Our RWC Privacy Policy
This privacy policy applies between you, the Client, and Rachel Wells trading as Rachel Wells Coaching, the owner and
provider of the Services. Rachel Wells trading as Rachel Wells Coaching takes the privacy of your information very
seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your
use of the Website.
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Please read this privacy policy carefully.
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Definitions and interpretation
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1.
In this privacy policy, the following definitions are used:
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Data: collectively all information that you submit to Rachel Wells trading as Rachel Wells Coaching via
online platforms including email. This definition incorporates, where applicable, the definitions
provided in the Data Protection Laws;
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Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation
GDPR: the UK General Data Protection Regulation;
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Rachel Wells trading as Rachel Wells Coaching: we or us
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User: you or any third party that accesses the Website and is not either (i) employed by Rachel Wells trading as
Rachel Wells Coaching and acting in the course of their employment or (ii) engaged as a consultant
or otherwise providing services to Rachel Wells trading as Rachel Wells Coaching and accessing the
Website in connection with the provision of such services;
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2.In this privacy policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this privacy policy.
3.Scope of this privacy policy
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This privacy policy applies only to the actions of Rachel Wells trading as Rachel Wells Coaching and Users.
For purposes of the applicable Data Protection Laws, Rachel Wells trading as Rachel Wells Coaching is the "data
controller". This means that Rachel Wells trading as Rachel Wells Coaching determines the purposes for which, and
the manner in which, your Data is processed.
4.Data collected
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We may collect the following Data, which includes personal Data, from you:
a. name;
b. job title;
c. profession;
d. contact Information such as email addresses and telephone numbers;
e. information relating to company/business information needed for the successful provision of services;
in each case, in accordance with this privacy policy.
How we collect Data
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5.We collect Data in the following ways:
a. data is given to us by you;
b. data is received from other sources; and
c. data is collected automatically.
Data that is given to us by you
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6.Rachel Wells trading as Rachel Wells Coaching will collect your Data in a number of ways, for example:
a. when you contact us through a Website, by telephone, post, e-mail or through any other means;
b. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
c. when you make payments to us, through our payment platform or otherwise;
d. when you elect to receive marketing communications from us;
e. when you use our services;
in each case, in accordance with this privacy policy.
Data that is received from publicly available third parties sources
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7.We will receive Data about you from the following publicly available third party sources:
a. public business databases and contact databases including LinkedIn profiles and pages.
Data that is collected automatically
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8.To the extent that you access any of our website platforms, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make
improvements to Website content and navigation, and includes your IP address, the date, times and frequency with
which you access the Website and the way you use and interact with its content.
9.Our use of Data
Any or all of the above Data may be required by us from time to time in order to provide you with the best possible
service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping and service delivery;
b. improvement of our products / services;
c. transmission by email of marketing materials that may be of interest to you;
d. contact for market research purposes which may be done using email, telephone, fax or mail. Such information
may be used to customise or update the Website and media platforms
in each case, in accordance with this privacy policy.
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10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are
not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights"
below).
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11. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for
example, you contact us to ask us for more details about a particular product/service, and we are marketing similar
products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive
and affirmative action when consenting by, for example, checking a tick box that we'll provide.
c. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To
find out how to withdraw your consent, see the section headed "Your rights" below.
Who we share Data with
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12. We may share your Data with the following groups of people for the following reasons:
a. our employees, agents and/or professional advisors - to enable us to provide bespoke and effective services;
b. third party payment providers who process payments made over the Website - to enable third party payment
providers to process user payments and refunds;
in each case, in accordance with this privacy policy.
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Keeping Data secure
14. We will use technical and organisational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a user name that is unique to you.
b. we store your Data on secure servers.
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15. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any
misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail
address: rachel@rachelwellscoaching.org.
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16. If you want detailed information from Get Safe Online on how to protect your information and your computers and
devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get
Safe Online is supported by HM Government and leading businesses.
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Data retention
17. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the
period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
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18. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
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Your rights
19. You have the following rights in relation to your Data:
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a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we
modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally
permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which
we can use it.
e. Right to data portability - the right to request that we move, copy or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
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20. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data
(where consent is our legal basis for processing your Data), please contact us via this e-mail address:
rachel@rachelwellscoaching.org.
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21. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able
to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's
Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
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22. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes
during the period for which we hold it.
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Transfers outside the United Kingdom and European Economic Area
23. Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and
European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the UK
or EEA or one of our service providers is situated in a country outside the UK or EEA.
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24. We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means
of transfer provides adequate safeguards in relation to your data, eg by way of data transfer agreement, incorporating
the current standard contractual clauses adopted by the European Commission.
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25. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and
procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a
way that is consistent with the Data Protection Laws.
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Links to other websites
26. We may, from time to time, provide links to other websites. We have no control over such websites and are not
responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are
advised to read the privacy policy or statement of other websites prior to using them.
Changes of business ownership and control
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27. Rachel Wells trading as Rachel Wells Coaching may, from time to time, expand or reduce our business and this may
involve the sale and/or the transfer of control of all or part of Rachel Wells trading as Rachel Wells Coaching. Data
provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part
and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data
for the purposes for which it was originally supplied to us.
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28. We may also disclose Data to a prospective purchaser of our business or any part of it.
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29. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
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General
30. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights
under this privacy policy where we reasonably believe your rights will not be affected.
31. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid,
illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the
validity and enforceability of the other provisions of this privacy policy will not be affected.
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32. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a
waiver of that, or any other, right or remedy.
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33. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising
under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
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Changes to this privacy policy
34. Rachel Wells trading as Rachel Wells Coaching reserves the right to change this privacy policy as we may deem
necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and
you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the
alterations.
You may contact Rachel Wells trading as Rachel Wells Coaching by email at rachel@rachelwellscoaching.org.
This privacy policy was created on 30 November 2022 and revised on 18 May 2023.