Our Privacy Policy

Privacy policy

Last updated August 2023.

Your privacy is important to us, and as such, we’ve sought to write this privacy policy in plain, everyday language that will hopefully be clear and not full of legal jargon.  To that end, we’d ask if you have any concerns, please contact us to discuss.

There are a few different areas of privacy that are covered in this policy:

• your privacy when engaging us as your coach
• your privacy when using our website (https://www.raf.coach),
• your privacy when contacting or engaging with us.
• Who are we?

This is the privacy policy of Raf Coaching Ltd, a company registered in England and Wales under company number 14566144 with our registered office at Faversham House, Wirral International Business Park, Old Hall Road, Wirral CH26 3NX, UK (“we” or “us”). We are the controller responsible for your personal data.

We comply with “Data Protection Requirements”, which means the General Data Protection Regulation (EU) (2016/679) (“GDPR”), and any applicable laws, regulations, and other legal requirements relating to (a) privacy, data security, and protection of personal data; and (b) the processing of any personal data, which may include, but are not limited to, the EU law retained version of the GDPR (“UK GDPR”), the Swiss Federal Act on Data Protection 2020, Lei Geral de Protecao de Dados (Brazil’s General Data Protection Law), the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act, the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act.

You can make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, we ask that you raise any concerns with us so we can deal with them before you approach the ICO, so please contact us in the first instance by emailing [email protected].

1. What are our obligations as a coach?

As part of our role as your coach, we will be bound by data protection and confidentiality obligations. We are bound by the International Coach Federation (ICF) Code of Ethics which covers matters of our professional behaviour. Confidentiality is paramount. Any information you provide us during our coaching engagement will be used solely for the purposes of providing you with coaching. As such, we will protect the information you share with us, whether it is considered personal data under the Data Protection Requirements or not.

As is explained in your coaching agreement, we will maintain confidentiality except in the following circumstances:

• We are compelled to break confidentiality by law (i.e. court order) as coaching isn’t protected in the same way as a doctor-patient relationship
• If you tell us that you’re going to do harm to yourself or another
• If you tell us you’ve committed or will commit a crime.

As a professional coach, we also engage with a coach supervisor to help us develop further as a coach and for our own self-care. When working with a supervisor, we may discuss aspects of your coaching so we can learn, validate and understand ourselves better as a coach, but no personally identifiable information is shared with the supervisor; the focus is on our coaching rather than any particular client. We will always work with a supervisor who is a member of the ICF and is also bound by the same code of ethics that we are bound by.

During our initial discovery session, we will create a document that will contain details of how we will work together, any goals of coaching and other aspects of our coaching relationship. This will be shared with you via a third-party service currently Dubsado (explained later). We will also keep a copy of this agreement for seven years to comply with any legal and insurance requirements. After such time, it will be destroyed. This document, which we co-create, will also contain details of any other notes, actions or data that we agree to capture and how they will be handled.

During a coaching session, I may take notes of keywords that you use. this helps me reflect back to you and enables me to question through curiosity more effectively.  A copy of these notes can be provided if requested but will be deleted after the coaching engagement, usually 6 weeks for security and your privacy.

3.  What data may we collect about you?

Personal data/information means any information about an individual that enables them to be identified, but it doesn’t include anonymous data. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our website, products, and services, but as explained below, we’re not able to track users over multiple visits or track individual behaviours.
• Marketing and Communications Data includes your preferences in receiving marketing from our third parties and us and your communication preferences.
• Health Data includes information about your physical health, mental well-being, medical diagnoses, health risk factors, and what your occupation is. These are considered a special category of personal data.

Aggregated Data, such as statistical or demographic data for any purpose, isn’t considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We don't automatically collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). We also don’t collect any information about criminal convictions and offences. This is unless you have decided to share this information about yourself while you’re receiving our coaching services, and we will protect this personal data as detailed in this policy.

4.  How is your personal data collected?

We will collect personal data about you through our direct interactions, and so it is personal data you choose to share with us. You may give us your Identity and Contact by filling in the contact form on our website or by corresponding or engaging with us by post, phone, email, social media or otherwise. It’s possible we may also receive personal data about you from third parties and public sources, such as Google or Companies House.

5.  How do we use your personal data?

We’ll only use your personal data when we can rely on a legitimate (lawful) basis, such as:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal obligation.

