Privacy Policy

BACKGROUND:

Connect203 understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website www.connect203.co.uk. Our Site will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested upon submitting enquiries, subscribing to newsletters or emails, text messaging, registering for a mastermind group or 1:1 coaching session, enrolling on a course or visiting this website.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of our Site;
“Cookie”	means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Information About Us

Our Site is owned and operated by Connect203.

Main trading address: Tarporley, CW6 9YH.

Data Protection Officer: Dr Colleen Bass.

Email address: ColleenBass@Connect203.co.uk.

Telephone number: 07412 547819.

What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

What Data Do You Collect and How?

Depending upon your use of our Site, we may collect and hold some or all of the personal [and non-personal] data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and our Cookie Policy. We do not collect any ‘special category’ or ‘sensitive’ personal data AND/OR personal data relating to children AND/OR data relating to criminal convictions and/or offences.

Data Collected	How We Collect the Data
Identity Information including name and title.	The method of collection source is via any enquiry, subscription, registration and enrolment forms based on our website.
Contact information including address, email, telephone number.	The method of collection is via enquiry, subscription, registration and enrolment forms based on our website.
Business information including business name and job title, company address.	The method of collection is via enquiry, subscription, registration and enrolment forms based on our website
Payment information including card details, bank account numbers.	The method of collection is via an online third-party payment system based on our website.
Profile information including login details and purchase history.	The method of collection is via enrolment on to our courses and registration on mastermind groups, 1:1 coaching session based on our website.
Technical information including IP address, browser type and version and operating system.	The method of collection is Google Analytics.

How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data and our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Registering you on our courses, mastermind group, 1:1 coaching or membership site.	Name, address, telephone number	Where you have provided clear consent, processing necessary for entering into a contract for services with us and legitimate interest in delivering the course, mastermind group, 1:1 coaching and membership site.
Providing and managing your course, mastermind group, 1:1 coaching or membership site account.	Name, address, telephone number, account number, passwords.	Where you have provided clear consent, processing necessary for entering into a contract for services with us and legitimate interest in managing your course, mastermind group, 1:1 coaching and membership site account.
Providing and managing your access to our courses, mastermind group, 1:1 coaching and membership site.	Name, address, telephone number, account number, passwords	Where you have provided clear consent and legitimate interest in providing and managing your access to your account.
Administering our courses and membership sites.	Name, address, telephone number, account number, passwords	Where you have provided clear consent, processing necessary for the contract for services you have entered in to with us and legitimate interest in managing your course, mastermind group, 1:1 coaching and membership site account.
Administering our business in line with HMRC requirements.	Name, address, payments made.	Processing is necessary for us to comply with the law in relation to managing your account, payments and invoicing.
Supplying our consultancy, courses, membership site, mastermind groups and 1:1 coaching.	Name, address, telephone number	Where you have provided clear consent, processing necessary for the contract for services you have entered in to with us and legitimate interest in supplying your course, mastermind group, 1:1 coaching and membership site.
Managing payments for our outsourcing services, courses, membership site, mastermind group and 1:1 coaching sessions.	Name, address, telephone number, email address, bank account details, bank card details	Where you have provided clear consent, processing necessary for the contract for services you have entered in to with us and legitimate interest in managing payment for your course, mastermind group, 1:1 coaching and membership site.
Personalising and tailoring our outsourced marketing, consultancy, courses, membership site, mastermind groups and 1:1 coaching sessions.	Name, address, email address, telephone number, IP address, browser type and version.	Where you have provided clear consent and legitimate interest in personalising and tailoring your course, mastermind group, 1:1 coaching and membership site account.
Communicating with you via email, text and messaging services.	Name, address, telephone number, email address.	Where you have provided clear consent to communicating via email, text and messaging service.
Supplying you with information by email or post that you opted-in-to (you may opt-out at any time electronically.	Name, address, email address.	Where you have provided clear consent to receiving information by telephone, email or post.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, messenger, telephone or text message with information, news and offers related to our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary for the reason(s) for which it was first collected. Your personal data will, therefore, be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long [We] OR [I] Keep It
Identity Information including name and title.	Retention will remain valid for 24 months after initial collection or any other positive contact or in line with dates set under legal obligations.
Contact information including address, email, telephone number.	Retention will remain valid for 24 months after initial collection or any other positive contact or in line with dates set under legal obligations.
Business information including business name, job title.	Retention will remain valid for 24 months after initial collection or any other positive contact or in line with dates set under legal obligations.
Payment information including card details, bank account numbers.	Retention will remain valid for 24 months after initial collection or any other positive contact or in line with dates set under legal obligations.
Profile information including username, password, purchase history.	Retention will remain valid for life after initial collection or any other positive contact or in line with dates set under legal obligations.

How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
We have in place a separate Data Breach Policy.

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exception(s).

Recipient	Activity Carried Out	Sector	Location
HMRC	Tax, Customs and Excise Requirements	HMRC	UK

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Control My Personal Data?
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details and by managing your Account.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.

Can I Withhold Information?

You may access our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on our Site are used in accordance with current Cookie Law.

See our Cookie Policy for further information.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Dr Colleen Bass

Email address: ColleenBass@Connect203.co.uk.

Telephone Number: 07412 547819.

Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 24^th July 2020.