Last updated: September 2023
We are dedicated to safeguarding and preserving your privacy when visiting our site or communicating electronically with us.
This Policy covers the following:
- Who we are
- What information do we collect?
- How do we use your information?
- Who may use your information?
- Third party links and services
- How do we protect your information?
- Where is your information processed?
- Marketing Communications
- How long do we keep your information?
- Change in Terms of Privacy
- Site Content
- Your rights
- Complaints
- How do you contact us?
This Policy applies to all of the personal data we collect about you, including information collected by Go Thrive Coaching Ltd. (“GTC”) at events and any other websites (including mobile access) where this policy is linked to; all of which are referred to as the “Site” in this Policy.
GTC recognises the importance of protecting our users’ privacy. To that end we have created this privacy statement (Policy) in order to demonstrate our commitment to privacy. Information on how Site content can and cannot be used is also listed below.
We may occasionally amend this Policy. Any new policy will automatically be effective when it is published on the Site. You should therefore return here regularly to view our most up to date Policy. You should also print a copy for your records.
Who we are
Go Thrive Coaching Ltd. is a private limited company incorporated in England (Company Registration Number: 12385168) and its registered office is 71-75 Shelton Street, London, England, WC2H 9JQ.
We refer to Go Thrive Coaching (GTC) as “we”, “us” or “our” in this Policy.
For the purposes of data protection law, the data controller is Go Thrive Coaching Ltd.
We are registered with the Information Commissioner’s Office (ICO) under registration number ZB038296.
The person responsible for data protection is Ms. Grace Ong. For any queries relating to the management of your personal data please do not hesitate to reach out to us at grace@gothrivecoaching.com
What Information do we collect?
Most of the information we collect is information provided directly by you. This may include:
- Contact information – information such as name, job title, company name, department, email address, physical mailing address and telephone number
- Professional information – such as your employment background, job description and related information
- Transaction information – your contact information, the services you are interested in, your purchasing requirements, your financial information including credit card or other payment information
- Responses to surveys – information you provide in responding to a survey on the Site, via an app or email, on the telephone or otherwise
- Any other information that you submit when you contact us via our booking form, including via the online platform or for the purposes of purchasing our services
We may also collect, and process information obtained through the Site or the device you are using, including:
- Member information (including username and password)
- Location information (including GPS signals sent by a mobile device, location information gathered from social media networks or sensor or IP address data from your device
- information from cookies, web beacons or from the internet, including your IP address, browser type, operating system, domain name, access times, which pages you visit within our Site and referring website addresses – for more on this please see the next section below on how we use your information
- If you ask us to connect via other sites and social media (for example if you ask us to connect with your Facebook/Instagram/LinkedIn account) we may get information that way too
- We may record any telephone calls for quality assurance and training purposes and
- We may also make audio and video recordings of your coaching sessions with us for governance, quality control and monitoring purposes. These recordings will be shared only with you, as we believe, having access to your sessions could be beneficial for your progress. We assure you that all such personal data will be treated as confidential and will be held strictly in accordance with data protection legislation.
- We may use publicly accessible information to verify information we are provided with.
Throughout the website there may be forms to request information and purchase or obtain products and/or services. These forms typically ask for contact information, financial information, and demographic information. Information from these forms is used to deliver the information, products and/or services that you request. It may also be used to notify you of future GTC products, services and/or opportunities that may be of interest to you. When completing these forms, please do not supply another person’s personal data to us unless we prompt you to do so and you have received that individual’s consent to do so.
How do we use your information?
We use information collected about you as outlined in this Policy.
General
Our primary purpose in collecting your personal data is to provide you with the services you requested and those which we believe will optimise your use of the Site. We may use your personal data for the following purposes:
- To provide the information, services or support you request and related after -sales services
- To identify you, and to contact you from time to time with service updates
- To send other messages that are useful to the service we provide
- To manage our relationship with you and to carry out any related administration
- To send you our newsletters, including by email and via social media platforms, if you have opted in to receive our newsletters
- To promote services, or the services of our suppliers, including by email and via social media platforms (subject to the relevant marketing permissions)
- To compare information for accuracy, and verify it with third parties*
- To detect, investigate and prevent activity we think may be potentially illegal, unlawful or harmful and to enforce our Policy or any other purpose referenced herein or therein*
- To carry out research, including market research, statistical research on site traffic, sales and other commercial information to assist us in improving the services we provide to you and tailor the Site*
- To keep track of the areas of our Site you visit, the amount of time you spend and the date and time you access our Site to enable us to tailor it to better match your interests and/or preferences.
Lawful basis for collecting and processing your personal data
In more legal terms, we process your personal data where we have your consent to do so, which you may withdraw at any time, or otherwise where this is necessary for:
- The performance of our contract with you for the provision of our services or to take preliminary steps at your request
- Us to fulfil our legal obligations or,
- The purposes of the legitimate interests pursued by us or by a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are those indicated with a “*” above, and we consider that we have implemented sufficient checks and protections to ensure that your rights and interests are not unreasonably intruded on.
*However, you can object to processing on any of these bases at any time and, if you do so, we will stop processing the personal data unless we can show compelling legitimate grounds which override your rights and interests, or we need the data to establish, exercise or defend legal claims – see “Your rights” below.
Who may use your information?
We are committed to keeping your e-mail address confidential. We do not sell, rent or lease our subscription lists to third parties. We may disclose your personal data to enforce our policies, to comply with our legal obligations or in the interests of security, public interest or law enforcement in any country where we have entities or from where our clients may be accessing our services. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority. We may also disclose data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests.
