Privacy Policy

INTRODUCTION AND TERMS

PURPOSE OF THIS PRIVACY POLICY
The Relationships Academy ('We', 'Us' or 'Our' in this privacy policy) is committed to protecting and respecting your personal information and privacy. This privacy policy aims to outline how the Relationships Academy collects and processes personal data from any of our clients, or when our website is visited (regardless of where it is visited from), and may include but is not limited to:

'Coaching Clients' - individuals whose data will be aggregated where appropriate as a couple who have coaching with us.

'Prospective Coaching Clients' - individuals who may or may not become Coaching Clients (as above) in the future.

Individuals within prospective client organisations who are acting on behalf of their organisation to engage our services.

'Customers' are individuals who have purchased access to any of our non-coaching services or merchandise, who also may or may not be Coaching clients.

Visitors to our websites.

All of which we collectively refer to as 'You' or 'Your':

When you enquire about our services.

When you are a client or prospective client.

When you visit our website, including any data you may provide through this website.

In this document, the term 'Personal Data' covers data held both in computerised systems and in structured manual records, including client notes.

Whenever you provide such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal information; including the Data Protection Act 2018 (DPA) the General Data Protection Regulation (EU) 2016/679 (GDPR).

This policy also tells you about your privacy rights and how the law protects individuals. It is important that you read this privacy policy together with any other document we may provide on specific occasions such as when we are collecting or processing personal data about you as an individual or couple (either privately or within your organisation), so that how and why we are using your data is completely clear.

CONTROLLER
When we communicate with you about our services, or you become a client of the Relationships Academy there may be scenarios where we will act as a data processor and when doing so will comply with European Data Protection Legislation. The Relationships Academy is responsible for this website and is the data controller for all the personal data collected either via the website (through any contact forms or newsletter sign ups) or via another method (including the Coaching Services we offer).

We have appointed a data protection officer (DPO) at the Relationships Academy who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF ANY CHANGES
This version (v1) was last updated on 20th July 2020. Previous versions can be obtained by contacting us. It is important that the personal data we hold is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THE DATA WE COLLECT ABOUT YOU
Personal data, means any information about an individual from which that person can be identified. It does not include data where it is not possible to identify the individual, where the data has undergone 'pseudonymisation' or has been ‘anonymised’.

‘pseudonymisation’ is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person (GDPR Article 4.5)

‘anonymised’ data does not relate to an identified or identifiable natural person or is personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable (GDPR Recital 26)

All personal data will be:

Obtained for specified and lawful purposes and not processed in any manner incompatible with those purposes.

Adequate, relevant and not excessive.

Accurate and kept up to date.

Kept safe from unauthorised or unlawful access or processing, and protected against accidental loss, destruction or damage: clients will be assigned a code, and records containing client codes will be stored separately and securely away from other client information in a locked cabinet or password protected computer.

We may collect, use, store and transfer different kinds of personal data which we have grouped together in categories which include, but are not limited to the following:

Identity Data: first name, last name, marital status, title, date of birth etc.

Contact Data: billing address, delivery address, email address and telephone numbers, and the content of your communications (except where it falls within Coaching data below).

Coaching Data includes personal data that you provide to us, or which we collect, in connection with our coaching services: our communications with you or about you, our coaching process where it relates to you or any individual referred to in our coaching sessions, your personal circumstances or history. If you are not our client we will also process your personal data as set out in the HOW WE USE YOUR PERSONAL DATA and the NEW PERSON CONTACTING OUR SITE sections below.

Financial and Transactional Data: bank account and payment card details and details of services, courses, resources or any merchandise you have purchased from us. Although we have access to the data, your Financial data is not stored by the Relationships Academy but by any associated organisations that we use to process any financial payments that you make to us. These are global organisations that store and process data in any country where they have operations or where they engage service providers. Please see the list of THIRD PARTY PROVIDERS who we currently use and review their respective privacy policies for more information.

