Privacy Notice

Citrinitas Limited (“we” or “us”, and “our” is construed accordingly) respects your privacy and is committed to protecting your personal data in compliance with all applicable data protection laws and regulations. This privacy notice (“Privacy Notice”) sets out how we collect and process your personal data when you visit our website, including any data you may provide through this website or when you purchase any services from us, and your data privacy rights.

1. Who we are and contact details

We are the controller and responsible for your personal data. If you have any questions about this Privacy Notice and our data privacy practices, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below:

Name: Samantha Whetstone

Email address: samantha@citrinitascoaching.com

Postal address: 116 St Martins Road, Coventry CV3 6ER

2. The personal data we collect

When you visit or provide data through our website, or purchase any services from us, we may collect, use, store and transfer different kinds of personal data about you as follows:

(a) Identity and contact data, including your name, title, postal address, email address and telephone numbers; and

(b) Technical and usage data, including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and information about how you use our website and services.

When you purchase coaching or consulting services from us, we will also require you to enter into a separate coaching or consulting agreement with us, setting out full details of how we may collect, use, store and transfer other personal data that you provide in the course of the coaching or consulting relationship.

3. How your personal data is collected

We use different methods to collect data from and about you including through:

(a) Direct interactions, such as filling in forms or by corresponding with us by post, phone, email or otherwise, including when you purchase or receive our services or provide feedback on these;

(b) Automated technologies as you interact with our website, including using cookies and other similar technologies; and

4. Purposes for which we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we rely on the following lawful bases for using your personal data:

(a) Where it is necessary for our performance of an agreement to which you are a party or to take steps at your request before entering into such an agreement;

(b) Where it is necessary for our legitimate interests (or those of a third party) in conducting and managing our business in order to optimise the services we provide to you, and your interests and fundamental rights do not override those interests; or

(c) Where it is necessary for our compliance with a law, regulation, or rule or guideline of any relevant regulatory authority that we are subject to.

We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please email us if you need details about the specific legal ground on which we are relying.

The specific ways in which we plan to use your personal data, and the legal bases we rely on to do so, are set out in the table below:

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. In any such case, if you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by email. 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.

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. Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to marketing as set out below.

5. Marketing

You may receive email notifications or marketing communications from us if you have previously requested information from us or purchased services from us, and you have not opted out of receiving such communications. We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

You have the right to withdraw consent to marketing at any time by following the opt-out links on any marketing message sent to you or by contacting us by email.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your purchase of services.

6. 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.

7. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above:

(a) Service providers acting as processors based in the United Kingdom or Portugal who provide IT, data storage and system administration services;

(b) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom or Portugal who provide consultancy, banking, legal, insurance and accounting services;

(c) HM Revenue & Customs, the International Coach Federation (ICF) UK Chapter, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, who require reporting of processing activities in certain circumstances; and

(d) Autoridade tributária e aduaneira, regulators and other authorities acting as processors or joint controllers based in Portugal, who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Such third-party service providers are permitted to process your personal data for specified purposes only and not for their own purposes.

8. International transfers

Other than as set out above, we do not foresee transferring your personal data outside the UK. Whenever we do transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that either: (i) the country to which we are transferring the data has been deemed to provide an adequate level of protection for personal data, or (ii) we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us by email if you would like further information in relation to any potential transfer of your personal data out of the UK.

9. 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 directors, employees, agents, contractors and other third-parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have also 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.

10. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances we will 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.

11. Your legal rights

Under certain circumstances, you have the following rights under applicable data protection laws in relation to your personal data:

(a) Right to request access to your personal data held by us;

(b) Right to request correction of your personal data held by us that you believe to be inaccurate, or completion of your personal data held by us that you believe to be incomplete;

(d) Right to object to or request restriction of processing of your personal data;

(e) Right to request transfer of your personal data to you or to another organisation; and

(f) Right to withdraw any consent you have provided to us in relation to your personal data.

If you wish to exercise any of the rights set out above, please contact us by email. Following any such request, we may need 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), as 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 aim to respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests, it may take us longer than a month to respond and, in this case, we will notify you and keep you updated.

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive, or we may refuse to comply with your request in these circumstances.

12. Changes to this Privacy Notice

We keep this Privacy Notice under regular review and we reserve the right to amend this Privacy Notice from time to time by posting any updated version on this website.

13. Your duty to inform us of changes and provide data

It is important that the personal data we hold about you is accurate and current, and you should therefore keep us informed if your personal data changes during your relationship with us.

Where we need to collect personal data about you under law, regulation, or rule or guideline of any relevant regulatory authority or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement or provide you with certain services. In this case, we may need to terminate the agreement we have with you and we will notify you if this is the case at the time.

14. Third-party links

Our website 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 policy or notice of every website you visit.

15. Complaints

In the event that you have any complaints with regards to our data privacy practices, we encourage you to notify us promptly using the contact details above and discuss this with us in the first instance. If you feel that your concerns have not been resolved by us in a satisfactory manner, you may make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).