PRIVACY POLICY OF INTO THE NEW COACHING


Owner and Data Controller


Bernie Ritchie

Bristol, BS4 2EX, United Kingdom

Owner contact email: hello@intothenewcoaching.com


INTRODUCTION


Into The New Coaching ("we," or "us") respects your privacy and is committed to protecting your personal data. This policy explains how we collect, use, and disclose information related to our website, social media, and other communication channels, along with your choices regarding this data. By visiting intothenewcoaching.com, you consent to the practices described herein.


PERSONAL DATA WE COLLECT AND PROCESS


We may collect and process the following data about you:


Information You Provide Directly:


  • Includes your name, address, email, phone number, financial and credit card information, personal description, and photographs provided through forms, correspondence, service registration, social media interactions, surveys, or orders.

Automatically Collected Information:


  • Technical details including IP address, browser type/version, device information, operating system, and platform.
  • Information on website interaction, such as visited pages, response times, interactions (clicks, scrolling), and referring URLs.


Information from Third Parties:


  • We may receive data from third-party partners, such as technical providers, analytics providers, and social media platforms, depending on your permissions and privacy settings on those third-party services.


CATEGORIES OF PERSONAL DATA:


  • Identity Data (names, username, marital status, title, age, gender).
  • Contact Data (addresses, email, phone numbers, social media handles).
  • Transaction Data (payment details and purchase history).
  • Marketing and Communication Preferences.
  • Coaching Session Data (notes, and occasionally sensitive personal data provided explicitly during coaching sessions).


HANDLING OF COACHING SESSION INFORMATION AND SENSITIVE PERSONAL DATA:


Into The New Coaching acknowledges that coaching conversations may sometimes involve sensitive personal information relating to your health, wellbeing, personal life, or professional circumstances. We treat such information with heightened confidentiality and care.

Sensitive Data Consent (for coaching clients)


Sensitive personal data disclosed during coaching sessions is:


  • Collected only with your explicit verbal or written consent, clearly indicating your permission.
  • Recorded securely and confidentially, accessible exclusively by the data controller (Bernie Ritchie) or specifically authorised individuals bound by confidentiality obligations.
  • Handled strictly on a need-to-know basis to deliver high-quality coaching services and support.
  • Stored securely using encrypted, password-protected, and GDPR-compliant digital platforms, with access carefully restricted.


Sensitive personal data provided in coaching sessions will never be shared or disclosed to third parties without your explicit consent, unless legally mandated (such as when required by law or necessary to prevent serious harm to you or others).


You retain the right at any time to request access, rectification, or deletion of sensitive personal data shared during coaching sessions by contacting us directly via bernie@intothenewcoaching.com.


Explicit Consent for Sensitive Data:


Before discussing sensitive topics (e.g., health, personal circumstances), we will:


  • 1. Seek your verbal or written consent;
  • 2. Explain how the data will be used/stored (e.g., encrypted notes for session continuity).
  • 3. Confirm your right to withdraw consent anytime by emailing [bernie@intothenewcoaching.com].


USE OF YOUR INFORMATION:


- To deliver services you request or purchase.

- For analytics purposes to enhance service quality.

- To communicate updates, marketing, and promotional materials with your consent.

- For administrative purposes and legal compliance.


THIRD PARTY DISCLOSURES:


  • Third-Party Data Sharing


  • We work with trusted partners to deliver our services, including:


  • Payment Processors (e.g., Stripe, PayPal): To securely process transactions.
  • Email Services: To send newsletters (only with your consent).
  • Analytics Providers (e.g., Google Analytics): To analyse website usage (data is anonymised where possible).


  • These partners are contractually obligated to:


  • Process data only per our instructions.
  • Comply with GDPR/UK GDPR standards.
  • Implement robust security measures.


  • International Transfers: If data is transferred outside the UK/EEA, we ensure safeguards like Standard Contractual Clauses (SCCs) are in place.


DATA SECURITY AND STORAGE:


  • We use industry-leading digital tools with robust security settings to protect your data.
  • Personal data is stored securely, primarily within the UK, and retained as required by UK regulations (typically for 5 years following coaching engagements).