Marketing and Communications Data: your preferences in receiving marketing from us and your communication preferences. We may also receive personal data as part of a membership or shared event to which you have subscribed to or attended. We may also receive personal data via any social media platforms that we both make use of.

Depending on the nature of the services which we provide to you we may need to collect Special Categories of Personal Data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your physical and mental health and genetic data, criminality (alleged or proven) and criminal proceedings, their disposal and sentencing.

If we need to process this Special Category Data we will require your explicit consent beforehand so we will send you a further communication asking for you to confirm your consent to this processing.

Our services, and our website, are not intended for children and we do not knowingly collect any data from children.

NEW PERSON CONTACTING OUR SITE
When receiving a new enquiry this information will be stored in order to explore whether coaching with us is right for you. See data retention times for more information.

PERSONAL DATA COLLECTED VIA OUR WEBSITE
On our website you can order services, make information requests, subscribe to marketing or support materials, or register yourself to receive information and updates.

We may collect and process the following data about you:

Information you provide to us on these pages, which may include name, address, telephone, e-mail address.

Billing information, transaction, credit card information and contact preferences.

If you contact us, we may keep a record of that correspondence.

If you visit our website, SQUARESPACE will keep a record of that correspondence information about your computer (although we have access to that data) including where available your IP address, operating system and browser type. We may use this specific data to conduct analytics and measurement of how our visitors might use our website, such as what pages are most popular or what subjects interest them the most. See our cookie policy here.

You can browse our website without disclosing your personal data.

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have (or are trying to enter into) with you (for example, to provide you with coaching or services). In this case, we may have to cancel the coaching or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

Direct interactions
You may give us your Identity, Contact, Coaching and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Discuss our services with us, whether generally or as a prospective client.
Deal with us as part of our services.
Engage us to provide services.
Request to be informed about our services.
Subscribe to our newsletters or publications.
Complete a survey.
Make a complaint.
Give us feedback.

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

Technical Data: Such as data from analytics providers or search information providers.
Marketing and Communications Data: We may on occasion use social media sites to contact you via that platform but only if you have given us your details and permission to do so. Please remember that each social media platform has their own privacy policy and will process your data differently so we encourage you to read the privacy policy of every social media provider you use and to please check your privacy settings. These other sites may send their own cookies on your device and will collect or solicit personal data from you.

THIRD-PARTY LINKS
This website may include links to third-party websites for your convenience and information. You will be reminded on Our site that by using these links, You will leave this website. When you access a third-party owned site, please note that we do not control the content and are not responsible or liable for how they process your personal data. When you leave our website, we encourage you to read the privacy policy of every website you visit and to please check your privacy settings. These other sites may send their own cookies to users, collect data, or solicit personal data from you.

HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we are entering into, or have entered into a contract for services with you.

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 basis for processing your personal data other than in relation to sending direct marketing communications to you via email.

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Will only notify you of any services we think may be helpful to you if you have consented for us to do so. For example:

We will only send you our newsletter if you have signed up for it on our website.

We will only send you separate information about training courses if you have asked to be placed on the training database.

Where consent is needed (for example to send you electronic communications), we will ask for this consent separately and clearly.

We never spam.

We will always ensure that your personal data is treated with respect and we will never sell or share it with other organisations for marketing purposes.

We may ask you to confirm or update your marketing preferences over time, such as when you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

If you have signed up for the newsletter on this website, you are consenting for us to email you information about our blogs, articles, events, workshops and courses. We will only do this monthly. We may use third party applications to hold our email database and manage our marketing. See our current list of THIRD PARTY PROVIDERS for more information.

We will not contact Coaching Clients who use our services for marketing purposes unless you sign-up to receive our newsletter via this website or unless you have given us these details via an event that you have attended.

OPTING OUT
You have the right to withdraw consent to marketing at any time. You can ask us to stop sending you our newsletter by clicking on the “unsubscribe” link in our newsletter or if you contact us.

