Privacy Policy

INTRODUCTION

By providing us with your data, you confirm to us that you are over 16 years of age.

In this privacy policy, we detail the ways in which we collect and process your personal data through your use of our sites https://vivienneedgecombe.com and https://insideoutchange.co.

This includes data you provide to us when you sign up for our newsletter or purchase services from us.

The data controller is Vivienne Edgecombe Ltd (referred to as “we”, “us” or “our” in this privacy policy); as data controller we are responsible for your personal data.

Contact Details:

Vivienne Edgecombe Ltd

10 London Mews, London W2 1HY

vivienne@vivienneedgecombe.com

As fellow human beings, we take your privacy and the integrity of your data very seriously.  If you have any concerns about 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’d be very grateful if you’d contact us first if you do have an issue, to give us the opportunity to try and resolve it for you.

1.  What data do we collect?

Personal data is defined as any information that can identify an individual. That means that if data has been anonymised and cannot identify an individual, it is not classed as personal data.

During the course of running our business, we may process the following types of data about you:

Identity Data: may include your first name, last name, date of birth and gender.

Contact Data: may include your billing address, delivery address, email address and telephone numbers.

Financial Data: may include your bank account and payment card details.

Transaction Data: may include details about payments between us and other details of purchases made by you.

Technical Data: may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access our site.

Profile Data: may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.

Usage Data: may include information about how you use our website, products and services.

Marketing and Communications Data: may include your preferences in receiving marketing communications from us.

We may also process Aggregated Data from your personal data.  As this data does not reveal your identity it is not in itself personal data. An example of this is where we review Usage Data to work out the percentage of website users using a specific feature of our site.  If Aggregated Data is linked with your personal data (meaning you can be identified from it) is treated as personal data.

 Sensitive Data:  We may need to collect sensitive data about you in order to deliver an in-person programme (such as a Mind Detox Retreat), should you decide to join one of these programmes.  This information may also be collected during the course of a coaching session and would be held in notes or recordings of the session, and may include information about your health and/or information about your philosophical beliefs.

This may be for practical purposes such as ensuring dietary requirements are met and that we are aware of any medical conditions or allergies in case of emergency while you are on an in-person programme, and it may also be unsolicited information that forms part of discussion in a coaching context.  We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

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

2.  HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you in a number of ways, including:

You provide it to us directly:  You may do this by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, in the course of (for example) purchasing our products or services, giving us feedback, asking us questions or signing up to our newsletter.

We receive it via automated technologies: As you use our site, Technical Data about your equipment, browsing actions and usage patterns may be collected, via the use of cookies, server logs and similar technologies.

View our cookie policy at https://vivienneedgecombe.com/cookie-policy/ for further details.

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

 Technical Data from the following parties:

  • analytics providers such as Google based outside the EU;
  • advertising networks [such as Facebook based outside the EU]; and

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

3.  HOW WE USE YOUR PERSONAL DATA

We will use your personal data only when legally permitted. The most common reasons for us to use your personal data are:

  • To enable us to perform the contract between us.
  • Where we need to use your data for our legitimate interests (or those of a third party) and where your interests and fundamental rights do not override those interests.
  • To enable us to comply with a legal or regulatory obligation.

We will usually only rely on consent as a legal ground for processing your personal data for the purpose of sending email marketing communications to you. You may withdraw consent to marketing at any time by emailing us at vivienne@vivienneedgecombe.com or by following the opt-out links in our marketing emails.

Detail about how we process your personal data

Below is a table showing the ways we intend to use your personal data and the legal grounds on which we will process that 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 vivienne@vivienneedgecombe.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose of processing Categories of personal data Article 6 lawful basis for processing personal data
To enable sending newsletter / marketing Identity
Contact Details
Consent
To enable contact for arranging and conducting sessions and sending of client notes/video recordings of sessions Identity
Contact Details
Consent
To enable arranging participation and to gather required information Identity
Contact Details
Consent
In case of medical emergency Identity
Allergy and medical conditions / medications
Consent

Legitimate Interest (to make sure your health and safety is assured)

For provision of appropriate meals Identity
Dietary requirements
Consent

Legitimate Interest (to make sure your health and safety is assured)