Data Retention:


How Long We Keep Your Data:


  • Coaching Notes: Retained for 5 years after your last session (unless you request deletion).
  • Financial Records: Kept for 7 years to comply with UK tax laws.
  • Marketing Data: Stored until you unsubscribe or request deletion.
  • Contracts & email exchanges: Kept for 10 years unless you request deletion earlier.


YOUR RIGHTS AND CHOICES:


  • You have the right to access, update, or request deletion of your personal data at any time.
  • Opt-out of marketing communications through provided unsubscribe links.
  • Contact us directly at hello@intothenewcoaching.com for specific requests regarding your data.


CHILDREN’S PRIVACY:


  • Our services are not directed at individuals under the age of 13, and we do not knowingly collect data from children under this age.


EXTERNAL LINKS:


  • We are not responsible for the privacy practices of external websites linked from our site. Please review their policies directly.


POLICY CHANGES:


  • This Privacy Policy may be updated periodically. Changes will be posted on our website with the effective date clearly marked.


INTERNATIONAL DATA TRANSFERS:


We primarily store and process your personal data within the United Kingdom. However, if we transfer your personal data outside of the UK or European Economic Area (EEA), we ensure that such transfers comply strictly with GDPR standards through the use of adequacy decisions, Standard Contractual Clauses (SCCs), or with your explicit consent.


COOKIE POLICY:


We use cookies to enhance your experience, analyse site performance, and deliver personalised content. These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimise user experience by customising our web page content based on visitors' browser type and/or other information.


Cookies are temporary files stored in your web browser by a website to help track usage and enable services that rely on a persistent identity. You can control which cookies you accept and remove them at any time by adjusting your browser settings or using the controls built-in to this site, but it is important to be aware that some cookies are essential and our website may not function as expected without them.


You have full control over cookie preferences and can modify or withdraw your consent at any time. To manage cookie settings, adjust your browser’s cookie preferences or utilise tools provided on our website. Please note, disabling essential cookies might affect the functionality of our website and impact your overall experience.


Types of Cookies We Use:


Essential Cookies:


These are strictly necessary for our website's functionality and allow you to navigate our site and use its features. Without these cookies, critical functionalities (such as secure login or payment processes) cannot be provided.


Analytical/Performance Cookies:


These cookies enable us to recognise and track visitors to measure website traffic, engagement, and user interaction. We use this data to improve our website's usability and performance. These cookies typically expire after 12 months.


Functionality Cookies:


Functionality cookies help enhance your browsing experience by remembering your preferences and settings (such as your language or login details). These cookies generally persist for up to 12 months unless you manually clear your browser’s cookie settings.


Marketing and Advertising Cookies:


We may occasionally use these cookies to deliver personalised content or relevant advertisements tailored to your interests, based on your browsing history. These cookies typically expire after 12 months, unless explicitly renewed through continued interaction.


LEGAL BASIS FOR PROCESSING:


We process your personal data based on the following legal grounds:


  • Consent: For marketing communications and explicit permissions provided during coaching sessions.
  • Contractual Necessity: To fulfil coaching services and process your payments.
  • Legitimate Interests: For analysing and enhancing our service offerings, provided such interests are balanced against your privacy rights.
  • Legal Obligations: To comply with applicable laws and regulatory requirements.


COMPLAINT PROCEDURE:


If you have concerns regarding our data handling practices, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).


DATA BREACH NOTIFICATIONS:


In the unlikely event of a data breach compromising your personal information, we will promptly notify affected individuals and relevant supervisory authorities in accordance with UK GDPR requirements, clearly communicating the nature of the breach and the steps taken to mitigate its impact.


Breach Notification:


In the event of a data breach, we will:


  • Notify affected individuals within 72 hours of becoming aware of the breach.
  • Provide details of the breach (e.g., type of data exposed, steps taken to mitigate risks).
  • Report to the ICO if the breach poses a risk to rights/freedoms (per UK GDPR).


DATA PORTABILITY AND RESTRICTION OF PROCESSING:


You have the right to request the transfer of your personal data to you or another data controller (data portability), as well as the right to request the restriction of our processing of your data under specific conditions, such as contesting the accuracy of your data or objecting to processing activities.


CONTACT US:


If you have questions or concerns about this Privacy Policy or your personal data, contact us at bernie@intothenewcoaching.com.


This Privacy Policy was last modified on April 3, 2025.