PRIVACY POLICY – Orielle Taylor Coaching

This privacy policy outlines how we will meet the requirements of relevant legislation to protect your
personal data.
Thank you for trusting us with your personal information. This privacy policy outlines what we will
do to protect your personal information, and how we will use it within our business.
Orielle Taylor Coaching is a registered data controller and as such is responsible for your personal
data (referred to as “we”, “us” or “our” in this privacy notice).

1. Introduction
This is a notice to inform you of our policy about all information we hold and record about you. It
sets out the conditions under which we may process any personal information or that you provide to
us. It covers information that could identify you (“personal information”) and information that could
not identify you. In the context of the law “process” means to collect, store, transfer, use or
otherwise act on information.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors
to our website are entitled to trust that their personal information will not be used for any purpose
unintended by them, and will not accidentally be transferred to a third party.
We undertake to preserve the confidentiality of all information you provide to us, and trust that you
reciprocate.
Our policy complies with UK law accordingly implemented including the requirements of General
Data Protection Regulations and Privacy and Electronic Communications Regulations (PECR).

2. Who we are
Legal company name: Orielle Taylor Coaching
Company email address: info@orielle-taylor.co.uk
Postal address: 13 Newlands Park, Dunfermline, Fife, KY12 0RG
Directors: Orielle Taylor
Our Data Protection Officer: Orielle Taylor
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.

2. How we process information about you:
The law requires u that we process personal information under one of six defined basis and to notify
you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall
immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis
under which we have determined that we can continue to process your information.
The law on data protection sets out a number of different reasons for which a company may collect
and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in
connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you are a client or purchase an online course, book or audio download, we’ll collect
your address details for our records only or to deliver your purchase, and pass them to the relevant
courier.
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting
Orielle Taylor Coaching & Orielle Taylor to law enforcement .
Legitimate interest
In specific situations, we require your data to pursue our legitimate interests in a way which might
reasonably be expected as part of running our business and which does not materially impact your
rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We will also use your address details to send you direct marketing information by post, telling you
about products and services that we think might interest you.

3. Information we process as a contractual obligation

When you contact us about a service we provide as part of our business, create an account on our
website (buy a product or service from us, or otherwise agree to our terms and conditions) a
contract is formed between you and us. Any processing of information that may lead to a contract –
you contacting us to inquire about a service or product is also processed in this way as it may lead to
a contractual obligation.
In order to carry out our obligations under that contract we must process the information you give
us. Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most
from using our website
We process this information on the basis there is a contract between us, or that you have requested
we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide information
to monitor our performance with respect to a particular service we provide. If we use it for this
purpose, you as an individual are not personally identifiable.

5. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as
when you browse our website or ask us to provide you more information about our business,
products or services, including [insert what this includes], you provide your consent to us to process
information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example,
by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to
which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not
use your information in any way that would identify you personally. We may aggregate it in a
general way and use it to provide information, for example to monitor the performance of a
particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be
reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us [insert contact email address] or by
choosing to unsubscribe on emails that we send you.

6. Information we process for the purposes of legitimate interests
• We may process information on the basis there is a legitimate interest, either to you or
to us, of doing so.

• Where we process your information on this basis, we do after having given careful
consideration to:
o whether the same objective could be achieved through other means
o whether processing (or not processing) might cause you harm
o whether you would expect us to process your data, and whether you would, in the
round, consider it reasonable to do so.

• For example, we may process your data on this basis for the purposes of:
o record-keeping for the proper and necessary administration of our [organisational or
business]
o responding to unsolicited communication from you to which we believe you would
expect a response
o protecting and asserting the legal rights of any party
o insuring against or obtaining professional advice that is required to manage
[organisational or business] risk
o protecting your interests where we believe we have a duty to do so.

7. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order
to comply with a statutory obligation (such as HMRC tax or insurance obligations).
We may be required to give information to legal authorities if they so request or if they have the
proper authorisation such as a search warrant or court order.
This may include your personal information.

8. Sending a message via our website or contacting our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data
you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and
email address so as to be able to track our communications with you to provide a high quality
service.

9. Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content
while we investigate. If we think your complaint is vexatious or without any basis, we shall not
correspond with you about it.

10. Complaints received about our business

When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to
that other person some of the information contained in your complaint. We do this as infrequently
as possible, but it is a matter for our sole discretion as to whether we do give information, and if we
do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of
service we provide, but not in a way that could identify you or any other person.

7. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at
particular times. To help us form a better, overall understanding of you as a customer,
we combine your personal data gathered across Orielle Taylor Coaching. &
Orielle Taylor as described above, for example your customer history at both Orielle Taylor Coaching.

8. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will
treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using ‘https’
technology.

Access to your personal data is password-protected, and sensitive data such as payment
card information) is secured and tokenised to ensure it is protected.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry
out regular systems security to ensure your data is kept sage and secure.

9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is
necessary for the purpose for which it was collected.

As per our contractual agreement with our Insurance provider Balens, for all
Hypnotherapy & Coaching clients information will be held for 7 years.

At the end of that retention period, your data will either be deleted completely
Some examples of customer data retention periods:

Membership sites and lifelong e-learning platforms 10 years.

11. Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or
otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of WorldPay /PayPal
or some other reputable payment service provider. That page may be branded to look like a page on
our website, but it is not controlled by us.

14. Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have referred to us, and to credit to you commission due
for such referrals. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our
relationship. We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website

15. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when
you visit any website. They allow information gathered on one web page to be stored until it is
needed for use on another, allowing a website to provide you with a personalised experience and
the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser.
Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or
limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software
operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not
to accept them, we shall not use them for your visit except to record that you have not consented to
their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you will not
be able to use all the functionality of our website.
• We use cookies in the following ways:
· to track how you use our website
· to record whether you have seen specific messages we display on our website
· to keep you signed in our site
· to record your answers to surveys and questionnaires on our site while you complete them
· to record the conversation thread during a live chat with our support team.
[We provide more information about the cookies we use in our cookie policy].

16. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are
recorded.
We record information such as your geographical location, your Internet service provider and your IP
address. We also record information about the software you are using to browse our website, such
as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and
how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could
be used to identify you personally, even if you are not signed in to our website.

17. Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to
be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if
you have consented to our use of cookies, you may see advertisements for our products and services
on other websites.

Disclosure and sharing of your information
18. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this
notice), we sometimes receive data that is indirectly made up from your personal information from
third parties whose services we use.
No such information is personally identifiable to you.

Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.

Here’s the policy we apply to those organisations to keep your data safe and protect
your privacy:

We provide only the information they need to perform their specific services.

They may only use your data for the exact purposes we specify in our contract with
them.

We work closely with them to ensure that your privacy is respected and protected at all
times.

If we stop using their services, any of your data held by them will either be deleted or
rendered anonymous.

Examples of the kind of third parties we work with are:

IT companies who support our website and other business systems.
Operational companies such as delivery couriers.

Google/Facebook to show you products that might interest you while you’re browsing

the internet. This is based on either your marketing consent or your acceptance of
cookies on our websites. See our Cookies Notice for details.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

With your consent, given at the time you supply your personal data, we may pass that
data to a third party for their direct marketing purposes.

Or if we run a joint event with another provider, and you agree to receive direct
communications from them.

For fraud management, we may share information about fraudulent or potentially
fraudulent activity on our systems. This may include sharing data about individuals with
law enforcement bodies.

We may also be required to disclose your personal data to the police or other
enforcement, regulatory or Government body, in your country of origin or elsewhere,
upon a valid request to do so. These requests are assessed on a case-by-case basis and
take the privacy of our customers into consideration.

For further information please contact our Data Protection Officer – Orielle Taylor

To help personalise your journey through our websites we currently use the following
companies, who will process your personal data as part of their contracts with us:
• Facebook
• Twitter
• Instagram
• Linkedin
• Mailchimp

• Acuity
• Thinkific
• Eventbrite
• Meetup
• Capsule CRM
• Trello
• Capsule CRM

11. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers
outside the European Economic Area (EEA), such as Australia or the USA.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
We may transfer personal data that we collect from you to third-party data processors
in countries that are outside the EEA.

For example, this might be required in order to fulfil your order, process your payment
details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same
protection as if it were being processed inside the EEA. For example, our contracts with
third parties stipulate the standards they must follow at all times. If you wish for more
information about these contracts please contact our Data Protection Officer.

Any transfer of your personal data will follow applicable laws and we will treat the
information under the guiding principles of this Privacy Notice.

22. Access to your personal information

To obtain a copy of any information that is not provided on our website you may send us a request
at info@orielle-taylor.co.uk After receiving the request, we will confirm we have received your
request and let you know when we expect to provide you with the information within the 28 day
period required.

23. Removal of your information

If you wish us to remove personally identifiable information from our website, you may contact us at
info@orielle-taylor.co.uk.
This may limit the service we can provide to you.

24. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first
take reasonable steps to verify your identity before granting you access or otherwise taking any
action. This is important to safeguard your information.

25. Use of site by children
• If you are under 18, you may use our website only with consent from a parent or guardian
• Such child users and visitors will inevitably visit other parts of the site and will be subject to
whatever on-site marketing they find, wherever they visit.

26. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt
any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by
looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

27. How you can complain
If you are not happy with our privacy policy or if have any complaint then you should tell us by email.
Our address is info@orielle-taylor.co.uk.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good
faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right
to lodge a complaint with the Information Commissioner's Office. This can be done at
https://ico.org.uk/concerns/

How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is
necessary for the purpose for which it was collected.

As per our contractual agreement with our Insurance provider Balens, for all
Hypnotherapy & Coaching clients information will be held for 7 years.

At the end of that retention period, your data will either be deleted completely
Some examples of customer data retention periods:

Membership sites and lifelong e-learning platforms 10 years

29. Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal
jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction,
we should like to hear from you. It is your choice as to whether you wish to use our website.

30. Review of this privacy policy
We will update this privacy notice from time to time as necessary. The terms that apply to you are
those posted here on our website on the day you use our website. We advise you to print a copy for
your records.
If you have any question regarding our privacy policy, please do contact us.

How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then
stop any further emails from that particular division.

If you have an account, log in into your Thinkific/Orielle Taylor Coaching visit the ‘My Account’ area
and change your preferences.

Write to Orielle Taylor, Orielle Taylor Coaching, 13 Newlands Park, Dunfermline, Fife,
KY12 0RG

Please note that you may continue to receive communications for a short period after
changing your preferences while our systems are fully updated.

Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your
personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact our Data

Protection Officer who will be pleased to help you:
• info@orielle-taylor.co.uk
• Or write to us at Data Protection Officer, Orielle Taylor Coaching, 13 Newlands Park, Dunfermline, Fife, KY12 0RG

This notice was last updated on 20/02/2019