Privacy Policy

Privacy Policy for The Wings Coaching & Consulting Ltd

This privacy notice provides you with details of how we collect and process your personal data.

If you need to email us about anything related to this privacy notice, you can email us at hello@thewingscoaching.com.

WHAT PERSONAL DATA WE COLLECT ABOUT YOU

We may collect the following data about you:

· Your name

· Your email address

· Your address

· Your phone number

· Your date of birth

· Your business name

· Any personal data you post on our website

· Data about how you use our website

· Technical data such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website

· Your marketing and communication preferences

· Any other information that you directly provide to us whether through our contact form, over the phone, by email or otherwise, such as when entering a competition or completing a survey

· Credit information from third parties

HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by registering for our events). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. 

We may receive data from third parties such as analytics providers such as Google based outside the UK, advertising networks such as Facebook based outside the UK, such as search information providers such as Google based outside the UK, providers of technical, payment and delivery services, fraud detection agencies and data brokers or aggregators.

HOW WE MAY USE YOUR DATA

We will use your data in order to:

· Process financial transactions to enable you to purchase our goods our products or services

· Send you customer communications about enhancements to products or services you have bought

· Enable us to perform a contract with you and process orders, respond to enquiries related to the order and deal with complaints

· Reply to any enquiries you make about our products or services

· Send you marketing communications where we are allowed by law to do so

· Personalize your experience on our websites

· Monitor the use of our website and online services

· Ask you to complete surveys or invite you to enter into competitions or prize draws

· Keep records of orders placed and communications in relation to such orders

· Keep records of communications

· Analyse your use of our website and other online services

· Administer and protect our business and website

· Deliver relevant website content and advertisements to you

· Understand the effectiveness of our advertising

· Carry out credit checks

· Bring legal claims against you if you breach a contract or fail to make payment (we know you won’t….)

· Comply with any legal obligations we are subject to or as required by a government authority

· Obtain or maintain insurance policies

· Manage our business

· Obtain professional advice

OUR LAWFUL GROUND OF PROCESSING

Under the UK GDPR, we are only legally able to process your personal data if we have a lawful ground for doing so.

Our lawful grounds of processing are:

· In relation to Customer Data that we have obtained in relation to you placing an order with us that we hold for the purpose of fulfilling that contract, informing you about updates to the product or service and keeping records of the contract, the processing is necessary for the performance of a contract to which you are subject and for our legitimate interests in informing you about updates to the product or service, record keeping and to establish, pursue or defend legal claim as responsible business operations

· In relation to Prospect Data that we have obtained when you enquired about our products or services (whether that be through our website or otherwise) and that we process in order to reply to your enquiry and keep records of this, the processing is necessary in order to take steps at your request prior to entering into a contract and for our legitimate interests in record keeping and to establish, pursue or defend legal claim

· In relation to Prospect Data that we have obtained when you signed up for any of our free resources and that we process in order to send you those free resources, reply to your communications about the resources and to keep relevant records, you have given consent to the processing for the purposes of us sending you the free resource and it is in our legitimate interests to reply to your communications and to keep records for our business.

· In relation to Marketing Data that we have obtained when you told us your marketing preferences, when you consented to us sending you details of our products and services, for the purposes of us sending you marketing communications, enabling you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising, the processing is necessary for our legitimate interests which in this case are to study how customers and users use our products/services, to develop them, to grow our business and to decide our marketing strategy.

· In relation to User Data that we have obtained through cookies on our website or other online services for the purposes of operating our website, ensuring relevant content is provided to you, ensuring the security of our website, maintaining back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business, the processing is necessary for the purposes of our legitimate interests which in this case are to enable us to properly administer our website and our business.

· In relation to Technical Data (that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website), we process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

· In relation to your data that we process in order to comply with legal requirements or as required by a government authority, the processing is necessary for compliance with a legal obligation to which we are subject.

· In relation to keeping records, this processing is either necessary for compliance with a legal obligation that we are subject to or for our legitimate interests in responsible business operations or defending, pursuing or establishing a legal claim.

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We do not collect any information about criminal convictions and offences.

We do not carry out automated decision making or any type of automated profiling.

MARKETING COMMUNICATIONS  

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may only send you email or text marketing communications if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

We will never share your personal data with any third party for their own marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at hello@thewingscoaching.com. We also have unsubscribe buttons on the bottom of all of our emails.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc. 

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

· Service providers who provide IT and system administration services.

· Professional advisers including lawyers, bankers, accountants, auditors and insurers.

· Government bodies that require us to report processing activities or otherwise disclose your personal data.

· Market researchers and fraud prevention agencies.

· Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

DATA RETENTION

We will only retain your personal data 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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

//ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at hello@thewingscoaching.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Cookie Policy

We use cookies to help improve your experience of https://thewingscoaching.com. This cookie policy is part of Your Ascent's privacy policy, and covers the use of cookies between your device and our site. We also provide basic information on third-party services we may use, who may also use cookies as part of their service, though they are not covered by our policy.

If you don’t wish to accept cookies from us, you should instruct your browser to refuse cookies from https://thewingscoaching.com, with the understanding that we may be unable to provide you with some of your desired content and services.

What is a cookie?

A cookie is a small piece of data that a website stores on your device when you visit, typically containing information about the website itself, a unique identifier that allows the site to recognise your web browser when you return, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.

Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. timezone, notification preferences), and to personalise your content (eg. advertising, language).

Cookies set by the website you are visiting are normally referred to as “first-party cookies”, and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called “third-party cookies”, and can be used to track you on other websites that use the same third-party service.

Types of cookies and how we use them

Essential cookies

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts and payment processing. We use essential cookies to enable certain functions on our website.

Performance cookies

Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you’re visiting (first-party) or by third-party services. We use performance cookies on our site.

Functionality cookies

Functionality cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and time zone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you’re visiting (first-party) or by third-party service. We use functionality cookies for selected features on our site.

Targeting/advertising cookies

Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you’re visiting (first-party) or by third-party services. Targeting/advertising cookies set by third-parties may be used to track you on other websites that use the same third-party service. We do not use this type of cookie on our site.

Third-party cookies on our site

We may employ third-party companies and individuals on our websites—for example, analytics providers and content partners. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by The Wings's cookie policy.

Our third-party privacy promise

We review the privacy policies of all our third-party providers before enlisting their services to ensure their practices align with ours. We will never knowingly include third-party services that compromise or violate the privacy of our users.

How you can control or opt out of cookies

If you do not wish to accept cookies from us, you can instruct your browser to refuse cookies from our website. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie.

If you browse websites from multiple devices, you may need to update your settings on each individual device.

Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content across the sites you visit.