Privacy Policy

We are Thinking Space Coaching Ltd.  We’re a company registered in England and Wales with company number 14910078, whose registered address is at 68 King Edward Road, Maidstone, Kent, ME15 6PJ.  In this privacy notice we will refer to ourselves as ‘we’, ‘us’ or ‘our’. We are the Data Controller of the personal information we collect, hold and use about you, as explained in this notice.

You can get hold of us in any of the following ways: 

1. by phoning us on +44 7852 591555; 

2. by emailing us at thinkingspacecoach@gmail.com; or 

3. by writing to us at Thinking Space Coaching Ltd., 68 King Edward Road, Maidstone, Kent, ME15 6PJ.  

We take the privacy, including the security, of personal information we hold about you seriously.  This privacy notice is designed to inform you about how we collect personal information about you and how we use that personal information.  You should read this privacy notice carefully so that you know and can understand why and how we use the personal information we collect and hold about you. 

We have appointed Lucy Entacott as our Data Protection Officer. You can contact them using the details set out above.

We may issue you with other privacy notices from time to time, including when we collect personal information from you.  This privacy notice is intended to supplement these and does not override them.  

We may update this privacy notice from time to time.  This version was last updated on 11 June 2023.

1. Key Definitions

The key terms that we use throughout this privacy notice are defined below, for ease:

• Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used. 

• Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer-base.) 

• Personal Information: in this privacy notice we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified.  It does not apply to information which has been anonymised.

• Special Information – certain very sensitive personal information requires extra protection under data protection law.  Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life and sexual orientation and also includes genetic information and biometric information.  

2. Details of personal information which we collect and hold about you

(2.1 ) Set out below are the general categories and details of retention periods in relation to those categories (see section 8 below for more details about retention) and in each case the types of personal information which we collect, use and hold about you: 

General Category	Types of Personal Data in that category	Retention Periods
Identity Information	This is information relating to your identity such as your name	Your name will be stored for 7 years from the end of the relevant tax year, in accordance with HMRC. Your name may be stored for a longer period of time if required for evidence of coaching hours. Other identity information, such as marital status, disclosed by you and collected by me (for example, in session notes) will be anonymised, and then deleted or destroyed after 24 months of our last session, unless otherwise agreed with you.
Contact Information	This is information relating to your contact details such as e-mail address and, telephone numbers	Your email address may be kept for future contact, with your permission (for example, when you sign up to our mailing list). If relevant, your email address will also be stored as required for evidence of coaching hours. This will be kept safe in a password-protected file on a password protected device. If we communicate by phone, your telephone number may be stored in a password-protected mobile device to help us identify you when you communicate.
Payment Information	This is information relating to the methods by which you provide payment to us such as bank account, credit or debit card details and details of any payments (including amounts and dates) which are made between us.	Payment details will be stored for 7 years from the end of the relevant tax year, in accordance with HMRC.
Transaction Information	This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details.	These details will be stored for 7 years from the end of the relevant tax year, in accordance with HMRC.  Number of coaching sessions, coaching start and end date, and number of paid for or pro-bono coaching hours, may be stored for a longer period of time if required for evidence of coaching hours.
Survey Information	This is information which we have collected from you or which you have provided to us in respect of surveys and feedback.	Some survey information will be anonymised, and you will be informed when this is the case.  Non-anonymised survey information, such as feedback forms, will be stored for future reference.
Website, Device and Technical Information	This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device)	This data is not collected by us, but may be collected by our website hosting platform, which is currently Bluehost.  You can find their privacy policy here: https://newfold.com/privacy-center

(2.2) The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.

3. Details of special information which we collect and hold about you

(3.1) Special information is explained in section 1 above.  It is possible that you may disclose special information during the course of our work together, such as during a coaching session. This will only be collected if it is deemed relevant to the outcomes of our work together. Coaching session notes are anonymised and will be deleted or destroyed after 24 months of our last session, unless otherwise agreed with you.

(3.2) We do not collect information from you relating to criminal convictions or offences.

4. Details of how and why we use personal information 

(4.1) We are only able to use your personal information for certain legal reasons set out in data protection law.  There are legal reasons under data protection law other than those listed below, but in most cases,  we will use your personal information for the following legal reasons: 

a) Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you; 

b) Legitimate Interests Reason: this is where the use of your personal information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests. 

c) Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and 

d) Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons. 