6.  For what purposes will we use your personal data?

We have set out below the ways we may use your personal data and which of the legitimate bases we rely on to do so:

7. What cookies does our website use?

Short answer, it doesn’t. When browsing our website, we don’t store or track personal data about you unless you choose to sign-up to our email list (as explained above).

We specifically avoid Google Analytics due to the intrusive nature of tracking involved and instead, we have opted privacy privacy-focused service called Beam Analytics (as explained below). Within Beam, we have disabled the use of tracking cookies and anonymised IP addresses. This means we can gain insights into the general usage of our website, but we can’t track users over multiple visits or track individual behaviours.

8. Who hosts our website?

We use Midnight to host our website, which may also maintain server logs which will be used in the event of any security issues. Midnight also ensures that the traffic to our website is encrypted; however, we also use Cloudflare to help maintain the security of our website.

Through our website, we get rudimentary statistics on the geographic area where traffic to our website originates, but we don’t obtain any other personally identifiable information. It’s interesting to look at every now and then out of curiosity, but we don’t use this information for any purpose.

9. What third-party services do we use?

We use a variety of third party services (sub-processors) as part of our business activities and you/we will therefore share your personal data with these sub-processors. It’s important to note that we have no control over the privacy policies/practices of these sub-processors, and we’ve summarised them in the table below to explain why we use them and where you can find more information about them.

As things change, it’s possible that the links or details may become out of date – if that happens, please do let us know and we will update this policy to reflect that.

Where we share your personal data with those sub-processors, they will be bound by confidentiality and data protection obligations. We do this to ensure your personal data is kept safe and secure.

When else might we disclose your personal data?

In addition to the third parties listed above, we may also disclose your information in the following cases:

• If we want to sell our business or our company, we can disclose it to the potential buyer
• We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006
• We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety, or rights
• We can exchange information with others to protect against fraud or credit risks.

How do we secure your personal data?

Data security is of great importance to us, and to protect your data, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the data we collect. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions, and they 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.

If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further recurrence.

Can we transfer your data internationally?

We may transfer your personal data outside of the European Economic Area (EEA) or the UK where we engage third parties to provide services on our behalf (such as those sub-processors listed above). Whenever we transfer your personal data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it 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
• where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.

How long will we retain your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 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, regulatory, tax, accounting or other requirements.

What are your legal rights?

Under certain circumstances, you have rights under Data Protection Requirements in relation to your personal data:

• Request access to your personal data.
• Request correction of your personal data.
• Request the erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please email us at [email protected].

You won’t have to pay a fee to access your personal data (or to exercise any of the other rights), but we can charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we can refuse to comply in these circumstances. We may need you to provide evidence of your identity as a security measure, and 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, but it could take 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 and keep you updated.

What if you live in California?

If you are a California resident, we process your personal data in accordance with the CCPA, and you have a right to know when or before we collect your personal data. The CCPA gives you the following rights:

• How we collect, use and disclose your personal data

This is explained throughout this policy

Your CCPA rights and choices

As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

Exercising the right to know you

You can ask that we disclose to you the personal data we’ve collected about you. You also have a right to request additional information about categories of their personal data collected, sold, or disclosed, the purposes for that we collect or sell your personal data, the categories of sources of personal data, and the categories of third parties with whom we disclosed this personal information. This is all set out in this policy. It is important to emphasise that we don’t under any circumstances sell your personal data, nor do we ever plan to.

Exercising the right to delete

You can ask that we delete the personal data, subject to certain limitations under applicable law.

Non-discrimination

We’re not permitted to discriminate against you for exercising your rights under the CCPA.

If you would like to exercise any of these rights, please email us at [email protected]. You can choose to do this by designating in writing a power of attorney or an authorised agent who can make these requests on your behalf to the same email. We will need to have proof that you have authorised any other person to make the request on your behalf, and we may need you to verify your identity directly with us.

If you would like us to provide or delete certain bits of personal data we have collected about you, you will need to verify your identity to the degree of certainty required by law. We will then verify your request by asking you to send it from the email address associated with your account or requiring you to provide the information necessary to verify your account.

What about third-party links?

This policy only relates to our website. We might have links on/within our services to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

Will we make changes to this policy?

We can update this policy from time to time as laws change or as our website or services change. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.