Last updated 26/05/2018
The purpose of this policy is to outline how Happiness Transformation handles and manages the personal data in relation to third parties accessing our website.
This policy applies to the Happiness Transformation website: www.happinesstransformation.co.uk
3.1. INFORMATION ABOUT US
www.happinesstransformation.co.uk is a site operated by Happiness Transformation. We are a sole trader based in England and Wales. Our trading name is Morrin Consulting LTD. Our main trading address is Tremartyn, Hammersley lane, Penn, Bucks, HP10 8HB
We are committed to protecting and respecting your privacy. We are responsible for protecting your personal information as a “data controller” under applicable data protection legislation. If you have any queries about this policy or how we use your personal information, please contact us using the details at Contact Us.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.happinesstransformation.co.uk you are accepting and consenting to the practices described in this policy.
Our nominated person for data protection is Aoife Morrin, Founder and you can contact her using firstname.lastname@example.org
3.2. WHAT INFORMATION DO WE COLLECT?
We collect personal data as defined by applicable data protection legislation. The personal information we collect might include name, email address, postal address, and telephone number and health information as provided by you during our questionnaires.
If you provide services to Happiness Transformation, we will collect information in line with your contract for services.
If you have purchased goods or services from us, we will collect information about your purchase history.
We may collect information that is available in the public domain, for example: newspaper or online media items, publicly available posts on LinkedIn or social media or Companies House listings.
We record your requests for information and any communication we receive from you and record emails for quality assurance purposes.
We may also collect technical information relating to your use of our website, including your browser type or the Internet Protocol (IP) address used to connect your computer to the Internet.
We also gather general information about the use of our website, such as which pages users visit most often and which services, events or facilities are of most interest. We may also track which pages users visit when they click on links in emails. We may use this information to personalise the way our website is presented when users visit, to make improvements to our website and to ensure we provide the best service for users. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our website.
3.3. HOW DO WE COLLECT INFORMATION?
We obtain personal information from you when you use our website, enquire about our activities, register with us, complete a questionnaire, send or receive an email, ask a question or otherwise provide us with personal information during our interactions.
We may also receive information about you from third parties, for example from data providers or from individuals or third-party organisations who share our interests and may introduce you to us.
3.4. WHY DO WE COLLECT THIS INFORMATION?
We collect this information for the purpose of contacting you with relevant updates about our business including marketing messages and to help us monitor performance and engagement. The lawful basis for which we process your information is:
- your consent;
- processing is necessary for the performance of a contract to which you are a party. If you fail to provide this information we may be unable to perform the contract; and
- processing is necessary for our legitimate interest in promoting our business and services, except where your rights as a data subject override our legitimate interest.
3.5. HOW DO WE USE THIS INFORMATION?
We will use your personal information:
- to provide you with services, products or information you have requested;
- to provide you with information about future events and products and services we think may be of interest to you, including third-party events, products and services;
- for administration purposes including to create an account for you if you register with us; to notify you about changes to our services; as part of our efforts to keep our site safe and secure; and to ensure that content from our site is presented in the most effective manner for you and for your computer; and
- to make suggestions and recommendations to you about goods or services that may interest you.
- to help us monitor and profile the types of clients who buy from us
- for the purposes on continuous professional development, membership with professional bodies and accreditation
- for the purposes of accounting and tax obligations
We will only use your personal information for electronic marketing purposes if we are allowed to do this by law or if we have your consent. If you agree to us providing you with marketing information, you can always opt out at a later date. If you would rather not receive marketing material from us, please let us know at any time using the contact details at Contact Us.
3.6. DO WE SHARE YOUR INFORMATION WITH ANYONE ELSE?
We share your personal information with:
- third-party system operators for the purpose of marketing communication deployment, CRM and finance management and for assistance with administrative tasks such as data entry, event management, marketing and so on; and
- our trusted affiliates as detailed below
We may need to provide your information to our contractors and suppliers who provide services on our behalf, to the extent necessary to enable you to receive those services.
We may need to provide your name and preferred contact details to the coaches professional associations for the purposes of professional membership and accreditation.
We many need to share your information with HMRC and other official bodies for the purposes of fulfilling our tax and accounting obligations.
We may share your personal information with third parties for the purpose of our own marketing implementation. We will never pass your data to a third party for their own marketing purposes.
We may share your data with third parties for the purposes of creating ‘look-a-like’ prospective client profiles to which we can target marketing messages.
Some of the online systems we use host data outside of the EEA and are contracted either via an MCC or Privacy Shield to handle your data in line with EU requirements.
We may share your information with the service providers or other associated organisations as identified in this policy to use the information for their own purposes as described above.
We may also need to disclose your information if required to do so by law or as expressly permitted under applicable data protection legislation.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
3.7. HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We keep your information for no longer than necessary. We will retain your information for any period required by law, for example for compliance with HMRC requirements. Where we are not under a legal obligation to retain your information, we will determine what is necessary by reference to the lawful basis for processing set out above and our legitimate interests.
If you have any questions about how long we keep your information, please write to us at email@example.com
3.8. HOW DO WE PROTECT PERSONAL INFORMATION?
We take appropriate technical and organisational measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.
You should be aware that the use of the Internet is not entirely secure and although we will do our best to protect your personal data we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet. Any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features such as encryption to try to prevent unauthorised access and in line with our Security policy.
Happiness Transformation also provides training and support for staff and independent contractors who handle personal data, so that they can act confidently and consistently. In addition to being open and transparent, Happiness Transformation will seek to give individuals as much choice as is possible and reasonable, over what data is held and how it is used.
Happiness Transformation is committed to ensuring that in principle, data subjects are aware that their data is being processed and:
- for what purpose it is being processed
- what types of disclosure are likely
- how to exercise their rights in relation to the data.
3.10. COMMUNICATING OUR DATA PROTECTION PROCESSES
There’s a variety of guidance that is issued to all employees and associates to ensure adherence to these commitments. The guidance that is currently issued, and updated regularly, consists of:
- Data Protection process requirements
3.11. YOUR RIGHTS
You have a right to access the information we process about you. This includes being provided with a copy of the information we hold about you, the purposes for which we use it and with whom it has been shared (‘right of access’).
You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (‘right to rectification’). If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records.
In order that we can ensure that your personal information is accurate and up to date, if any of the information that you have provided us with changes, for example if you change your email address, name, payment details, or if you wish to cancel your registration, please let us know using the contact details at the end of this policy.
You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’). This right does not apply where our legal basis for processing is to perform a task carried out in the public interest or to exercise official authority.
You have a right to seek the erasure of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations, or for reasons of public interest.
In certain circumstances, for example if you contest the accuracy of the information or the lawfulness of our processing, you may ask us to restrict our processing of your information (‘right to restriction’).
If you exercise your right to restrict processing, we would still need to process your information to the extent permitted by law, including for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons.
If our lawful basis for processing is your consent, you have the right to withdraw your consent at any time.
You have the right to object to our processing in accordance with our legitimate interests, in which case we may only continue to use your personal data where we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms.
You have a right to prevent us from processing your data for the purposes of marketing.
If you would like to exercise any of your rights above, please contact us at firstname.lastname@example.org We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.
You have a right to report any of your concerns about our use of your data to the Information Commissioner’s Office. You may do so by calling their helpline at 0303 123 1113.
3.13. CHANGES TO THIS POLICY