We are committed to safeguarding the privacy of our website visitors and all data collected as clients of Step by Step Listening; this policy sets out how we collect and process your personal data using our website Manage Your Critic. This includes any information you may provide through our website when you sign up for newsletters, take part in prize draws or competitions, booking complimentary sessions and purchasing a product or service. By providing us with your data you confirm that you are over 13 years of age.
2. Contact Details
Our full contact details are:
Full name of legal entity: Step by Step Listening
Email address: Enquiries@stepbysteplistening.com
Postal Address: 58 Keyes Road, Gosport Hants PO13 0JA
Telephone Number: 01329 286648
The Information Commissioner’s Office (ICO) (www.ico.org.uk) are the UK’s independent body set up to uphold information rights. Should you have any concerns about how we collect and use your data, you have the right to complain to the ICO. We would be grateful if you would contact us in the first instance though, so that we can work with you to resolve your concern.
It is very important that all information we hold is up to date and accurate so please let us know if any of your personal information changes at any time. Please email Enquiries@stepbysteplistening.com
3. What data do we collect about you?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Personal Data may include details from notes made during our sessions together.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
4. Sensitive Data
Sensitive data refers to any data that includes information about your:
- race or ethnicity,
- religious beliefs,
- political opinions,
- whether you are a member of a trade union,
- your physical, mental health or condition
- your sex life or sexual orientation
We do not proactively collect sensitive data about you although these may be discussed during a session that are recorded for your purpose only.
5. How we collect your personal data
We may collect data about you through a variety of different methods, including:
- Website – We collect data such as your IP address, geographical location, browser type, referral source, length of visit and number of page views. We collect this data by using Cookies (please see below)
- Direct contact or interactions – You may provide information by filling out forms on our website or communicating with us through post, phone, email or another form. This will include when you:
- Order our products or services
- Subscribe to our newsletters, publications or updates
- Request information to be sent to you
- Give us feedback
- Enter draws, promotions, surveys, or competitions.
- Third parties or publicly available sources - We may receive personal data about you from various third parties and public sources as set out below:
- analytics providers such as Google based outside the EU;
- advertising networks such as Facebook based outside the EU;
A cookie is a text file sent by a web server to a web browser and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We may send a cookie which may be stored on your browser on your computer's hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website's usability and for marketing purposes.
We may also use that information to recognise your computer when you visit our website, and to personalise our website for you.
Most browsers allow you to refuse to accept cookies, however please note that this may affect the function and accessibility of our website.
7. Using your personal data
Personal data will only be used when legally permitted. Data submitted via our website or other means will be used for:
- Performing the contract between us,
- To comply with a legal or regulatory requirement, and
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
In addition, we may use your data to:
(a) improve your browsing experience by personalising the website;
(b) send information (other than marketing communications) to you which we think may be of interest to you by post or by email or similar technology;
(c) send to you marketing communications relating to our business which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications to be sent by emailing us);
(d) provide other companies with statistical information about our users - but this information will not be used to identify any individual user.
You have the right to withdraw your consent to marketing information at any time by emailing us at Enquiries@stepbysteplistening.com
8. Purposes of processing your personal data
Below is a description of the ways we intend to use your personal data.
|Purpose / Activity||Type of Data||Lawful Basis for Processing|
|To register you as a new customer||(a) Identity (b) Contact||Performance of a contract with you|
|To deliver our service to you in line with our business of coaching||(a) Identity (b) Contact (c) Personal meeting notes||Performance of a contract with you|
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business Communications|
|To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation|
|To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile||Necessary for our legitimate interests to develop our products/services and grow our business|
|In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)||(a) Identity (b) Contact (c) Profile (d) Usage (g) Technical||Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud|
9. Marketing Communications
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- if you provided us with your details when you entered a competition or registered for a promotion or free resources; and
- in each case, you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at Enquiries@stepbysteplistening.com at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
10. Change of purpose
We will only use your personal data 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 you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at Enquiries@stepbysteplistening.com.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.
11. Disclosures of your personal data
We may need to disclose your personal data with third parties for the reasons stated within section 5 of this policy. These parties may be:
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Service providers who provide IT and system administration services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Social media outlets whom we use to deliver relevant content and advertisements to you.
- Cloud providers and email marketing platforms, such as DropBox and AWeber, in order to manage our relationship with you.
- 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.
12. International Transfers
We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at Enquiries@stepbysteplistening.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
13. Data Security
We have appropriate security measures in place to prevent your personal data from being lost, used or accessed in an unauthorised way. We limit the access our employees, agents, contractors and other third parties have to your data. They will only process it on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
14. Data Retention
We will only keep your personal data for as long as necessary to fulfil the purposes for which we collected it. This also includes reasons that are 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
You can ask us to delete your data: see below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
15. Your Legal Rights
You may instruct us to provide you with any personal information we hold about you. Provision of such information is free however we may charge a reasonable fee if your request is unfounded, repetitive or excessive.
Your legal rights under the data protection laws can be viewed at the ICO website https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you would like to exercise any of your legal rights, please email us Enquiries@stepbysteplistening.com.
In order to confirm your identity we may need to obtain specific information from you. This is a security measure to make sure your personal data is not disclosed to any person who has no right to receive it.
We will try to respond to your request within 4 weeks, although there are occasions when this may take slightly longer. If this is the case, we will keep you updated.
You may instruct us not to process your personal data for marketing purposes. You will be asked if you wish to opt in or opt out of your data being used for marketing purposes. You can also instruct us to remove you from any existing marketing by email Enquiries@stepbysteplistening.com at any time.
16. Third-Party Links
Our website contains links to third party websites, plug-ins and applications. We are not responsible for the privacy policies of third party websites and do not have any control over them. For this reason, we encourage you to read the privacy policies for these other websites.
17. Policy Amendments
18. Intellectual Property Rights
Unless otherwise stated, we or our licensors own the intellectual property rights in the website and material on the website. Subject to the licence below, all our intellectual property rights are reserved.
19. Licence to use our website
You may view, download for caching purposes only, and print pages from the website, provided that:
- you must not republish material from this website (including republication on another website), or reproduce or store material from this website in any public or private electronic retrieval system;
- you must not reproduce, duplicate, copy, sell, resell, visit, or otherwise exploit our website or material on our website for a commercial purpose, without our express written consent.
20. Limitations of Liability
The information on this website is provided free-of-charge, and you acknowledge that it would be unreasonable to hold us liable in respect of this website and the information on this website.
Whilst we endeavour to ensure that the information on this website is correct, we do not warrant its completeness or accuracy; nor do we not commit to ensuring that the website remains available or that the material on this website is kept up-to-date.
To the maximum extent permitted by applicable law we exclude all representations, warranties and conditions (including, without limitation, the conditions implied by law of satisfactory quality, fitness for purpose and the use of reasonable care and skill).
Our liability is limited and excluded to the maximum extent permitted under applicable law. We will not be liable for any direct, indirect or consequential loss or damage arising under these terms and conditions or in connection with our website, whether arising in tort, contract, or otherwise - including, without limitation, any loss of profit, contracts, business, goodwill, data, income, revenue or anticipated savings.
However, nothing in these terms and conditions shall exclude or limit our liability for fraud, for death or personal injury caused by our negligence, or for any other liability which cannot be excluded or limited under applicable law.