(4.2) As explained in section 3 above, there are more sensitive types of personal data which require higher levels of protection.  Where we process such sensitive types of personal data we will usually do this in the following circumstances: 

a) We have your explicit consent; 

b) Where it is necessary in relation to legal claims;

c) Where you have made the personal data public.

(4.3) So that we are able to provide you with services, we will need your personal information.  If you do not provide us with the required personal information, we may be prevented from supplying the services to you.

(4.4) It is important that you keep your personal information up to date.  If any of your personal information changes, please contact us as soon as possible to let us know.  If you do not do this then we may be prevented from supplying the services (for example, if you move address and do not tell us, then your goods may be delivered to the wrong address).

(4.5) Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time.  If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice.  If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information – in which case, we will confirm that reason to you.  

(4.6) We have explained below the different purposes for which we use your personal information and, in each case, the legal reason(s) allowing us to use your personal information.  Please also note the following: 

a) if we use the Legitimate Interests Reason as the legal reason for which we can use your personal information, we have also explained what that legitimate interest is; and 

b) for some of the purposes we may have listed more than one legal reason on which we can use your personal information, because the legal reason may be different in different circumstances.  If you need confirmation of the specific legal reason that we are relying on to use your personal data for that purpose, please contact us using the contact details set out at the start of this privacy notice. 

Purpose	Legal Reason(s) for using the personal information
To enrol you as a customer	Contract Reason. Legitimate Interests Reason (in order to offer you other services or digital content which helps us to develop our business)
To process your transaction, which includes taking payment from you, advising you of any updates in relation to your order or any enforcement action against you to recover payment.	Contract Reason. Legitimate Interests Reason (in order to recover money which you owe us)
To manage our contract with you and to notify you of any changes	Contract Reason. Legal Obligation Reason.
To comply with audit and accounting matters	Legal Obligation Reason
For record keeping, including in relation to delivering the contract, and in relation to delivering a potential future contract with you in the 24 months following completion of the previous one.	Contract Reason. Legal Obligation Reason. Legitimate Interests Reason (in order to support you in a potential future contract that begins within 24 months of the previous one, by being able to refer to our records regarding the previous contract)  Legitimate Interests Reason (in order to provide evidence to authorities of services delivered, for example evidence of coaching hours to the International Coaching Federation for accreditation)
To improve the services, and/or digital content which we supply	Legitimate Interests Reason (in order to improve the services, and/or digital content for future customers and to grow our business)
To recommend and send communications to you about, services, and/or digital content that you may be interested in.  More details about marketing are set out in section 11 below	Legitimate Interests Reason (in order to grow our business) Consent Reason
To ensure the smooth running and correct operation of our website	Legitimate Interests Reason (to ensure our website runs correctly)
To understand how customers and visitors to our website use the website and interact with it via data analysis	Legitimate Interests Reason (to improve and grow our business, including our website, and to understand our client’s needs, desires and requirements)

(4.7) Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes.  Because this is grouped together with other personal information and you are not identifiable from that combined data we are able to use this.  

(4.8) Under data protection laws we can only use your personal information for the purposes  we have told you about, unless we consider that the new purpose is compatible with the purpose(s) which we told you about.   If we want to use your personal information for a different purpose which we do not think is compatible with the purpose(s) which we told you about then we will contact you to explain this and what legal reason is in place to allow us to do this. 

5. Details of how we collect personal information and special information

(5.1) We usually collect Identity Information, Contact Information, Payment Information, Transaction Information, Survey Information, Special Information; directly from you when you fill out a form, survey or questionnaire, purchase goods, services and/or digital content from us, or contact us by email, telephone, in writing or otherwise.  This includes the personal information which you provide to us when you subscribe to our mailing list, or enter a competition or survey. 

6. Details about who personal Information may be shared with

(6.1) We may need to share your personal information with other organisations or people.  These organisations include: 

a) Third parties who may include: 

(i) Suppliers: such as IT support services, payment providers, administration providers, marketing agencies, who are based in the UK or US; 

(ii) Government bodies and regulatory bodies: such as HMRC and  fraud prevention agencies, [who are based in the UK;

(iii) Our advisors: such as lawyers, accountants, auditors, insurance companies who are based in the UK;;

(iv) Our bank (currently Starling Bank) who are based in the UK;

(v) Email platforms who are based in the UK;

b) any organisations which propose to purchase our business and assets in which case we may disclose your personal information to the potential purchaser. 