To enable sending links to downloads or training etc Identity
Contact Details
Consent
To enable sending invoices and recovering monies owed to us Identity
Contact Details
Contract
To improve continuity between sessions
To provide a record for the use of the Coach, and in some cases, the client.
To facilitate assessment, planning and evaluation of progress.
To provide a record that is clear, complete and up to date.
Identity
Contact Details
Health
Performance of Contract

Legal obligation

Client registration Identity
Contact Details
Performance of Contract
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
Identity
Contact Details
Financial
Transactional
Marketing
Performance of Contract
Legitimate Interest (to recover debts owed to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
Identity
Contact Details
Interests / use of services
Marketing & Communications
Performance of  contract
Legal obligation
To enable you to partake in a prize draw, competition or complete a survey Identity
Contact Details
Interests / use of services
Marketing & Communications
Consent
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity
Contact Details
Technical information
Performance of Contract
Legitimate Interest (for administration and IT services)
Legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising Identity
Contact Details
Interests / use of services
Marketing & Communications
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 Identity
Contact Details
Technical information
Legitimate interests (to study how customers use our products/services, to develop them, to grow 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 Identity
Contact Details
Interests / use of services
Marketing & Communications
Legitimate Interests (to develop the business)

Newsletters and other marketing communications

We will send you marketing communications if you have:

  1.  Opted in to our mailing list via our website or other avenue
  2.  Purchased a product and chosen to go onto our mailing list
  3.  in each case, you have not opted out of receiving marketing from us.

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

You may, at any time, ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at vivienne@vivienneedgecombe.com.

Opting out of receiving our marketing communications does not extend to personal data provided to us as a result of a purchase, product/service experience or other transactions.

Change of purpose

We collect your personal data for specific purposes, and will only use your data for those purposes, unless we consider that we need to use it for a different reason that 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 vivienne@vivienneedgecombe.com.

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

Where required or permitted by law, we may process your personal data without your knowledge or consent.

4.  DISCLOSURES OF YOUR PERSONAL DATA

It may be necessary for us to share your personal data with the parties set out below, for the purposes set out in the table in section 3 above:

  • Service providers who provide IT and system administration services.
  • 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.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

Any third parties to whom we transfer your data are required to treat it in accordance with the law and respect the security of your personal data. We give permission for such third parties to process your personal data only for specified purposes, and in accordance with our instructions.

5.  SECURITY OF YOUR PERSONAL DATA

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.

6.  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 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.

7.  INTERNATIONAL TRANSFERS

Given the variation of standards of protection of personal data outside of the EEA (European Economic Area, European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

We use some third-party service providers based outside the European Economic Area (EEA) so in order for them to process your personal data, it will be transferred outside the EEA.

We do our best to ensure a similar standard of data protection when transferring data outside the EEA.  We achieve this by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; 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
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If we are unable to ensure one of the above safeguards, we may request your explicit consent to the specific transfer. You have the right to withdraw this consent at any time.

Please email us at vivienne@vivienneedgecombe.com if you want further information on the transfer of your personal data out of the EEA.

8.  YOUR RIGHTS

European Data Protection law provides the following rights for individuals:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights in relation to automated decision making and profiling.

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 vivienne@vivienneedgecombe.com

No fee is charged to access your personal data (or to exercise any of your other rights). We may charge a reasonable fee if your request is unfounded, repetitive or excessive. We may refuse to comply with your request in these circumstances; if this is the case, we will let you know why we are not going to comply with your request.

We may need to confirm your identity as part of ensuring your right to access your personal data (or to exercise any of your other rights). This may involve us requesting specific information from you as a security measure to ensure that we do not disclose personal data to any person who has no right to receive it.

We may also ask you for further information to help us respond accurately and quickly to your request – usually within one month.  If we won’t be able to respond within that timeframe, we will let you know and keep you updated of our progress.

9.  THIRD-PARTY LINKS

You may find links to third-party websites, plug-ins and applications on our sites, to enable the site to work correctly, or to provide you with resources or information held outside our sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Third-party websites are not under our control, and we are not responsible for their privacy policies or processes.  We encourage you to read the privacy policy of each website you visit and engage with upon leaving our site.

10.  COOKIES

Your internet browser lets you adjust settings to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you choose to disable or refuse cookies, please note that some parts of our sites may not function as intended.  For more information about the cookies we use, please see https://vivienneedgecombe.com/cookie-policy/