The POTS Coach Approach

1. Introduction

We are committed to safeguarding the privacy of our website visitors. This policy sets out how we will treat your personal information.

In order to provide users with its services, The POTS Coach Ltd may request and/or record information about them. We therefore believe that we have a “legitimate business interest” to collect and use this information. This privacy notice explains the type of information collected; how it will be used; whether it will be disclosed to third parties and the use of cookies.

The POTS Coach websites contain hyperlinks to websites owned and operated by third parties and these websites will have their own privacy notices and The POTS Coach Ltdencourage users to review them. The POTS Coach Ltd does not accept any responsibility or liability for the practices of such third-party websites and users should read carefully their privacy statements. The POTS Coach Ltd understands that some communications may be relevant to users and others are not and some unsolicited communications are unwelcome, so it is fully committed to ensuring that the rights and obligations set out in law are respected.

2. Collecting personal information

The POTS Coach Ltd may ask for limited personal information when users register to receive a service from us. The information collected will vary depending on the part of the website visited, but only by supplying this data, is The POTS Coach able to provide users with the services requested.

We may collect, store and use the following kinds of personal information:

• Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
• Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name, which is optional, and email address);
• Information contained in or relating to any communications that you send to us or send through our website (including the communication content and meta data associated with the communication); and
• Any other personal information that you choose to send to us.
• Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with the terms of this policy.

3. Using your personal information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

We may use your personal information to:

• Administer our website and business;
• Send you non-marketing commercial communications;
• Send you email notifications that you have specifically requested;
• Send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
• Send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, 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);
• Deal with enquiries and complaints made by or about you relating to our website or our services and products;
• Deal with The POTS Ltd software support requests made by you;
• Anonymous data will be collected for research purposes to enable us to increase our knowledge in relation to POTs and other related illnesses and to devlope our courses and other services.

We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.

4. Disclosing personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

• To the extent that we are required to do so by law;
• In connection with any ongoing or prospective legal proceedings;
• 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);
• To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

5. Retaining personal information

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will send email and other marketing communications for a maximum of 24 months after initial collection unless there has been some subsequent positive contact (eg. purchase, clicking email, visiting website).

Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:

• To the extent that we are required to do so by law;
• If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
• 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).

Data we process in accordance with Our legitimate interests (to acquire new customers, to study how customers use our products/services, for running our business): 

To administer and protect our business and our platform, website or app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data): Identity and contact data. technical data, correspondence data, product and service data, response data, marketing and communications data, UGC data, and transaction data 

To improve our Platform, products/services, marketing, customer relationships and experiences: Identity and contact data. technical data, correspondence data, product and service data, response data, marketing and communications data, UGC data, and transaction data 

Data we process in accordance with Consent: 

To enable you to partake in a prize draw or competition, to leave a review or to complete a survey: Identity and contact data. technical data, response data, marketing and communications data, UGC data, and transaction data 

To deliver relevant and personalised platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you: Marketing and communications data, response data, product and service data, identity and contract data, UGC data, and transaction data 

To make suggestions and recommendations to you about goods or services that may be of interest to you: Transaction data and marketing and communications data 

4.6.4 Data we process in accordance with (d) To comply with our legal obligations: 

To keep accountancy records: Identity and contract data, product and services data, and transaction data 

4.7 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.

4.8 If we need to use your personal data for an unrelated purpose, we will notify you (which may be by way of update to this notice) and we will explain the legal basis which allows us to do so.

4.9 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Security of your personal information

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure (password and firewall-protected) servers.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping any passwords you use for accessing our website confidential; we will not ask you for your password except when you log in to our website.

All payments are processed via SagePay a secure payment gateway. We do not store any card details on our system. All website communications are processed through a SSL (Secure Socket Layer) connection which is encrypted.

7. Amendments

We may update this policy from time to time by publishing a new version on our website. The date of the latest update will be shown at the top of the Privacy Policy. You should check this page occasionally to ensure you are happy with any changes to this policy.

8. Opting Out of the various activities

If you do not wish to receive certain types of communication, just let us know. Any marketing communications you receive from us will always include a clear, simple method to ‘opt-out’ of future communications.

You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9. Your rights

• The right to be told how we use your information and obtain access to your information;
• The right to have your information rectified or erased or place restrictions on processing your information;
• The right to object to the processing of your information e.g. for direct marketing purposes;
• The right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
• Where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• The right to object to any decisions based on the automated processing of your personal data, including profiling; and
• The right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).

Provision of such rights will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

If you request a copy of your information you may be required to pay a statutory fee.

We may withhold personal information that you request or refuse erasure of data to the extent permitted by law.

10. Third party websites

Our website includes hyperlinks to, and details of, third party websites.

We have no control over, and are not responsible for, the privacy policies and practices of third parties.

11. Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

13. Cookies

Our website uses cookies, to help improve your user experience and provide analytical data. You can find full details in our cookie policy

14. Our details

This website is owned and operated by The POTS Coach Limited.

We are registered in England and Wales under registration number 14394039, and our registered office is at Unit 6 Balfour St, Leyland PR25 2TF.

You can contact us by email to info@thepotscoach.co.uk

Last updated: 08/01/2024