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 would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA
Your data is confidential and will not be disclosed to anyone unless authorised by you, except in the following circumstances:

Where we have reason to believe there is the potential of serious harm to you or to others.

We have a statutory obligation to disclose information regarding prevention of terrorism, drug trafficking, money laundering, the driver in a road traffic offence, serious crime or FGM to the relevant Law enforcement agencies.

Where we are ordered by a court to disclose your personal data or if we are ordered to attend court with any relevant personal data about you.

With our professional indemnity insurer in the event we notify them of a potential circumstance which could lead to a claim or a claim is made against us and in order to defend that claim.

If we discover a potential safeguarding issue, we will need to discuss this with the other Directors of the Relationships Academy and may also need to discuss this with our preferred safeguarding partner. All Directors of the Relationships Academy follow accepted ethical and legal frameworks of confidentiality.

During coaches’ professional supervision, your personal data will be ‘pseudonymised’ unless there are rare, extenuating circumstances that cause the professional quality of the supervision to be compromised. This is also possible (although much less likely) during peer or group supervision. In any case, all people involved in any supervisory capacity would also be following accepted ethical and legal frameworks of confidentiality.

In the event that we are incapacitated, our supervisor or alternative professional may contact you in accordance with our professional will.

COOKIES
We understand that privacy is important to you and we are committed to being transparent about the technology we use.

WHAT ARE COOKIES AND WHY DO WE USE THEM?
When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies. We use cookies to help to enhance our features and services for visitors to our website.

We do not use cookies for collecting personal data, meaning we do not use cookies to identify you personally.

Our website does not automatically store or capture personal data other than logging where available your IP address, operating system and browser type.

We do not link information automatically logged by other means with personal data about specific individuals. Although we have access to this data, the Relationships Academy does not keep a record of this information as it is retained by SQUARESPACE.

Any cookies used help Us and SQUARESPACE run the website safely, efficiently as well as hopefully providing the best experience for you. For more details on the cookies used on this site please see SQUARESPACE's Cookie Policy (link opens in new window)

HOW DO YOU REMOVE AND DISABLE COOKIES?
If at any time you wish to restrict or block the cookies which are set by our websites, or indeed any other website, you can do this through your browser settings. The ‘Help’ function within your browser should tell you how.

Alternatively, you may wish to visit www.aboutcookies.org (link opens in new window) which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies.

Please be aware that restricting cookies may impact on the functionality of our website.

If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie.

For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
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, coaching or reporting requirements.

We will hold no more client or personal information than is necessary for us to be of service to you and this information will be retained only for as long as is determined necessary or required by law.

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.

Any data held for the purposes of maintaining contact with a data subject will only be held with the data subject’s prior consent and only maintained whilst that contact is necessary or until the data subject withdraws consent.

Contact data is not passed to others unless you request us to do so or in the event that we are incapacitated. In this case our supervisor or alternative professional may contact you in accordance with our professional wills.

We have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for seven years after our business relationship ends for tax purposes.

Regulation 40 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (UK) requires that we retain records and information obtained to complete due diligence for a period of five years after the end of our business relationship.

We are also required under our contract with you to keep Coaching Data so that we, and our professional indemnity insurers, may to refer to it in the event that you bring a claim against us. We will therefore retain such information for seven years from the date of the closure of your matter or the last coaching appointment you attended with us, whichever is the latter.

Any Data that doesn’t fall into any of the above categories will be held for a period of seven years after the cessation of our coaching relationship, except where there is a mutually agreed decision to retain it for longer or where we believe that it is in our best professional interests to do so.

Longer retention periods may apply for certain Coaching Data if we use pseudonymised data for research, statistical or training purposes. We will never publish your pseudonymised data (regardless of the format) without your prior expressed written permission.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research, statistical or training purposes in which case we may use this information indefinitely without further notice to you.