(6.2) We do not sell or trade any of the personal information which you have provided to us.

7. Details about transfers to countries outside of the EEA

(7.1) If any transfer of personal information by us will mean that your personal information is transferred outside of the EEA then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information, as is given to it within the EEA and that the transfer is made in compliance with data protection laws (including where relevant any exceptions to the general rules on transferring personal information outside of the EEA which are available to us – these are known as ‘derogations’ under  data protection laws).  We may need to transfer personal information outside of the EEA to the third parties listed above in section 6 who may be located outside of the EEA.

(7.2) The safeguards set out in data protection laws for transferring personal information outside of the EEA include: 

a) where the transfer is to a country or territory which the EU Commission has approved as ensuring an adequate level of protection;

b) where personal information is transferred to another organisation within our group, under an agreement covering this situation which is known as “binding corporate rules”; 

c) having in place a standard set of clauses which have been approved by the EU Commission; 

d) compliance with an approved code of conduct by a relevant data protection supervisory authority (in the UK, this is the Information Commissioner’s Office (ICO); 

e) certification with an approved certification mechanism; 

f) where the EU Commission has approved specific arrangements in respect of certain countries, such as the US Privacy Shield, in relation to organisations which have signed up to it in the USA.

8. Details about how long we will hold your personal information

(8.1) We will only hold your personal data for as long as is necessary.  How long is necessary will depend upon the purposes for which we collected the personal information (see section 4 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons).  We may also need to keep personal information in case of any legal claims.

(8.2) We have set out above the details of our retention periods for different types of data. You can find them in section 2 and also in section 3.

9. Automated decision making 

(9.1) ‘Automated decision making’ is where a decision is automatically made without any human involvement.  Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences).

(9.2) Data protection laws place restrictions upon us if we carry out automated decision making (including profiling) which produces a legal effect or similarly significant effect on you. 

(9.3) We do carry out automated decision making (including profiling) which produces a legal effect or similarly significant effect on you.  If we do decide to do this then we will notify you and we will inform you of the legal reason we are able to do this. 

10. YOUR RIGHTS UNDER DATA PROTECTION LAW

(10.1) Under data protection laws you have certain rights in relation to your personal information, as follows:

a) Right to request access: (this is often called ‘subject access’).  This is the right to obtain from us a copy of the personal information which we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used. 

b) Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed. 

c) Right to erasure: (this is often called the “right to be forgotten”). This right only applies in certain circumstances.  Where it does apply, you have the right to request us to erase all of your personal information. 

d) Right to restrict processing: this right only applies in certain circumstances.  Where it does apply, you have the right to request us to restrict the processing of your personal information. 

e) Right to data portability: this right allows you to request us to transfer your personal information to someone else. 

f) Right to object: you have the right to object to us processing your personal information for direct marketing purposes.  You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section 4 above) and there is something about your particular situation which means that you want to object to us processing your personal information.  In certain circumstances you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing). 

(10.2) In addition to the rights set out in section 10.1, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent.  Further details about this are set out in section 4.5.

(10.3) If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice.  If you do make a request then please note:

a) we may need certain information from you so that we can verify your identity;

b) we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and

c) if your request is unfounded or excessive then we may refuse to deal with your request. 

11. Marketing

(11.1) You may receive marketing from us about similar goods and services, where either you have consented to this, or we have another legal reason by which we can contact you for marketing purposes. 

(11.2) However, we will give you the opportunity to manage how or if we market to you. In any e-mail which we send to you, we provide a link to either unsubscribe or opt-out, or to change your marketing preferences. To change your marketing preferences, and/or to request that we stop processing your personal information for marketing purposes , you can always contact us on the details set out at the beginning of this notice. 

(11.3) If you do request that we stop marketing to you, this will not prevent us from sending communications to you which are not to do with marketing (for example in relation to services or digital content which you have purchased from us).

(11.4) We do not pass your personal information on to any third parties for marketing purposes. 

12. Complaints

If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO).  Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position.  You can contact us using the details set out at the beginning of this privacy notice. 

13. Third Party Websites

Our website may contain links to third party websites such as social media sites connected to the business.  If you click and follow those links then these will take you to the third party website.  Those third party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them