1.
Introduction
- 1.1 We are committed to safeguarding
the privacy of our website visitors and service users.
- 1.2 This policy applies where we are
acting as a data controller with respect to the personal data of our website
visitors and service users; in other words, where we determine the purposes and
means of the processing of that personal data.
- 1.3 We use cookies on our website.
Insofar as those cookies are not strictly necessary for the provision of our
website and services, we will ask you to consent to our use of cookies when you
first visit our website.
- 1.4 In this policy, “we”, “us” and
“our” refer to Elite Feats. For more information about us see Section 13.
2.
How we use your personal data
- 2.1 In this Section 2 we have set out:
- (a) the general categories of personal data that we
may process;
- (b) in the case of personal data that we did not
obtain directly from you, the source and specific categories of that data;
- (c) the purposes for which we may process personal
data; and
- (d) the legal bases of the processing.
- 2.2 We may process data about your use
of our website and services. The usage data may include your IP address,
geographical location, browser type and version, operating system, referral
source, length of visit, page views and website navigation paths, as well as
information about the timing, frequency and pattern of your service use. The
source of the usage data is our analytics tracking system. This usage data may
be processed for the purposes of analysing the use of the website and services.
The legal basis for this processing is your consent, or our legitimate
interests, namely monitoring and improving our website and services.
- 2.3 We may process your account data.
The account data may include your name and email address. The source of the
account data is you or your employer, or the International Coaching Community
trainer who enrolled you in an International Coaching Community Coaching
course. The account data may be processed for the purposes of operating our
website, providing our services, ensuring the security of our website and
services, maintaining back-ups of our databases, providing International
Coaching Community membership services. and communicating with you. The legal
basis for this processing is your consent or our legitimate interests, namely
the proper administration of our website and business.
- 2.4 We may process your information
included in your personal profile on our website. The profile data may include
your name, address, telephone number, email address, profile pictures, gender,
date of birth, educational details and employment details. The profile data may
be processed for the purposes of enabling and monitoring your use of our
website and services. The legal basis for this processing is your consent, our
legitimate interests, namely the proper administration of our website and
business, or providing International Coaching Community membership services.
- 2.5 We may process your personal data
that are provided in the course of the use of our services. The service data
may include your name, address, telephone number, email address, profile
pictures, gender, date of birth, educational details and employment details.
The source of the service data is you or your employer or the International
Coaching Community trainer who enrolled you in an International Coaching
Community Coaching course. The service data may be processed for the purposes
of operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and communicating
with you. The legal basis for this processing is your consent or our legitimate
interests, namely the proper administration of our website and business.
- 2.6 We may process information that you
post for publication on our website or through our services. The publication
data may be processed for the purposes of enabling such publication and
administering our website and services. The legal basis for this processing is
consent or our legitimate interests, namely the proper administration of our
website and business.
- 2.7 We may process information
contained in any enquiry you submit to us regarding goods and/or services. The
enquiry data may be processed for the purposes of offering, marketing and
selling relevant goods and/or services to you. The legal basis for this
processing is consent.
- 2.8 We may process information relating
to our customer relationships, including customer contact information.The
customer relationship data may include your name, your employer, your job title
or role, your contact details. The source of the customer relationship data is
you or your employer. The customer relationship data may be processed for the
purposes of managing our relationships with customers, communicating with
customers, keeping records of those communications and promoting our products
and services to customers. The legal basis for this processing is consent or
our legitimate interests, namely the proper management of our customer
relationships.
- 2.9 We may process information relating
to transactions, including purchases of goods and services, that you enter into
with us and/or through our website. The transaction data may include your
contact details, your card details and the transaction details. The transaction
data may be processed for the purpose of supplying the purchased goods and services
and keeping proper records of those transactions. The legal basis for this
processing is the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract and our legitimate
interests, namely the proper administration of our website and business.
- 2.10 We may process information that
you provide to us for the purpose of subscribing to our email notifications
and/or newsletters. The notification data may be processed for the purposes of
sending you the relevant notifications and/or newsletters. The legal basis for
this processing is consent or the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract.
- 2.11 We may process information contained
in or relating to any communication that you send to us. The correspondence
data may include the communication content and metadata associated with the
communication. Our website will generate the metadata associated with
communications made using the website contact forms. The correspondence data
may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business and communications with
users.
- 2.12 We may process any of your
personal data identified in this policy where necessary for the establishment,
exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of- court procedure. The legal basis for this processing
is our legitimate interests, namely the protection and assertion of our legal
rights, your legal rights and the legal rights of others.
- 2.13 We may process any of your
personal data identified in this policy where necessary for the purposes of
obtaining or maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is our legitimate
interests, namely, the proper protection of our business against risks.
- 2.14 In addition to the specific
purposes for which we may process your personal data set out in this Section 3,
we may also process any of your personal data where such processing is
necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural
person.
