OUR PRIVACY PROCEDURES IN PLAIN ENGLISH!

If you are a subscriber to our newsletter we currently hold your:

• Name.
• e-mail address.

If you are a client or someone who has enquired about our services, we currently hold your:

• Name.
• Contact details (that you used to make contact with us directly or that you gave to someone else to pass on to us so we could contact you).
• Workplace (where it’s necessary for us to know this).
• Social Media links (where you have used these to contact us).

We use these details to:

• Keep an accurate record of your personal details as a subscriber, client or potential client.
• Send resources to current clients.
• Send information regarding services, offers and important updates on our coaching and training activities.

*Notes that help us to provide personalised services such as one-to-one coaching are anonymised, and held extremely securely offline, with no information that could possibly make a connection to any person either living or dead.

What we do NOT do is:

• Sell or share client lists with any third parties.

INTRODUCTION

This document has been produced in line with our obligations under the General Data Protection Regulation (GDPR) effective from 25^th May 2018 and to demonstrate our continuing commitment to safeguarding your privacy.  Since that date, the GDPR  introduced changes which will give you greater control over your personal information, including a right to object to processing of your personal information where that processing is carried out for our business purposes.

Please take time to read this notice carefully.  If you are under 18 years of age, please read this summary with a parent or guardian and ensure you understand it.  If you have any questions about how we use your information please contact us at the details below.

SUMMARY

This summary explains the most important aspects of how we use your information and what rights you have in relation to your personal information.

1. Who we are

Throughout this document, “we”, “us”, “our” and “ours” refer to Aslan VA and Coaching Ltd.

2. The information we collect about you

We will hold:

• Data to identify you, including your contact information.
• Information provided by you in the course of enquiring about or accessing our services.
• Information which you have consented to us storing.

3. When we collect your information

We collect information:

• that you give us in the course of enquiring or accessing our services via any of our contact touchpoints.
• that has been given to us by way of referral by a third party, with your consent.

4. How we use your information and the legal basis.

We use your data where:

• you have agreed or specifically consented to the using of your data in a specific way (you may withdraw your consent any time)
• the information is necessary in relation to the services we provide to you.
• the information is necessary for us to comply with a legal obligation (e.g. regulatory authorities or law enforcement).
• the information is necessary for our legitimate interests (which you may object to) such as managing our business, providing service or service information, conducting marketing activities, coaching and training.

 5. How we use automated processing or ‘analytics’.

We may analyse your information using automated means to:

• help us understand your needs and develop our relationship with you.
• help us offer you products and service information we believe may be of interest to you.

 6. Who we share your information with on a need to know basis:

• Employees of Aslan VA and Coaching Ltd.
• Service providers retained by Aslan VA and Coaching Ltd.
• Another professional should this be required (e.g. if it becomes apparent during coaching or training that you require counselling) on the strict basis that this is with your knowledge and full consent.

7. How long we hold your data

Financial: The length of time we hold data about your financial transactions with us is subject to legislation and regulatory rules we must follow, set by authorities such as Revenue Commissioners.

Other information: Your personal data in relation to our coaching and training services is reviewed annually and if it has not been used for a period of 2 years and/or it is not expected to be needed for repeat business it will then be deleted.

8. Implications of not providing your data

If you do not provide information we may not be able to:

• Provide requested services to you.
• Continue to provide requested services to you.
• Inform you of upcoming products or services when you have opted in for such information or specifically requested it.

9. Using companies to process your information.

In the course of conducting our business we use companies, agents and service providers that may be inside or outside the EEA (European Economic Area).  In either case, we will always check that such providers are GDPR compliant and have systems in place to protect your information from unauthorised use.

10. How to exercise your information rights including the right to object

Since 25^th May 2018, you have several enhanced rights in relation to how we use your information including the right, without undue delay, to:

• find out if we use your information, access your information and receive copies of your information.
• have inaccurate/incomplete information corrected and updated.
• object to particular use of your personal data for our legitimate business interests or direct marketing purposes.
• have your information deleted or restricted (a need for compliance with law would override this).
• withdraw consent at any time where processing is based on consent.

 11. How to contact us

Aslan VA and Coaching Ltd. Data Protection Controller:
Lisa Nolan
e-mail: lisa [at] aslancoaching [dot] ie
Contact Lisa

MORE DETAILS

Security

The security of our systems, websites and your information is of great importance to us. Our websites have reasonable security measures in place to protect the loss, misuse and alteration of your information under our control, but we make no assurances about our ability to prevent any such loss, misuse or alteration, and we shall have no liability to you or any third party from any loss, misuse or alteration. We do not warrant that your access to our websites is completely secure.

IP Address and Cookies

You may use or browse this website without entering personal information. However, your internet protocol (IP) address may be used to help diagnose problems with the server and to administer the website.

