Full Potential Performance Ltd & Full Potential Coaching 8 Audleigh Place
Chigwell Essex. IG7 5QT 25th April,2018
1. Important information and whoweare....................................................................... 1
2. The data we collectaboutyou.................................................................................. 3
How is your personaldatacollected?.......................................................................... 4
How we use yourpersonaldata................................................................................. 4
Disclosures of yourpersonaldata............................................................................... 8
6. Internationaltransfers............................................................................................. 8
Data security......................................................................................................... 8
Welcome to the Full Potential Performance Ltd and Full Potential Coaching’s privacy notice.
FullPotentialPerformanceLtdandFullPotentialCoachingrespectsyourprivacyandiscommitted toprotectingyourpersonaldata.Thisprivacynoticewillinform youastohowwelookafteryour personaldatawhenyouvisitourwebsite(regardlessofwhereyouvisititfrom)andtellyouabout your privacy rights and how the law protectsyou.
Important information and who we arePurpose of this privacynotice
This privacy notice aims to give you information on how Full Potential Performance Ltd and Full Potential Coaching collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
Thiswebsiteisnotintendedforchildrenandwedonotknowinglycollectdatarelatingtochildren except when receiving enquiries about our young athlete camp or scholarshipscheme.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are: Full Potential Performance Ltd / Full Potential Coaching
Full name of legal entity: Full Potential Performance Ltd / Full Potential CoachingName and title of data privacy manager: Richard Coates, Director
Email address: email@example.com
Postal address: 8 Audleigh Place, Chigwell, Essex. IG7 5QTTelephone Number: 07770523227 /02081238605
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, click here. We would, however, appreciatethechancetodealwithyourconcernsbeforeyouapproachtheICO sopleasecontact our data privacy manager herethe firstinstance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 25th April, 2018 and historic versions can be obtained by contacting us.
ThedataprotectionlawintheUKwillchangeon25thMay,2018.Althoughthisprivacynoticesets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) as we are still working towards getting our systems ready for some of thesechanges.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Thiswebsitemayincludelinkstothird-partywebsites,plug-insandapplications.Clickingonthose linksorenablingthoseconnectionsmayallowthirdpartiestocollectorsharedataaboutyou.We donotcontrolthesethird-partywebsitesandarenotresponsiblefortheirprivacystatements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect aboutyou
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Wemaycollect,use,storeandtransferdifferentkindsofpersonaldataaboutyouwhichwehave grouped togetherfollows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth andgender.
Contact Data includes billing address, delivery address, email address and telephone numbers].
Financial Data includes bank account and payment carddetails.
Health Data includes previous or current illnesses andinjuries.
TransactionDataincludesdetailsaboutpaymentstoandfromyouandotherdetailsof products and services you have purchased fromus.
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 thiswebsite.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and surveyresponses.
MarketingandCommunicationsDataincludesyourpreferencesinreceivingmarketing from us and our third parties and your communicationpreferences.
Wealsocollect,useandshareAggregatedDatasuchasstatisticalordemographicdatafor anypurpose.AggregatedDatamaybederivedfromyourpersonaldatabutisnotconsidered personal data in law as this data does not directly or indirectly reveal your identity. For example,wemayaggregateyourUsageDatatocalculatethepercentageofusersaccessing a specific website feature. However, if we combine or connect Aggregated Data with your personaldatasothatitcandirectlyorindirectlyidentifyyou,wetreatthecombineddata as personal data which will be used in accordance with this privacynotice.
WedonotcollectanySpecialCategoriesofPersonalDataaboutyou(thisincludesdetails aboutyourraceorethnicity,religiousorphilosophicalbeliefs,sexlife,sexualorientation, politicalopinions,tradeunionmembership,geneticandbiometricdata).Nordowecollect any information about criminal convictions andoffences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have withyouandyoufailtoprovidethatdatawhenrequested,wemaynotbeabletoperform thecontractwehaveoraretryingtoenterintowithyou(forexample,toprovideyouwith goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at thetime.
3. How is your personal datacollected?
We use different methods to collect data from and about you including through:
Directinteractions.YoumaygiveusyourIdentity,contactandfinancialdatabyfilling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide whenyou;
apply for our products orservices;
create an account on ourwebsite;
subscribe to our service orpublications;
request marketing to be sent toyou;
enter a competition, promotion or survey;or
give us somefeedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit otherwebsites employingourcookies.PleaseseeourcookiepolicyforfurtherdetailsbyclickingHERE.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set outbelow;
analytics providers [such as Google based inside or outside theEU];
advertising networks [such as Google AdSense based inside or outside the EU];and
search information providers such as UK Athletics / Powerof10, Facebook, Twitter and Instagram based inside or outside theEU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Barclays, Stripe and PayPal based inside or outside theEU.
IdentityandContactDatafrompubliclyavailablysourcessuchasCompaniesHouseand the Electoral Register based inside theEU.
4. How we use your personaldata
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into withyou.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override thoseinterests.
Where we need to comply with a legal or regulatoryobligation.
Generally,wedonotrelyonconsentasalegal basisforprocessingyourpersonaldataotherthan in relation to sending third party direct marketing communications to you via email or text message.Youhavetherighttowithdrawconsenttomarketingatanytimebycontactingourdata privacy manager at anytime.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personaldata,andwhichofthelegalbaseswe relyontodoso.Wehavealsoidentifiedwhat our legitimate interests are whereappropriate.