We share your information with third parties who help deliver our services to you. Examples include hosting our web servers, analysing data, providing marketing assistance, and providing customer service. These companies will have access to your personal information on a need to know basis, i.e., as necessary to perform their functions, but they may not use that data for any other purpose.
Whilst we encourage you to inform your therapist and/or any other qualified healthcare professional you are consulting, that you are being coached by us, we will not share your information with your therapist/ NHS care provider/ GP/ any other qualified physician/medical expert unless we have your express written permission to do so or where there is an overriding public interest in disclosing the information without your consent or where your interests in terms of your health and safety over-ride our obligation of confidentiality. This is in accordance with the General Medical Council's guidance which may from time-to-time change.
We will generally share your information/personal data with persons nominated as your “Emergency Contact” or where an “Emergency Contact” has not been nominated, with the next of kin, only in cases of emergencies where it is in the legitimate interest of the public or in the legitimate interest of our organisation or in your own legitimate interests for us to disclose the personal data or where your interests (health) over-ride our obligation of confidentiality. For such circumstances it shall be deemed that you have consented to your information being shared with the Emergency Contact or next of kin.
We may report to the ICF (International Coaching Federation), your participation in our coaching sessions, in order to maintain our credentials, as per the requirements of the ICF. For the purposes of submitting records to the ICF, only your name, email address, contact number, dates and duration of the coaching sessions, and no further details or notes relating to your coaching session will be shared. The only purposes for such personal data being shared will be for the ICF to verify that GTC is in compliance with its credentials requirements prescribed by the ICF.
We may share aggregated anonymised data with third parties in order to monitor our services and to ensure consistent quality and safety relating to the Services provided to clients.
Marketing communications
If you have given permission, we may contact you by about any of the following:
- Our newsletters
- Updates about services and packages
- Promotions
- Invitations to webinars and teleconferences conducted by us
- Events
In compliance with the relevant data protection law, all email sent from us will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further email communication from us.
We are committed to keeping your information confidential. We do not sell, rent or lease our subscription lists to third parties, and we will not provide your personal information to any third - party individual, government agency or company at any time unless compelled to do so by law. We will use your email address solely to provide timely information about GTC and its programs and services. GTC will maintain the information you send via email in accordance with applicable data protection law.
If you prefer not to receive any direct marketing communications from us you can opt out at any time by emailing grace@gothrivecoaching.com. See further ‘Your rights’, below.
How long do we keep your information?
We will retain your personal data only as long as is necessary for the purposes set out in this Policy, or as is required by applicable law, and then we will delete it.
Change in Terms of Privacy
We reserve the right to alter this Privacy Policy. Any changes to the Policy will be posted on this page.
Your rights
As explained above, you have the right to opt-out of receiving marketing communications from us. In addition, to the extent permitted by the laws of your country, you may have the right to object to the processing of your personal data for direct marketing purposes. If your objection is not in relation to direct marketing in general, but to direct marketing by a particular channel, for example email or telephone, please specify the channel you are objecting to.
Under the UK Data Protection Act, you have the following rights in relation to your own personal data:
- to request copies of your personal information
- to request us to rectify incorrect information. You can also request us to complete information that you think is incomplete
- to request us to erase your personal information in certain circumstances
- to ask us to restrict the processing of your information in certain circumstances
- applying only to information you have given us; you may ask that we transfer the information you gave us from one organisation to another, or that we give it to you.
- to object to automated decisions. We do not, however, use automated decision making
- the right to withdraw consent from us continuing to process your personal data and
- a right to object to processing that is likely to cause or is causing damage or distress
If you want to (1) tell us to stop using your data for direct marketing or withdraw consent from us processing your personal data for any of the purposes mentioned in this Policy; (2) exercise your subject access rights; (3) tell us about inaccurate personal data you think we hold on you; or (4) object to a use you believe we’re making of your data which is causing, or is likely to cause, damage or distress, please contact our Data Protection Manager at grace@gothrivecoaching.com or write to us at this address:
Go Thrive Coaching Ltd.
71-75 Shelton Street, London, England, WC2H 9JQ
Unless the law permits us to do so, we will not charge you to exercise your subject access rights but may charge a reasonable fee reflecting our administrative costs should you request further copies of the personal data. When you contact us to exercise any of the above rights, we will first ensure that the person requesting the data is the person whose data is being sought (or that it is being requested on that person’s behalf). This may involve providing us with proof of your identity or your authority to act for the data subject. We may also ask you for any information we need to help us find the personal data you’re enquiring about.
We will also provide you with the following information relating to your personal data:
- the purpose for which we’re processing it
- what categories of data about you we process
- the recipients of your data, if any, including specifically international or foreign organisations
- our expected retention period or how we’ll calculate this, if we don’t know yet
- your rights in relation to the data and
- the source of the data, if we didn’t get it from you
- Should you contact us in relation to us holding incorrect, incomplete or inaccurate data about you, we will make the required corrections promptly.
Complaints
If you have any concerns about the way we are processing your personal data or our use of your personal information, you can make a complaint to us by emailing us at grace@gothrivecoaching.com or by sending your complaint to:
The Data Controller
Grace Ong
Go Thrive Coaching Ltd. 71-75 Shelton Street, London, England, WC2H 9JQ
You can also complain to the Information Commissioner’s Office (ICO) The ICO’s address is:
Information Commissioner’s Office
Wycliffe House Water Lane Wilmslow Cheshire, SK9 5AF
Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk
How do you contact us?
If you have any questions about this Policy, we encourage you to contact us using the following details:
Grace Ong
Go Thrive Coaching Ltd. 71-75 Shelton Street, London, England, WC2H 9JQ
grace@gothrivecoachingcom
