INTRODUCTION
This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here but we want you to be fully informed about your rights, and how Sterling Coaching uses your data. Simplicity and openness are key, but there are some important technical and legal terms!
New data protection laws are coming in across Europe. Called the General Data Protection Regulations (GDPR), they come into force on 25th May 2018 in the UK and EU. GDPR broadens the scope of personal data. Data controllers must attempt to be more transparent about processing.
If your business data is held and listed on our Contact Relationship Management system, our Data Processor, we must tell you what personal data we hold, why we hold it and what we do with it.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
When you are using the Sterling Coaching websites, Sterling Coaching is the data controller.
SECTION 1 – WHAT WE DO WITH YOUR INFORMATION
The entry in the contact data list for the company you work for may include your name, telephone and business email address. The GDPR classes your name as personal data. The email address, if it includes your name, is also classed as personal data. The telephone number may be classed as personal data. We would like to show you how you can take more control over this information.
The public sections of Sterling Coaching does not share your name or email address. We never share any part of your information with any third parties or external sources. We may have to share your data where required to do so by law.
Your information is kept and transmitted securely on our GDPR compliant data processor.
We may send you emails about our services, events, new products, other updates and relevant educational content. You will always have the option to unsubscribe from email marketing, within each email.
SECTION 2 – WHY WE HOLD THE DATA
The GDPR lists six lawful bases for processing data. We process your data based upon the following:
Legitimate Interest
For “direct marketing” this is generally the lawful basis we use for the processing we carry out. This is covered in the GDPR. The ICO say companies using this basis should conduct a “Legitimate Interests Assessment” (LIA), and we are in the process of completing this. The LIA balances your rights and our interests. The ICO consider direct B2B marketing as having a relatively low risk of causing harm, where their guidance is adhered to.
For example, we will use your engagement history to send you or make available personalised offers and information.
We also combine the behavioural history of many contacts to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your email address details to send you direct marketing information by email telling you about products and services that we think might interest you.
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 enter an AJM Business Services Ltd T/A Sterling Coaching agreement, we’ll collect your address and billing details to deliver your agreement.
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 Sterling Coaching to law enforcement.
SECTION 3 – WHERE HAS THE DATA COME FROM
Your details will have been obtained from several sources. These include: directly from yourself, GDPR compliant data providers, and online resources. Data in the public domain is also collated. You may ask us for the data specific to your records in the form of a Data Subject Access Request.
When you download, subscribe or purchase something from our online platforms, as part of the provision of information, subscribing and selling process, we collect the personal information you give us such as your name, address, contact numbers and email address.
When you browse our website, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
SECTION 4 – YOUR RIGHT TO OBJECT AND YOUR RIGHT TO RECTIFICATION
You have the right to object to the processing of your personal data that we carry out. The quickest way to do this is to use the unsubscribe link contained in the emails we send you. If you wish, you can email us your objection – please see the details below. You may also tailor your preferences and update your details on your own profile page within our data processor. This allows you to rectify any errors.
The ICO “For the public” website has helpful information about your rights and how to exercise them.
SECTION 5 – ABOUT US
Sterling Coaching is one trading arm of AJM Business Services Ltd., UK Company Registration Number 06790989, providing Business Coaching and other services to businesses and business owners and business coaches and managers globally.
One of the services offered to our contacts is the provision of educational content created by us or sourced externally. This information is provided directly by email, on digital platforms and in webinars and seminars. This information may also be available in downloadable formats requiring an online opt in process. Registration is also required for events.
Many of our contacts and clients request our knowledge of products and service provider and we may consider that they have an interest in your services. Inclusion in our contact list could allow your business to benefit. Your data enables us to better match the services you offer with businesses that may have interest in them. This works both ways. It also helps us send you targeted marketing relevant to your role in the business. We hope you enjoy the benefits of our contact service. It could bring increased business and networking chances for your business and yourself. Any introduction of your services will only be with your prior knowledge and permission. The provision of our clients information to you is also by their permission, both ways in accordance with our data policy We are committed to supporting your data protection in a lawful, fair and responsible manner.
SECTION 6 – HOW WE PROTECT YOUR PERSONAL DATA
We know how much data security matters to all our clients. 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, we also identify ways to further strengthen security.
SECTION 7 – COMMENTS
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
SECTION 8 – MEDIA
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
SECTION 9 – COOKIES
If you leave a comment on our site you may opt in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
SECTION 10 -EMBEDDED CONTENT FROM OTHER WEBSITES
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
SECTION 11 – WHO WE SHARE YOUR DATA WITH
If you request a password reset, your IP address will be included in the reset email.
SECTION 12 – HOW LONG WE RETAIN YOUR DATA
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
SECTION 13 – WHAT RIGHTS YOU HAVE OVER YOUR DATA
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
SECTION 14 – WHERE YOUR DATA IS SENT
Visitor comments may be checked through an automated spam detection service.