Note that we may process your personal data for more than one lawful ground depending on the specificpurposeforwhichweareusingyourdata.Pleasecontactourdataprivacymanagerifyou needdetailsaboutthespecificlegalgroundwearerelyingontoprocessyourpersonaldatawhere more than one ground has been set out in the tablebelow.
Type of data
Lawful basis for processingincluding basis oflegitimateinterest
To register you as a newcustomer
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
(c) Deliver coaching and training plans
(e) Marketing and Communications
(f) Health data
(a) Performance of a contract with you for a product or coaching
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Deliver coaching and training plans
(d) Marketing and Communications
(a) Performance of a contract with you for a product or coaching
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use ourproducts/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to studyhow customers use
(e) Marketing Communications
our products/services, to develop them and grow ourbusiness)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(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 website content andadvertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing Communications
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
Necessary for ourlegitimate interests (to define types of customers for our products and services, to keep our website 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
Necessary for our legitimate interests (to develop ourproducts/servicesand grow ourbusiness)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can contact our data privacy manager at any time to view your personal data and make certain decisions about your personal data use.
Promotional offers from us
WemayuseyourIdentity,Contact,Technical,UsageandProfileDatatoformaviewonwhat we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call thismarketing).
We will get your express opt-in consent before we share your personal data with any company outside Full Potential Performance Ltd and Full Potential Coaching for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following theopt-outlinksonanymarketingmessagesenttoyouorbycontactingourdataprivacymanager at anytime.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Cookies are text files stored on your computer, and accessible only to the websites thatcreate them.
Most web browsers automatically accept cookies, however you may delete, or disable cookies by following the instructions at http://www.allaboutcookies.org/manage-cookies/.
Further information about cookies can be found on the Interactive Advertising Bureau’s
Log Files - Our systems automatically gather some anonymous information about visitors, including IP addresses, browser type, language, and the times and dates of webpage visits. The data collected does not include personally identifiable information and is used, as described above, for statistical analysis, to understand user behaviour, and to administer the site.
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our data privacy manager.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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.
5. Disclosures of your personaldata
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in theGlossary.
External Third Parties as set out in theGlossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.Ifachangehappenstoourbusiness,thenthenewownersmayuseyourpersonal data in the same way as set out in this privacynotice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limitaccesstoyourpersonaldatatothoseemployees,agents,contractorsandotherthirdparties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty ofconfidentiality.
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.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
ofyourpersonaldata,thepurposesforwhichweprocessyourpersonaldataandwhetherwecan achieve those purposes through other means, and the applicable legalrequirements.
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.
In some circumstances 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 associatedwithyou)forresearchorstatisticalpurposesinwhichcasewemayusethisinformation indefinitely without further notice toyou.
9. Your legalrights
Under certain circumstances, you have rights under data protection laws in relation to your personal data;
Request access to your personaldata.
Request correction of your personaldata.
Request erasure of your personaldata.
Object to processing of your personaldata.
Request restriction of processing your personaldata.
Request transfer of your personaldata.
Right to withdrawconsent.
If you wish to exercise any of the rights set out above, please contact our data privacy manager.
No fee usually required
Youwillnothavetopayafeetoaccessyourpersonaldata(ortoexerciseanyoftheotherrights). However, we may charge a reasonable fee of £10 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in thesecircumstances.
What we may need from you
Wemayneedtorequestspecificinformationfromyoutohelpusconfirmyouridentityandensure yourrighttoaccessyourpersonaldata(ortoexerciseanyofyourotherrights).Thisisasecurity measuretoensurethatpersonaldataisnotdisclosedtoanypersonwhohasnorighttoreceive
it.Wemayalsocontactyoutoaskyouforfurtherinformationinrelationtoyourrequesttospeed up ourresponse.
Time limit to respond
Wetrytorespondtoalllegitimaterequestswithinonemonth.Occasionallyitmaytakeuslonger 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 youupdated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We makesureweconsiderandbalanceanypotentialimpactonyou(bothpositiveandnegative)and yourrightsbeforeweprocessyourpersonaldataforourlegitimateinterests.Wedonotuseyour personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our data privacymanager.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
FullPotentialPerformanceLtd&FullPotentialCoaching[actingasjointcontrollersorprocessors] who are based in the UK andEurope.
External Third Parties
Service providers [acting as processors] based in the UK, Europe and US who provideIT and system administration services (Google, Survey Monkey, Dropbox,Microsoft)
Professional advisers [acting as processors or joint controllers] including coaches, lawyers, bankers, auditors and insurers based in the UK and Europe who provide coaching (running coaches), consultancy (Rachael O’Leary), banking (Barclays), legal (Bolt Burden), insurance and accounting / audit services (PKF FrancisClark).
HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based [in the United Kingdom] [who require reporting of processing activities in certaincircumstances].
YOUR LEGAL RIGHTS
You have the rightto:
Requestaccesstoyourpersonaldata(commonlyknownasa"datasubjectaccessrequest").This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processingit.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or wherewearerequiredtoeraseyourpersonaldatatocomplywithlocallaw.Note,however,that wemaynotalwaysbeabletocomplywithyourrequestoferasureforspecificlegalreasonswhich will be notified to you, if applicable, at the time of yourrequest.
Objecttoprocessingofyourpersonaldatawherewearerelyingonalegitimateinterest(orthose of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.Youalsohavetherighttoobjectwhereweareprocessingyourpersonaldatafordirect marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights andfreedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend theprocessingofyourpersonaldatainthefollowingscenarios:(a)ifyouwantustoestablishthe data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to useit.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially providedconsentforustouseorwhereweusedtheinformationtoperformacontractwithyou.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.