What are Cookies?

Cookies are small text files that your browser downloads and stores on your device. This data is anonymous and is stored separately from any personal information you may provide during the course of your visit to our website, thereby making it impossible to connect it to any particular person. This data is only used for the purposes of improving our website and services.

In most cases, these are simply session cookies that are deleted once you leave the website. They also allow the website to recognise your computer when you access the website by way of recognising your IP address. Cookies are also used to assist with tools like website analytics.

If you would like to prevent the placement of cookies on or remove cookies from your device, please do so via the settings or preferences options in your browser or contact your browser provider. You can also choose to browse the website Incognito – you can do this via your browser settings.  Please be aware that if you block or remove cookies from your computer, this website may not recognise your computer and you may not have access to all parts of the website and therefore your experience of the website may be limited.

Facebook Pixels

Facebook pixels are used to assess what type of visitor comes to the website and who likes our Facebook page.  This is so that we can create advertising that appeals to our customers and potential customers. We do not collect any specific personal information about you via these Pixels.

Website Contact Page and Sign Up Options

Using the Contact page or Sign Up options on our websites and Social Media

The contact form on this website requires users to provide certain personal information, i.e. name, e-mail address and short message explaining the nature of their enquiry.  I use this information to facilitate communication with the user.  None of this information is linked to information that may be collected by other components of the website (e.g. Cookies).

We do not rent, sell or exchange user information, and we restrict access to user information to our own qualified employees and agents.

The only time we may disclose a user’s contact information is if required to do so by law or in the good-faith belief that such disclosure is necessary to comply with an order of a court or government authority or a subpoena. We may also disclose a user’s contact information in the good-faith belief that such disclosure is necessary to protect us, our company or our websites, or enforce the applicable Terms and Conditions, in conjunction with an investigation or legal, equitable or administrative action or proceeding.

Signing up

When you sign up for our newsletter or any of the guides or courses on offer, your email and name are added to our mailing list database, which is hosted by MailChimp. Please review MailChimp’s information on how they are modifying their systems and processes in order to comply with GDPR.

https://kb.mailchimp.com/accounts/management/about-the-general-data-protection-regulation

The purpose of collecting this information is solely to provide the subscriber with quality content, access to downloads and marketing communications.

If you subscribe or asked to be subscribed to a particular newsletter or automated sequence of emails, you will be added only to the appropriate list.  We operate ‘double opt-in’ lists so you will need to reconfirm your subscription regarding each opt-in.

You may cancel your subscription and revoke your consent to the storage or processing of this data at any time. The unsubscribe option is available in every automated communication sent by us.  Alternatively you can contact us at Lisa [at ]  aslancoaching [dot] ie and put ‘Unsubscribe’ in the subject line and we will manually unsubscribe you.

We do not rent, sell or exchange user information, and we restrict access to user information to our own qualified employees and agents.

The only time we may disclose a user’s contact information is if required to do so by law or in the good-faith belief that such disclosure is necessary to comply with an order of a court or government authority or a subpoena. We may also disclose a user’s contact information in the good-faith belief that such disclosure is necessary to protect us, our company or our websites, or enforce the applicable Terms and Conditions, in conjunction with an investigation or legal, equitable or administrative action or proceeding.

Third party content and hyperlinks

Our websites and social media may contain visible and clickable links to external websites that we believe may be of interest to you.  We place them in good faith that they are of interest to you and that the links are working correctly.  It is your choice whether or not to click on any such links.  We do not accept any responsibility or liability in relation to using these links.

Unless specifically stated we do not endorse or recommend third party websites, references, or the products, services, or information they may provide or offer. We may delete or disable any hyperlink to external sites at any time.  We have the right but not an obligation to monitor third party websites and hyperlinks to other sites.

Our Contact Touchpoints

These include, but are not limited to the following:

• Our websites.
• Our verified and legitimate social media accounts.
• Our verified and legitimate e-mail addresses.
• Our verified and legitimate telephone numbers.
• Face to Face interactions.
• Networking meetings.

User’s Age:

While those under 18 are welcome to use our websites and to access our services, consent of a parent or guardian is strongly advised.

Reviewing our records and procedures

All our personal data records and procedures are reviewed annually to ensure full and continuing compliance with GDPR.  Records may be reviewed more frequently if necessary.

Sale of Business

In the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our business you will be notified by us at which stage you will be afforded an opportunity to re-submit your consent to storage and use of your personal data by the future owners of the business.  Information for anyone who does not re-submit consent in this case will be deleted permanently before transfer of the business.

Revisions of this Policy

This Policy may be updated if required to ensure full and continuing compliance with GDPR.  Amended policies will be published online immediately.  This does not affect your rights as an individual and any amendments we make to our policies in relation to your personal information will be notified to you immediately and you will be required to submit consent to any proposed changes.