Privacy Policy

 

 

PRIVACY POLICY

1.  Introduction

 

This Privacy Notice provides you with details of how we collect and use your personal information when you use our websites & landing pages. This includes any information you may provide through our sites when you sign up to our newsletter, programmes, free resources, events or contact us for more information.

 

By providing us with you data, you confirm to us that you are over the age of 13

 

The Innate Coach is the data controller and is responsible for your personal data (referred to as we, us, or our in this privacy notice)

 

2. Contact Details

 

Our Full details are:

Full name of legal entity:  The Innate Coach Ltd

Email address: [email protected]

Postal address: 63-65 Heworth Road YORK YO31 0AA

If you are not happy with any aspect of how we collect or use your data, you have the right to complain to the Information Commissioner’s Office (ICO0, the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you contact us first if you do have a complaint so that we can resolve it for you.

It is important that the information that 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 protected]

 

3. What data do we collect about you?

 

Personal data means information capable of identifying an individual. It does not include anonymised data

 

1. Identity Data: This may include your first name, maiden name, last name, username, marital status, date of birth, and gender.
2. Contact details: This may include your billing address, delivery address, email address, and telephone numbers

• Employment details: This may include the name of your manager, human resources, your job title, your employer’s name, address and postcode.

1. Your past experience: This may include your relevant work experience to the programme or event you are attending
2. Your past qualifications: This may include both academic and professional qualifications.
3. Health and Accessibility data: We may collect information about your health or learning needs (for example, hearing impairment, ADHD, or other conditions) so that we can make reasonable adjustments and ensure our learning materials, coaching, and events are accessible to you.

• Financial Data: This may include your bank details and payment card details
• Transaction Details: This may include details about payments between us and other details of purchases made by you.

1. Technical Data: This may include login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone settings and location, operating systems and platform and other technology on the devices you use to access this site.
2. Profile Data: This may include your user name and password, purchases or orders, your interests, preferences, feedback and survey responses.
3. Usage Data: This may include information about ow you use our website, products and services

• Marketing and Communications Data: This may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

 

We may also use Aggregated Data from your personal data. Please be assured that this data does not reveal your identity to us and as such is not personal data. An example of this would be where we review how our website is being used by our visitors and how they are using a particular feature of our site. It will only be treated as personal data if we link this ‘Aggregated Data’ to your personal data so that you can be identified by it.

 

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example to deliver goods and services to you). If you do not provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

Sensitive Data

 

Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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 offences.

We may need to collect the following sensitive data about you in order to deliver the services of coaching or therapy. If we need to do so we will only do so if you have provided your explicit consent when you agree to work with us.

 This data might be information on your mental, emotional or physical health, religious or philosophical beliefs, your sex or sexual orientation.

 

4. How we collect your personal data

 

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

• order our products or services;
• create an account on our site;
• subscribe to our service or publications;
• request resources or marketing be sent to you;
• enter a competition, prize draw, promotion or survey; or
• give us feedback.

 

Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. You can request our cookie policy at [email protected].

 

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below

• Analytics providers such as Google based outside the EU;
• Google Form, Kajabi or Cognito questionnaire completed by you
• Paypal, GoCardless, Stripe or other payment providers
• Email service providers such as Outlook
• OneDrive
• Social Networks such as Linkedin, Instagram, Facebook & Zoom
• Whatsapp
• Technical information from Kajabi, Google Analytics, advertising platforms such as Facebook & Google addwords.
• Identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

 

5. How we use your personal data.

 

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• 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 or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at [email protected]

 

Purposes for processing your personal data

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data then please get in touch.

  

Marketing communications 

You will receive marketing communications from us if you have:

• requested information from us or purchased goods or services from us; or
• if you provided us with your details when you registered to receive further information, registered to receive our newsletter or registered to attend either an online or in person event; and
• in each case, you have not opted out of receiving that marketing.

 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

You can ask us or third parties to stop sending you marketing messages at any time by sending an email [email protected] and ask to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you which will appear at the bottom of any message.

 

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

 

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at [email protected]

 If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

5. Disclosures of your personal data

 

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above:

• Service providers who provide IT, system administration, learning-platform, communications or other operational services.
• Trusted contractors, associates and administrative support providers who help us deliver our programmes and manage our operations – for example, programme coordination, client communication, marketing support or financial administration.
• Coaches, mentors or facilitators engaged by us to deliver specific elements of our programmes or services. These individuals act under our instruction and are bound by confidentiality and data-protection obligations consistent with this policy.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Public bodies or funders (for example Combined Authorities, local councils, the Department for Work and Pensions or other government departments) where we are contractually required to share limited business or participant information for monitoring, reporting or evaluation purposes.
• Third parties to whom we sell, transfer or merge parts of our business or assets.
• Third parties with whom we have a confidential data-sharing agreement for the purposes of independent evaluation of our services.

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 with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

5A. Funded Programmes and Data Sharing

 

When we deliver programmes that are fully or partly funded by a public body (for example, a Combined Authority, Local Enterprise Partnership, local authority, the Department for Work and Pensions, or another government department), we are required to share certain information with the funding body for monitoring, reporting and evaluation purposes.

This may include details such as your name, business name, job role, sector, location, and summary information about your participation or outcomes. We will only share the information that is necessary to meet our contractual obligations under the funding agreement.

The funding body may, in turn, share anonymised or aggregated data with other government departments for audit or research purposes. We do not sell your information or use it for unrelated marketing.

 

Our lawful basis for this processing is performance of a contract (delivering the funded programme) and compliance with a legal obligation (where required under the grant or funding agreement).

 

6. International Transfers

 

Some of our service providers and partners are based outside the United Kingdom (and, in some cases, the European Economic Area). This means that their processing of your personal data may involve a transfer of data internationally.

Whenever we transfer your personal data outside the UK, we take steps to ensure that your information is protected to the same standard as it would be under UK data protection laws. This includes using one or more of the following safeguards:

 

• Adequacy decisions: We will transfer your personal data only to countries that the UK government (and, where relevant, the European Commission) has deemed to provide an adequate level of data protection.
• Appropriate safeguards: Where we use service providers in countries without an adequacy decision, we use legally approved data transfer mechanisms such as the UK International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses (SCCs) with the UK Addendum, to ensure your data is protected.
• US transfers: Where we use US-based providers, we may rely on the UK Extension to the EU-US Data Privacy Framework or equivalent safeguards to ensure your data receives adequate protection.

If none of these safeguards are available, we will ask for your explicit consent before transferring your personal data and will explain the possible risks involved.

If you would like more information about the specific safeguards we use when transferring your data outside the UK, please contact us at [email protected]

 

 

7. Data Security

 

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 limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. 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.

 

8. Data Retention

 

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.

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 requirements.

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 accordance with our need to maintain the possibility of access to client data as a result of returning clients or those who may wish to lodge a complaint in respect of our professional services to either our professional body or our insurers (i.e. in all cases perhaps after a long period of time has elapsed) or where funding has been put in place to receive services, we retain client records & data for a minimum period of 6 years. After this time all information will be destroyed/deleted.

All data pertaining to enquiries will be deleted after 2 years. Any data collected for marketing purposes in accordance with paragraph 5 will be deleted after 2 years from the last contact you have made with us (for example opening an email)

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 associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

9. Your Legal Rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request 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.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

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

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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). This is a security measure to ensure that personal data is not disclosed 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 requests. In this case, we will notify you and keep you updated.

 

10. Third Party Links

 

Our websites may include links to third-party websites, plug-ins and applications. 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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

12. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

 

 

 

DATED 24^th OCTOBER 2025