We at Umiani understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website, https://www.umiani.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Coaching Programmes” means the coaching programmes provided by Us from time to time to paying clients in person and/ or via the Platform;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below;
“Cookie Law” means 1) the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003, unless and until the said Regulations are no longer directly applicable in the UK; and subsequently 2) any legislation which succeeds the said Regulations;
“Data Protection Legislation” means 1) unless and until EU Regulation 2016/679 General Data Protection Regulation (“GDPR”) is no longer directly applicable in the UK, the GDPR and any national implementing laws, regulations, and secondary legislation (as amended from time to time), in the UK; and subsequently 2) any legislation which succeeds the GDPR;
“Platform” means the online platform through which We may release the Programme Materials to You if You join one of Our paid Coaching Programmes, or such other online platform as We may use from time to time;
2. Information About Us
Our Site is is owned and operated by Umiani, a company registered in the United Kingdom.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed.
If you have any cause for complaint about our use of your personal data, we would welcome an opportunity to resolve this with you: please contact us using the details in Part 15. If you are not happy with how we have attempted to resolve your complaint, you may contact the Information Commissioner’s Office.
6. What Data Do You Collect and How?
How We Collect the Data
Identity Information including name, age and date of birth, gender, nationality, title and social media handles.
Our contact form, online application form(s), initial chemistry telephone call and any written communications you may send to us including electronic communications.
Contact information including address, email address, telephone number.
Our contact form, online application form(s) and any written communications you may send to us including electronic communications.
Business information, including your present business and job title, business income, previous business experience and your business’s social media account details.
Our online application form(s) and chemistry telephone call with you and any written communications you may send to us including electronic communications.
Payment information including your purchase history from us.
Our online application form(s) and our billing process;
User profile information including your interests and your marketing and communications preferences. Our marketing opt-in form, website contact form, online application form(s) and any written communications you may send to us including electronic communications. Technical information including your IP address, login details, details about your browser, operating system, length of visit to pages on Our Site, page views and navigation paths, the number of times you use Our Site, time zones and other technology on the devices you use to access Our Site.
Third party analytics services provided by Google and Facebook or similar services, our security software and any written communications you may send to us including electronic communications.
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do
What Data We Use (as set out above)
Our Lawful Basis
Processing communication data
Identity and contact information supplied by you
Our legitimate interest in communicating with you, keeping records and pursuing or defending legal claims.
Providing and managing your access to Our Site.
Identity and contact information supplied by you, your user profile and technical information.
Our legitimate interests in properly administering Our Site and our business, ensuring relevant content is provided to you, and ensuring the security of Our Site.
Administering Our Site and our business.
Identity and contact information supplied by you, your payment information, your user profile and technical information.
Our legitimate interest in properly administering Our Site and our business; to ensure relevant content is provided to you, to ensure the security of Our Site, to maintain back-ups of Our Site and/ or databases and to enable publication and administration of Our Site.
Supplying our services to you.
Identity and contact information, your business information, information regarding your preferences, information regarding billing and payment, user preferences.
Our legitimate interest in entering into and performing our contract to provide you with access to our Coaching Programme(s) and related services; including processing the data to enter into the contract and supply the services you have purchased under that contract, and keeping records of those transactions
Managing payments for our services.
Identity, contact and payment information
Our legitimate interests in collecting payment for the services we supply and thereby protecting and growing our business.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/ or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and Cookie Law, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We do not carry out automated decision making or any type of automated profiling.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected (including for the purposes of satisfying any legal, accounting or reporting requirements).
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means, and the legal requirements.
For tax purposes, the law required us to keep basic information about our customers (including identity, contact and payment information as well as information on the contracts we enter into with our customers) for six years after they stop being customers.
In some circumstances, we may anonymise your personal data for research of statistical purposes in which case we may use this information indefinitely without further notice to you.
9. How and Where Do You Store or Transfer My Personal Data?
We may transfer your personal data outside the European Economic Area (“EEA”) for storage and processing. By providing any information including personal data to us, you consent to such transfer, storage and processing.
“Third countries” outside the EEA may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
· We will only transfer your personal data to countries that have been deemed to have an adequate level of protection for personal data.
· Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
For details of our third party data processors’ own privacy policies please visit their sites: Dropbox
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
· personal data provided by you is secured both in transit and at rest by encryption using Secure Socket Layer (SSL)/Transport Layer Security (TLS)
· payment via the Platform is taken via secure server, and payment information is transferred via Secure Socket Layer (SSL) Technology
· payment information is secured at rest via encryption
· access to your personal data is limited to those employees, agents, contractors, and other third parties with a legitimate need to know and they are subject to duties of confidentiality; and
· we have in place procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the relevant authorities where we are legally required to do so.
10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
We may have to share your personal data with service providers who provide IT and system administration services, and on occasion with our professional advisers such as lawyers, auditors and insurers.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation, as explained above in Part 9.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. We aim to give you control over our use of your data for direct marketing purposes (including the ability to opt out of receiving marketing emails from us), which you may do by unsubscribing using the links provided.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email address shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for the purposes of our analytics system. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please email us at firstname.lastname@example.org, marking your email “Data Protection” or “Subject Access Request” as appropriate.