This privacy notice provides you with details of how we collect and process your personal data through your use of our si t e tracykennedy.com By providing us wi th your data, you warrant to us that you are over 13 years of age.
Tracy Kennedy and KENNEDY COACHING + CONSULTING, L L C i s the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: KENNEDY COACHING + CONSULTING LLC
Email address: firstname.lastname@example.org
Postal address: PO Box 1552, Topanga, CA 90290
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND HOW WE MAY PROCESS IT
Personal data means any information capable of identifying an i n d i v i d u a l . I t d o e s not include anonymized data.
We may process the following categories of personal data about you:
• Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, s o c i a l media posting or any other communication that you send us. We process t h i s data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply tocommunications sent to us, to keep records and to es t a b l i s h , pursue or defend legal claims.
• Customer Data that includes data relating to any purchases of goods and/or services such as your na m e , t i t l e , b i l l i ng address, delivery address email address, phone number, contact details, purchase details and your card details. We process t h i s data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing i s the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
• User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process t h i s data to operate our website and ensure relevant conten t is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. 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.
• 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. The source of this data is from our analytics tracking system. We process t h i s data to analyze your use of our website and otheronline services, to administer and protect our business and website, to deliver relevant website content and advertisementsto you and to understand the effectiveness of o u r advertising. Our lawful ground for this processi n g i s our legitimate interest s 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.
• Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of t h i s advertisi n g . Our lawful ground for this processing is our legitimate interests which in this case are to study how customer s use our products/services , to develop them, to grow our business and to decide our marketing strategy.
• We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant websi t e content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing i s l e gitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processi n g i s either consent or legitimate interest s (namely to grow our business) .
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity , re l i g i o us o r philosophical beliefs, s e x l i f e , 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 offenses.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more
information on this please email us a t firstname.lastname@example.org I n case we need to use your details for an unrel a t ed new purpose we w i l l let you know and explain the legal grounds for processi ng.
We may process your personal data without your knowledge or consent where t h i s i s r equired or permitted by l a w .
We do not carry out automated decision making or any type of automated profili n g .
3. 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 sending us emails). We may automatica l l y c o l l e c t certain data from you as you use our website by using cookies and si m ilar technologies.
We may receive data from third parties such as analytics providers such as Google based ou t s ide the EU, adver t i s ing networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. 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 send you market ing communic a t ions fom us i f ( i ) you made a purchase or asked for information from us about our goods o r 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 st i l l o p t out of receiving marketing emails from us at any time.
Before we share your personal d a ta wi th any third party for their own marketing purposes we will get your express consent. You can ask us or third parties t o stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at email@example.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a res ult of other transactions, such as purchases, warranty registrations etc.
5. 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, auditors and insurers
• Government bodies that require u s to report processing a c t i v i t i e s .
• 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 wi t h the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same l e v e l s 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 in place:
• We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; 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
• If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place. If none of the above safeguards is available, we may request your exp l i c i t consent to the speci f i c transfer. You will have the right to withdraw this consent at any time.
7. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. 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 k e ep it con f i d e n t i a l . 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.
To use certain features of the Website or its Content, you may need a username and password. You are responsible for maintaining the confiden t i a l i t y of the username and password, and you are responsi b l e f o r a l l a c t i v i t i e s , whether by you or by others, that occur under your username or password and within your account. You agree to notify us immediately of any unauthorized or improper use of your username or password or any other breach of security. To help protect against unauthorized or improper use, make sure that you log out at the end of each session requiring your username and password. It is your responsibility to protect your own username and password from disclosure to others. We cannot and will not be liable for any loss or damage arising from your failure to protect your username, password or account information. If you share your username or password with others, they may be able to obtain access to your personal information at your own risk .
By using our Websi te and its Content you agree to enter true and accurate information on the Website and its Content. If you enter a bogus email address we have the right to immediately deactivate your account. We will use our best efforts to keep your username and password(s) private and will not otherwise share your password(s) without your consen t , except as necessary when the law requires i t o r i n t h e good faith belief that such action is necessary, particularly when disclosure i s necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.
9. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes o f s a t isfying any lega l , accounting, or repor t ing requ i remen t s . 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 unauthorized use or disclosure, the processing purposes, if t h e se 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 si x years after they stop being customers. In some circumstances we may anonymize your personal data for research or st a t i stical purposes in which case we may use t h i s information indefinitely without further notice to you.
10. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, c o r r e c t i o n , erasure, rest r i ction, transfer, to object to processi n g , to p o r t a b i l i t y o f data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at : https://ico.org.uk/fororganisations/guide-to-the-general-data-protection-regulationgdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org. 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 i s clearly unfounded, repetitive or excessive or refuse to comply with your request in t he s e 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) . T his is a security measure to ensure that personal data is not di sclosed 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 request s . In t h i s case, we w i ll n o t i f y 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 fi r s t if you do have a complaint so that we can try t o resolve it f o r y o u .
11. THIRD-PARTY LINKS
This website may include links to third-party websi t e s, plug-ins andapplications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websi t e s and are not responsible for th e i r privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit .
We may use the standard "cookies" feature of major web browsers. We do not set any personally identifiable information in cookies, nor do we employ any data-capture mechanisms on our Website other than cookies. You may choose to disable cookies through your own web browser’ s settings. However, disabling this function may diminish your experience on the Website and some features may not work as intended. We have no access to or control over any information collected by other individuals, companies or entities whose website or materials may be linked to our Website or i t s Content.
13. ASSIGNMENT OF RIGHTS
14. NOTIFICATION OF CHANGES
Updated May 24, 2018