Last updated 18th September 2024

1. Introduction
This Privacy and Cookie Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you (“you/your”) through the use of our services (“Services”), or the use of any landing page or Webpage we have (the “Webpage”), how that information may be used or disclosed by us and the safeguards we use to protect it.

Our Webpage and Services may contain links to third party Web Pages that are not covered by this Privacy and Cookie Policy. We therefore ask you to review the privacy statements of other Webpages and applications to understand their information practices.

We have drafted this Privacy and Cookie Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy and Cookie Policy. This Privacy and Cookie Policy
may change from time to time and your continued use of the Webpage or the Services is deemed to be accepting of such changes, so please check periodically for updates.

This Privacy and Cookie Policy was last updated on 18th September 2024. Please check back regularly to keep informed of updates to this Privacy and Cookie Policy. Please read this Privacy and Cookie Policy carefully and ensure that you understand it. Your acceptance of our Privacy and Cookie Policy is deemed to occur upon your first use of our Webpage. If you do not accept and agree with this Privacy and Cookie Policy, you must stop using our Web Page
immediately.
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. It is important that the personal data we hold about you is
accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you have any comments on this Privacy and Cookie Policy, please email them to ask@a2cm.co.uk.

2. Who We Are
2.1 Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as “the EU law retained version of the General Data Protection Regulation (2016/679), together with the UK Data Protection Act 2018 (“Data Protection Legislation”). Data Protection Legislation says we have to give you as a ‘data controller’:
– Our Webpage address is www.a2cm.co.uk
– Our company name is A2 Coaching & Mentoring
– Office 83820, PO Box 6945, London, W1A 6US

– Our nominated representative is Andy Austin and they can be contacted at ask@a2cm.co.uk.
2.2 We respect your right to privacy and will only process personal information you in accordance with the Data Protection Legislation which for the purposes of this Privacy and Cookie Policy shall mean: (i) unless and until the Data Protection Legislation is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the Data Protection Legislation or the Data Protection Act 2018 and other applicable privacy laws.

3. What we may collect
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
– Identity Data includes first name, last name, username or similar identifier. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number.
– Contact Data includes billing address, invoicing address, email address and telephone numbers.
– Health Data includes your height, weight, measurements and other related data.
– Financial Data includes bank account and payment card details.
– Transaction Data includes details about payments and other details of our Services you have purchased from us.
– Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Webpage.
– Profile Data includes your username and password, reservations made by you, your interests, preferences, feedback and survey responses.
– Usage Data includes information about how you use our Webpage and Services.
– Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
– Interaction Data includes any information that you might provide to any discussion forums on the Webpage.
– Cookies Data like many Web Pages, we use “cookies” to enhance your experience and gather information about visitors and visits to our Web Pages. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them and what kind.
– Third Parties and Information we receive from other sources. We may receive
information about you if you use any of the other Webpages we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Webpage. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.
– Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Webpage, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Webpage and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Webpage, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy and Cookie Policy.
3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Webpage feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy and Cookie Policy.
3.4 We do not collect any 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 health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3.5 Under Data Protection Legislation we will ensure that your personal data is processed lawfully, fairly and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) You have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
3.6 If we receive personal information in the course of providing our Services to you from another data subject, we expect you to have complete responsibility for ensuring that the contents of this Privacy and Cookie Policy are brought to their attention and you have obtained their consent in the process.
3.7 In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.

4. How we may collect and use your data
4.1 We (or third party data processors, agents and subcontractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. You may give us your information by filling in forms via our Webpage or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
a) present Webpage content;
b) use any of our Services;
c) create an account on our Webpage;
d) subscribe to our Services or publications;
e) request marketing to be sent to you;
f) enter a competition, promotion or survey; or
g) give us some feedback.
4.2 In addition to the above, we may use the information in the following ways:
a) To personalise your Webpage experience and to allow us to deliver the type of content and product offerings in which you are most interested.
b) To administer a contest, promotion, survey or other site feature.
c) If you have opted-in to receive our email newsletter, we may send you periodic emails. If you would no longer like to receive promotional email from us, please refer to the “How can you opt-out, remove or modify information you have provided to us?” section below. If you have not opted-in to receive email newsletters, you will not receive these emails. Visitors who register or participate in other site features such as marketing programs and ‘members-only’ content will be given a choice whether they would like to be on our email list and receive e-mail communications from us.
d) Present Webpage content effectively to you.
e) Provide information, and services that you request, or (with your consent) which we think
may interest you.
f) Carry out our contracts with you.
g) Provide the relevant Services to you
h) Tell you our charges.
4.3 If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you.
4.4 If you are a new customer, you will only be contacted if you agree to it.
4.5 We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.
4.6 In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 5, you can let us know at any time by contacting us at ask@a2cm.co.uk, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.

