign ups and other personal data is collected indirectly, i.e. when you are browsing my website.
How do I use your data?
I use your personal data to:
- Provide goods and services such as 1-2-1 or group coaching sessions;
- Record our coaching sessions (if applicable);
- Make a tailored website for you;
- Verify your identity;
- Prevent crime and fraud and other related purposes;
- With your agreement, to contact you electronically about promotional offers on products and services which I think may interest you;
- For promotional and marketing purposes and to tailor and personalise products and services;
- To develop products and services;
- For client insight and market research purposes, which helps me to better understand your needs;
- To enable me to manage all interactions with you; and
- Where I have a legal right or duty to disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
I use your personal data for electronic marketing purposes and providing updates on products and services which are of interest and relevant to you as an individual.
You have the right to opt out of receiving promotional communications at any time by:
- Clicking the “unsubscribe” link at the bottom of my emails
- Contacting me directly via the contact details within this policy
If you visit my website, you may receive personalised advertisements for my products and services whilst using other websites. Any advertisements you will see will relate to products or services you have viewed whilst browsing my website on your computer or other devices, or which I believe are of interest to you.
I may process data about your use of my website and services (“usage data“). The usage data may include your IP address, location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing and pattern of your service use. This is used to allow me to process and analyse the use of my website.
Your responses to surveys, feedback and competitions
I occasionally ask for feedback on my products or on how you feel I am doing. Generally, responses are anonymized but I may want to respond to you directly, for example if you mention you are unhappy with something. This also helps me improve my service.
If you enter a competition, I will need to contact you if you have won.
Legal basis for using your data
I am required to set out the legal basis for my processing of your personal data.
I collect and use your personal data as it is necessary:
- to pursue my legitimate interests;
- for the purposes of complying with my duties and exercising my rights under a contract for the sale of services to a client; or
- to comply with my legal obligations.
You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, I will cease to process data after consent is withdrawn.
My legitimate interests
The usual legal basis for processing your data is that it is necessary for my legitimate interests, which includes:
- Selling and supplying goods and services to my clients;
- Protecting clients and other individuals and maintaining their safety, health and welfare;
- Promoting, marketing and advertising my products and services;
- Sending promotional communications which are relevant and tailored to clients;
- Understanding client behaviours, preferences and needs;
- Improving existing products and services and developing new products and services;
- Complying with legal and regulatory obligations;
- Preventing crime and fraud;
- Handling client contracts, queries, complaints and disputes (including refunds);
- Managing any claims made by clients (including legal); and
- Respond to you on social media, particularly if you are unhappy with a service.
Sharing data with Third Parties
My service providers and suppliers
To make certain services available to you, I may need to share your personal data with some of my service partners. These include delivery and marketing service providers.
I only allow my service providers to handle your personal data when I have confirmed that they apply appropriate data protection and security controls.
Other third parties
Aside from my service providers, I will not disclose your personal data to any other third party, except for those set out below:
- Third party marketing partners such as Google or Facebook (to deliver advertising)
- Government bodies, regulators, law enforcement agencies, courts/tribunals and insurers where I am required to do so.
I will never sell or rent your data to other organisations for marketing purposes.
To deliver products and services to you, it may be necessary for me to share your data outside of the European Economic Area (“EEA”). This will occur when service providers are located outside the EEA.
How I protect your data
I am committed to keeping your personal data safe and secure. To do this, my security measures include the following:
- Security software to protect my website infrastructure
I will strive to protect your data in all means reasonably required by me to do so. However, data transmission is not 100% reliable so I cannot guarantee its absolute security. Therefore, I make no warranties as to the level of security afforded to your data.
How you can help me protect your data
I will never ask you to confirm any bank account or credit details via email, if you receive an email claiming to be from me asking you to do the same, please ignore it and do not respond.
How long do I keep your data?
I will not retain your data for longer than necessary, and the longest I will normally hold any personal data is 6 years.
If you no longer wish for me to hold your information, you can contact me. However, please note I have a legal requirement to keep some of your personal data even after you have asked me to delete it to ensure I can meet my legal or regulatory requirements, resolve disputes, prevent fraud or enforce my contract with you.
Your rights in respect of your data
You have rights relating to your personal information, these are:
- To ask for a copy of the personal data that I hold about you (right to access)
- To request that I delete personal data held on you, where I no longer have any legal reason to retain it (right of erasure)
- To ask me to update and correct any out of date or incorrect personal data that I hold about you (right of rectification)
- To opt out of any marketing communications that I may send to you and to object to using/holding your personal data if I have no legitimate reasons to do so (right to object)
- To ask me to restrict processing of data (only in certain circumstances)
- To ask me to supply you with some of the personal data I hold about you in a machine readable format (right to data portability)
If you wish to exercise any of the above rights, please contact me using the details below.
Data Protection Officer
As Data Protection Officer I ensure that the personal data of my clients is protected and that I comply with relevant data protection legislation.
You have the right to lodge a complaint with the Information Commissioner’s Office. You can find further information, including contact details at https://ico.org.uk.
This policy was last updated on 11 November 2021
I may update this policy from time to time so please check this page occasionally to ensure you are happy with any changes to this policy.