- 2.15 Please do not supply any other
person’s personal data to us, unless we prompt you to do so.
3.
Providing your personal data to others
- 3.1 We may disclose your personal data
to our insurers and/or professional advisers insofar as reasonably
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, obtaining professional advice, or the establishment,
exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of- court procedure.
- 3.2 In addition to the specific
disclosures of personal data set out in this Section 4, we may disclose
your personal data where such disclosure is necessary for compliance with
a legal obligation to which we are subject, or in order to protect your
vital interests or the vital interests of another natural person. We may
also disclose your personal data where such disclosure is necessary
for the establishment, exercise or defence of legal claims, whether in court proceedings
or in an administrative or out-of- court procedure.
4.
International transfers of your personal data
- 4.1 In this Section 4, we provide
information about the circumstances in which your personal data may be
transferred to countries outside the European Economic Area (EEA).
- 4.2 You acknowledge that personal data
that you submit for publication our website or services] may be available,
via the internet, around the world. We cannot prevent the use (or misuse)
of such personal data by others.
- 4.3 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 us or for one of our suppliers. They may be answering
your enquiries or working on your transactions or providing support
services. By submitting your personal data, you agree to this transfer,
storing or processing. We will take all reasonable steps to ensure that
your data is treated securely and in accordance with this privacy policy.
5.
Retaining and deleting personal data
- 5.1 This Section 5 sets out our data
retention policies and procedure, which are designed to help ensure that
we comply with our legal obligations in relation to the retention and
deletion of personal data.
- 5.2 Personal data that we process for
any purpose or purposes shall not be kept for longer than is necessary for
that purpose or those purposes.
- 5.3 We will retain your personal data
as follows:
- (a) Usage data will be retained for a minimum
period of 2 years following 28th August 2019, and for a maximum period of
5 years following 28th August 2019.
- (b) Public data will be retained for a minimum
period of 2 years following 28th August 2019, and for a maximum period of
5 years following 28th August 2019.
- (c) Customer Relationship data will be retained for
a minimum period of 2 years following 28th August 2019, and for a maximum
period of 10 years following 28th August 2019.
- (d) Transaction data will be retained for a minimum
period of 2 years following 28th August 2019, and for a maximum period of
10 years following 28th August 2019.
- (e) Enquiry data will be retained for a minimum
period of 2 years following 28th August 2019, and for a maximum period of
10 years following 28th August 2019.
- (f) Notification data will be retained for a
minimum period of 2 years following 28th August 2019, and for a maximum
period of 10 years following 28th August 2019.
- (g) Account data, profile data and service will be
will be retained for a minimum period of 2 years following 28th August
2019, and for a maximum period of 10 years following 28th August 2019,
unless you are a certified International Coaching community member of trainer,
in which case it will be retained as long as you continue to have that
status.
- 5.4 Notwithstanding the other
provisions of this Section 5, we may retain your personal data where such
retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital
interests of another natural person.
6.
Amendments
- 6.1 We may update this policy from time
to time by publishing a new version on our website.
- 6.2 You should check this page
occasionally to ensure you are happy with any changes to this policy.
- 6.3 We may notify you of significant
changes to this policy by email or through the private messaging system on
our website.
7.
Your rights
- 7.1 In this Section 7, we have
summarised the rights that you have under data protection law. Some of the
rights are complex, and not all of the details have been included in our
summaries. Accordingly, you should read the relevant laws and guidance
from the regulatory authorities for a full explanation of these rights.
- 7.2 Your principal rights under data
protection law are:
- (b) the right to rectification;
- (c) the right to erasure;
- (d) the right to restrict processing;
- (e) the right to object to processing;
- (f) the right to data portability;
- (g) the right to complain to a supervisory
authority; and
- (h) the right to withdraw consent.
- 7.3 You have the right to confirmation
as to whether or not we process your personal data and, where we do,
access to the personal data, together with certain additional information.
That additional information includes details of the purposes of the
processing, the categories of personal data concerned and the recipients
of the personal data. Providing the rights and freedoms of others are not
affected, we will supply to you a copy of your personal data. The first
copy will be provided free of charge, but additional copies may be subject
to a reasonable fee.
- 7.4 You have the right to have any
inaccurate personal data about you rectified and, taking into account the
purposes of the processing, to have any incomplete personal data about you
completed.
- 7.5 In some circumstances you have the
right to the erasure of your personal data without undue delay. Those
circumstances include: the personal data are no longer necessary in
relation to the purposes for which they were collected or otherwise processed;
you withdraw consent to consent-based processing; you object to the
processing under certain rules of applicable data protection law; the
processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right
to erasure. The general exclusions include where processing is necessary:
for exercising the right of freedom of expression and information; for
compliance with a legal obligation; or for the establishment, exercise or
defence of legal claims.