4.7 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
4.8 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:
a) Where we need to perform the contract we are about to enter into or have entered into with you.
b) 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.
c) Where we need to comply with a legal or regulatory obligation
4.9 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at ask@a2cm.co.uk, and we will either delete your data from our systems or move your data to our “unsubscribe list”. However, you acknowledge this will limit our ability to provide the best possible services to you.
4.10 As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email and/or telephone with information, news and offers on our services. We agree that we will not do anything that we have not agreed to under this Privacy and Cookie Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5. Cookies
5.1 All Cookies used by and on our Webpage are used in accordance with current English and EU Cookie Law.
5.2 We use cookies to distinguish users and improve our Webpage. We use both session cookies and persistent cookies.
5.3 ‘Session cookies’ allow us to track your actions during a single browsing session, but they do not remain on your device afterwards.
5.4 ‘Persistent cookies’ remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our site.
5.5 Session and persistent cookies can be either first or third party cookies. A first-party cookie is set by the website being visited; a third-party cookie is set by a different website. Both types of cookie may be used by us.
5.6 All our cookies are categorised by the role they fulfil on our Webpage:
a. Strictly Necessary: these are essential to enable you to move around our Webpage and use features such as secure services. Without these cookies such services could not be provided;

b. Functionality: allow the Webpage to remember your choices and to personal certain features. These cookies may be anonymised and cannot track your browsing activity on other websites; and
c. Performance: collect information as to how users use the Webpage. These cookies don’t collect information that identifies a visitor. The information collected is aggregated and used to improve our Webpage.
d. None of the cookies employed are classified as ‘Behavioural Targeting’.
5.7 If at any time you wish to disable our cookies, you may do so through the settings on your browser. However, if you choose to disable or delete our cookies that will prevent certain important areas and features of our service from functioning properly. (but if you do so you will not be able to use certain important features of our service). You can find additional information at AboutCookies.org.
5.8 Notwithstanding, the audit undertaken regarding our cookies, it is possible we may have missed one from our list above. If you happen to find one that is being set on our site, please let us know.

6. Where we store your data and security
6.1 We may transfer your collected data to storage outside the European Economic Area (EEA or the UK). It may be processed outside the EEA or the UK to fulfil your order and to receive our Services and deal with payment. If we do store or transfer data outside the EEA or the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA or the UK and under the Data Protection Legislation . Such steps may include, but not be limited to, the use of legally binding contract terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements. Your acceptance of this Privacy and Cookie Policy shall be your consent permitting us to store or transfer data outside the EEA or the UK if it is necessary for us to do so.

Notice for California residents of privacy practices and rights

If you are a California resident, California law may provide you with additional rights regarding your personal data.

Your rights

The California Consumer Privacy Act of 2020 (“CCPA”) gives you the following rights:

• Right to know about the personal information we collect and share:
  • The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you;
  • Please see above for information on the data we collect on you, and how we process it; and
  • We do not sell your personal information. However, we do disclose your personal data to limited third parties, as described above
• Right of deletion:
  • You have the right to request that we delete your personal information, subject to certain exceptions
  • If you wish to delete your personal data, please contact us at [email address]. Please note that we may require certain information from you in order to verify your identity before proceeding with your request.

Disclosures about your personal information

We collect the categories of personal information from you in connection with your use of our website as described above.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights.

6.2 Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.
6.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Webpage. In addition, we limit access to your personal data to those 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.
6.4 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.
6.5 By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
6.6 Any payments made by you, will be encrypted.
6.7 We have implemented security measures such as a firewall to protect any data and maintain a high level of security.

6.8 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
6.9 If we give you a password upon registration on our Webpage, you MUST keep it confidential.
6.10 We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship has ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

7. Disclosing your information
We are allowed to disclose your information in the following cases:
7.1 We are allowed to disclose your information in the following cases:
7.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer.
7.1.2 We can disclose it to other businesses in our group.
7.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
7.1.4 We can exchange information with others to protect against fraud or credit risks.
7.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data.
7.3 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under Data Protection Legislation and the law.

8. Your rights
8.1 When you submit information via our Webpage, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided above in this Privacy and Cookie Policy.
8.2 Under the Data Protection Legislation , you have the right to:
– request access to, deletion of or correction of, your personal data held by us at no cost to you;
– request that your personal data be transferred to another person (data portability);
– be informed of what data processing is taking place;
– restrict processing;
– to object to processing of your personal data; and
– complain to a supervisory authority.
8.3 You also have rights with respect to automated decision-making and profiling as set out in section 11 below.

8.4 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
8.5 To enforce any of the foregoing rights or if you have any other questions about our Webpage or this Privacy and Cookie Policy, please contact us at ask@a2cm.co.uk.

9. Links to other sites
9.1 Please note that our terms and conditions and our policies will not apply to other Web Pages that you get to via a link from our Webpage. We have no control over how your data is collected, stored or used by other Webpages and we advise you to check the privacy policies of any such Web Pages before providing any data to them.

10. Changes
10.1 If we change our Privacy and Cookie Policy, we will post the changes on this page. If we decide to, we may also email you.

11. Automated Decision-Making and Profiling
11.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under Data Protection Legislation , requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
11.2 The right described in section 11.1 does not apply in the following circumstances:
a) the decision is necessary for the entry into, or performance of, a contract between the you and us;
b) the decision is authorised by law; or
c) you have given you explicit consent.
11.3 Where we use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

12. Terms and Conditions
12.1 Please also visit our Terms and Conditions establishing the use, disclaimers, and limitations of liability governing the use of our Webpage.

13. Your Consent
13.1 By using our Webpage and by way of acknowledgment, you consent to our Privacy and Cookie Policy.

14. Dispute Resolution
14.1 The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy and Cookie Policy or any breach of it.
14.2 Any dispute shall not affect the parties’ ongoing obligations under this Privacy and Cookie Policy.
14.3 This Privacy and Cookie Policy, and any non-contractual rights arising hereunder, will be governed in accordance with English law, and the English courts shall have exclusive jurisdiction.