Privacy Policy

Privacy Statement

Our coaching relationship will always be built on transparency, trust and confidence in each other. Here below you will find the details of our privacy policy which describes how data is collected and used in accordance with the General Data Protection Regulation (GDPR).

This Privacy Statement applies to:

All Clients
All Third Parties and Suppliers with whom we have dealings in the ordinary course of our business including those individuals with whom we send marketing information.

Any reference to ‘we’, ‘us’, ‘our’, ‘the company’ shall mean Leadership75 and its Coaches.

Any reference to ‘you’ or ‘Data Subject’ shall mean any individual receiving this notice for whom we hold personal data.

In most circumstances, your data will be held by us as a “Data Controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you about the holding of information in this privacy notice.

We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection laws including GDPR. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only if necessary for the purposes we have told you about.
Kept securely.

The kind of information we hold about clients

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about clients.

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

In case of business coaching we will collect the following information:

Location of employment or workplace.
Company name
Name of person to whom the invoice is addressed, for invoicing purposes only.

We may also collect, store and use the following “special categories” of more sensitive personal information in respect of client information arising from some coaching interventions.

Business address and company registration number(s).
A management contact for the business we are engaged with.

Why we hold information on clients

It is necessary for us to retain data on clients in order for us to fulfil contractual obligations and hold data for legitimate business needs.

We will only retain data which we reasonably require and for a period which is reasonably necessary.

We will not disclose your data to third parties unless you have consented for us to do so or we are otherwise required to do either contractually or under another law or enactment.

How we collect data

We collect personal information about clients directly from themselves when they contact us through our website contact form or via telephone, email or social media.

Leadership75 securely stores your data at our Cloud Hosting provider. The data will be kept in our database for seven years and then destroyed. Once this time period has expired, we will delete your data by requesting our Cloud Hosting provider to delete your data.

How will we use your information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest (or for official purposes).

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

Administering the contract we have entered into with you.
Dealing with legal disputes involving you.
To prevent fraud.
To market other products or services which we offer which may be of interest to you.
To inform you about updates about our services.
To administer our business which may include disclosure of client data to our accountants.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

In certain circumstances listed above, we hold your data to market other services to you, send you inspirational blogs, or send you information that we think may interest you. We have a legitimate business interest in retaining your data for this purpose, but you may ‘opt out’ of receiving these types of communication from us. More on this in the Marketing section of this Privacy Policy.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered with you or we may be prevented from complying with our legal obligations.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

The kind of information we hold about individuals other than clients and how this data is used

During our day to day business we acquire information regarding individuals other than our clients and we will retain this data where we have a legitimate business reason to do so.

Typically, we acquire personal data on individuals, third parties and suppliers other than our clients in the following circumstances:

Where we have met individuals, third parties and suppliers at networking or other marketing events.
Where individuals, third parties or suppliers have made enquiries with us regarding possible services but have not subsequently become clients of Leadership75.
Where we have dealt with individuals, third parties or suppliers in the capacity as suppliers of goods or services to us.
Where we have regular business-related dealings with you.

We have a legitimate business interest in retaining this data to send informative blogs, event details or other updates relating to our services or something that we believe relates to your interests. You have the right to ask us to erase or rectify your data and you have the right to opt out of receiving marketing, networking information or information we think might be of interest to you. More on this in the Marketing section of this Privacy Policy.

Why we might share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Data retention

How long will we use your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

In respect of client data, you can expect us to hold data relating to your instructions for a period of seven years after completion of the last coaching interaction. The reason for this is that the Limitation Act 1980 typically provides that legal proceedings for breach of contract or negligence can be brought up to six years after the events. We, therefore, have a legitimate business interest in retaining the data should any subsequent legal proceedings ensue.

Given the nature of our services clients often return to us with repeat instructions within weeks, months or years of contacting us in the first instance. The seven-year period referred to above will start from the last contact we had with the client, third party or supplier, to ensure we are able to assist as and when we need to. Should you not contact us for seven years, we will confidentially destroy all data held for you.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

Leadership75 would like to make sure you are fully aware of all of your data protection rights.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with Leadership75.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. We might charge a small fee for this service.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Federica Esposito at [email protected].

Please note that where you ask us to erase, correct, object to process or seek to restrict our processing of data we may refuse your request where we have a legal obligation, contractual or other legitimate business interest to refuse your request. If we refuse your request then we will notify you of this refusal and you will have the right to appeal.

What we may need from you

We may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Timeframes and practical information

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please email us at [email protected] or write to us at Leadership75 c/o Bitboxx Ltd. Wellesley House Duke Of Wellington Avenue, Royal Arsenal, London, England, SE18 6SS.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Federica Esposito at [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data Privacy Manager

Federica Esposito is the Data Privacy Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact her at [email protected] or by post at Leadership75 c/o Bitboxx Ltd. Wellesley House Duke Of Wellington Avenue, Royal Arsenal, London, England, SE18 6SS.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues: https://ico.org.uk/make-a-complaint/

Marketing

Leadership75 would like to send you information about products and services of ours that we think you might like.

If you have agreed to receive marketing, you may always opt-out at a later date. You have the right anytime to stop Leadership75 from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please send an email to [email protected] or write to us at Leadership75 c/o Bitboxx Ltd. Wellesley House Duke Of Wellington Avenue, Royal Arsenal, London, England, SE18 6SS.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. For further information, visit allaboutcookies.org.

How do we use cookies

We don’t use any tracking cookies.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Changes to this privacy policy

Leadership75 keeps its privacy policy under regular review and places any updates on this web page. We reserve the right to update this privacy policy at any time. When substantial updates are made we will notify you directly.

This privacy policy was last updated on 12 November 2020.

Contact and further information

If you have any questions about this privacy policy or wish to submit a complaint, please send an email to [email protected] or write to Leadership75 c/o Bitboxx Ltd. Wellesley House Duke Of Wellington Avenue, Royal Arsenal, London, England, SE18 6SS.

If you make a complaint, we will respond to let you know how your complaint will be handled.