- 7.6 In some circumstances you have the
right to restrict the processing of your personal data. Those
circumstances are: you contest the accuracy of the personal data;
processing is unlawful but you oppose erasure; we no longer need the
personal data for the purposes of our processing, but you require personal
data for the establishment, exercise or defence of legal claims; and you
have objected to processing, pending the verification of that
objection. Where processing has been restricted on this basis, we may
continue to store your personal data. However, we will only otherwise
process it: with your consent; for the establishment, exercise or defence
of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
- 7.7 You have the right to object to our
processing of your personal data on grounds relating to your particular
situation, but only to the extent that the legal basis for the processing
is that the processing is necessary for: the performance of a task carried
out in the public interest or in the exercise of any official authority
vested in us; or the purposes of the legitimate interests pursued by us or
by a third party. If you make such an objection, we will cease to process
the personal information unless we can demonstrate compelling legitimate
grounds for the processing which override your interests, rights and
freedoms, or the processing is for the establishment, exercise or defence
of legal claims.
- 7.8 You have the right to object to our
processing of your personal data for direct marketing purposes (including
profiling for direct marketing purposes). If you make such an objection,
we will cease to process your personal data for this purpose.
- 7.9 You have the right to object to our
processing of your personal data for scientific or historical research
purposes or statistical purposes on grounds relating to your particular
situation, unless the processing is necessary for the performance of a
task carried out for reasons of public interest.
- 7.10 To the extent that the legal basis
for our processing of your personal data is:
- (b) that the processing is necessary for the
performance of a contract to which you are party or in order to take steps
at your request prior to entering into a contract, and such
processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used
and machine-readable format. However, this right does not apply where it
would adversely affect the rights and freedoms of others.
- 7.11 If you consider that our
processing of your personal information infringes data protection laws,
you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of
your habitual residence, your place of work, or the place of the alleged
infringement.
- 7.12 To the extent that the legal basis
for our processing of your personal information is consent, you have the
right to withdraw that consent at any time. Withdrawal will not affect the
lawfulness of processing before the withdrawal.
- 7.13 You may exercise any of your
rights in relation to your personal data by written notice to us, in
addition to the other methods specified in this Section 8.
8.
About cookies
- 8.1 A cookie is a file containing an
identifier (a string of letters and numbers) that is sent by a web server
to a web browser and is stored by the browser. The identifier is then sent
back to the server each time the browser requests a page from the server.
- 8.2 Cookies may be either “persistent”
cookies or “session” cookies: a persistent cookie will be stored by a web
browser and will remain valid until its set expiry date, unless deleted by
the user before the expiry date; a session cookie, on the other hand, will
expire at the end of the user session, when the web browser is closed.
- 8.3 Cookies do not typically contain
any information that personally identifies a user, but personal
information that we store about you may be linked to the information
stored in and obtained from cookies.
9. Cookies that
we use
- 9.1 We use cookies for the following purposes:
- (a) authentication – we use cookies to identify you
when you visit our website and as you navigate our website and determine
if you are logged into the web site.
(b) Personalisation – we use cookies [to store information about
your preferences and to personalise the website for you.
- (c) analysis – we use cookies to help us to analyse
the use and performance of our website and services..
- 10. Cookies
used by our service providers
- 10.1 Our service providers use cookies
and those cookies may be stored on your computer when you visit our
website.
- 10.2 We use Google Analytics to analyse
the use of our website. Google Analytics gathers information about website
use by means of cookies. The information gathered relating to our website
is used to create reports about the use of our website. Google’s privacy
policy is available at: https://www.google.com/policies/privacy/.
Please visit Google Analytics page to know more about cookies used by
the service:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=es-419
- 10.4 We use PayPal.com to process
credit card payments. This service uses cookies for authentication,
security and session control purposes. You can view the privacy policy of
this service provider at https://stripe.com/cookies-policy/legal
11.
Managing cookies
- 11.1 Most browsers allow you to refuse
to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version
to version. You can however obtain up-to- date information about blocking
and deleting cookies via these links:
- (a)
https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- (b) https://support.mozilla.org/en-US/kb/enable-
and-disable- cookies-website-preferences (Firefox);
- (c)
http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- (d)
https://support.microsoft.com/en-gb/help/17442/windows-
internet-explorer-delete- manage-cookies (Internet Explorer);
- (e) https://support.apple.com/kb/PH21411 (Safari); and
- (f) https://privacy.microsoft.com/en-us/windows-
10-microsoft- edge-and-privacy (Edge).
- 11.2 Blocking all cookies will have a
negative impact upon the usability of many websites.
- 11.3 If you block cookies, you will not
be able to use all the features on our website.
12.
Our details
- 12.1 This website is owned and operated
by Neesham Consulting Company.
- 12.2 We are registered in Australia and
our registered office is at 465 Hampton St, HAMPTON VIC. 3188, Australia12.3 You can contact us:
(a) by E-mail: using the email address published on
our website from time to time.
(b) using our website contact form;
13.
Data protection officer