STRIPE is a US company and will retain personal data in compliance with applicable data protection laws, and additional sector-specific rules, as they may apply to Stripe. As a provider of payment services, Stripe is also required to comply with anti-terrorism and anti-money laundering laws. These laws require Stripe to obtain, verify, and record information that identifies businesses and persons to whom they provide services and to retain associated transactional records for at least five years after the close of the customer relationship. You can read more about STRIPE's underwriting obligations here (link opens in new window)

NEW PERSON CONTACTING OUR SITE
When receiving a new enquiry this information will be stored in order to explore whether coaching with us is right for you. This will be stored for a period of 12 months but longer if you become a client of the Relationships Academy or if we believe that there is a safeguarding issue or if there is another professional reason for us to do so.

INTERNATIONAL TRANSFERS

There may be occasions where it will be necessary to transfer your Personal Data outside the European Economic Area (EEA).

For example:

SQUARESPACE is an American company and stores any website data in multiple Tier III data centres across the United States.

Any data sent to us (either via direct email or through our website's contact page) will be stored in 123-reg’s Leeds data centre. 123-reg use international web partners to filter emails for spam and viruses, but these partners do not store any email content.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

See our current list of THIRD PARTY PROVIDERS for more information.

DATA SECURITY

We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. However, we cannot absolutely guarantee the security of your personal data.

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. This means that both you and the Information Commissioners office will be informed of any breaches of data security within 72 hours if the breach is deemed to put your individuals’ rights and freedoms at risk.

WEBSITE SECURITY
We do not give visitors to our website the option of using a secure transmission method to send us their personal data, unless otherwise indicated. Accordingly, your attention is drawn to the fact that any information carried over the Internet is not secure; information can be intercepted, lost, redirected, changed and read by other people. If you need to send us Personal Data securely for any reason then please contact us.

Our website is protected with SSL certificates to improve security. SSL (Secure Sockets Layer), is a technology that secures the connection between your browser and the website you’re visiting. All modern desktop and mobile browsers support SSL. Websites using SSL will have URLs beginning with https://.

SSL secures connections and prevents hackers from impersonating Our site or stealing your information. Because of this, our site won't load in browsers that don't support SSL.

Our checkout page is protected by SSL to protect credit card information, is Level 1 PCI compliant and use 128 bit SSL encryption.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:

Request access to your personal data.
Commonly known as a “data subject access request", this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data.
You can have any incomplete or inaccurate data that we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. In order to keep your data up to date, we will endeavour to correct any identified inaccuracies without undue delay.

Request erasure of your personal data.
You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see 4 below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data.
You can object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data.
You can ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data and Subject Access Requests.
We will not transfer your personal data to a third party. We will provide your personal data in a structured, commonly used, machine-readable format. You should note that for security reasons we do not accept Subject Access Requests via third party platforms. Requests should be made using the contact us form.

Right to withdraw consent.
You may withdraw consent at any time where we are relying on that consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED
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.

WHAT WE MAY NEED FROM YOU
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 hold Coaching Data about both partners in a couple coaching session, which (aside from the occasional individual session) includes details given by any partner who is present. Where both partners are present in a session, this Coaching Data remains confidential material of the couple relationship, as opposed to any one individual client and therefore one person alone cannot request access to these notes.

If one partner in a couple seeks information that identifies both parties present in a couple’s coaching session, we will need written consent from both of the people who have been physically present in the sessions before we release any information requested.

TIME LIMIT TO RESPOND
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.

POLICY HISTORY
This policy will be reviewed at least annually by the Relationships Academy DPO. (Date of Last review: 20th July 2020)

EXTERNAL THIRD PARTY LIST (all links open in new window)
123-REG
MAILCHIMP
QUICKBOOKS
SANTANDER
SQUARESPACE
STRIPE
SURVEYMONKEY
THIRTYONE:EIGHT (formerly CCPAS)