PRIVACY POLICY

Privacy Notice 

 

High Fifteen Ltd (collectively referred to as “we”, “us” or “our” in this notice) respects your privacy and is committed to protecting your personal data. We are dedicated to being transparent about what data we collect about you and how we use it. 

 

The purpose of this privacy notice 

 

This notice aims to provide you with information about how we collect and process your data. This includes what personal data we collect, how we use your data, how we ensure your privacy is maintained and your legal rights relating to your personal data. 

 

It is important that you read this privacy notice together with any other documentation on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

 

What personal data do we collect?

 

Personal data, or personal information, means any information about an individual from which that person can be identified. 

 

We may collect the following information about you: 

 

  • Identity Data: title, first name, last name

  • Contact Data: your contact details, email address, business website, social media handles;

  • Financial data: should you engage our services, your payment details;

  • Your web browsing activities on our website;

  • Your communication and marketing preferences;

  • Publicly available personal data including information shared on social media platforms such as Twitter, Instagram and Facebook;

 

This list is not exhaustive and in specific instances, we may need to collect additional data for the purposes set out in this notice. Some of the above personal data is collected directly, i.e. through any google forms completed by you and emails. Other personal data is collected indirectly, i.e. when you are browsing our website. 

 

Recordings

 

Please note that coaching sessions may be recorded at your request. These recordings will only be taken with your consent and once the recordings have been sent and received by you, they are immediately deleted in a secure manner. These recordings will not be stored or shared in any way other than with you. 

 

Consent

 

The age of consent to data collection in the UK is 13 years of age. Our website is not intended for children and we do not knowingly collect data relating to children under this age
 

How do we use your data?

 

We use your personal data for: 

 

  • Providing our services to you;

  • Providing information to you that you request from us relating to our services;

  • Internal record keeping;

  • Improving and personalising our services;

  • Sending you relevant information updates should you sign up to receive them;

  • Promotional and Marketing purposes: with your agreement, to contact you via email or phone about relevant promotional offers, and events which we think may interest you;

  • Developing new services;

  • Client insight and market research purposes, which helps us to better understand your needs;

  • Enabling us to manage all interactions with you; 

  • To send out invoices;

  • To maintain communication and correspondence with you in regard to our services;

  • Where we have a legal right or duty to disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

 

Marketing 

 

Promotional communications: 

 

We may use your personal data for electronic marketing purposes and providing updates on products and services which are of interest and relevant to you as an individual. 

 

You have the right to opt out of receiving personal communications at any time by: 

 

  1. Clicking the “unsubscribe” link at the bottom of emails 

  2. Contacting us directly via the contact details within this notice

 

Web Advertising 

 

If you visit our website, you may receive personalised advertisements for our services whilst using other websites. Any advertisements you will see will relate to services you have viewed whilst browsing our website on your computer or other devices or which we believe are of interest to you. 

 

These advertisements are provided by us via specialist providers using “cookies” and similar technologies placed on your computer or other devices. These advertisements will be especially prominent via social media advertisements. For more information or to disable such cookies, please visit our cookie policy. [insert hyperlink].

 

Usage Data

 

We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, 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 and pattern of your service use. This is used to allow us to process and analyse the use of our website. 

 

Legal basis for using your data 

 

We are required to set out the legal basis for our processing of your personal data. 

 

We collect and use your personal data as it is necessary: 

 

  • To pursue our legitimate interests;

  • For the purposes of complying with our duties and exercising our rights under a contract for the sale of services to a client;

  • To comply with our legal obligations; or 

  • Where you have consented to the use.

 

You have the right to withdraw your consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn. 

 

Our legitimate interests 

 

The usual basis for processing your data is that it is necessary for our legitimate interests which include: 

 

  • Selling and supplying services to our clients;

  • Promoting, marketing and advertising our services; 

  • Sending promotional communications which are relevant and tailored to clients; 

  • Understanding client behaviours, preferences and needs; 

  • Improving existing services and developing new services;

  • Complying with legal and regulatory obligations; 

  • Preventing crime and fraud;

  • Handling client contracts, queries, complaints and disputes (including refunds); 

  • Managing any claims made by clients (including legal).

 

Sharing data with Third Parties 

 

Aside from our service providers, we will not disclose your personal data to any other third party, except for those set out below: 

 

  • Third party marketing partners such as Google or Facebook and other social media platforms (to deliver advertising); 

  • We store your information on all or some of the following: Gmail and Google Drive, Zoom

  • Government bodies, regulators, law enforcement agencies, courts/tribunals and insurers, where we are required to do so.

 

We will never sell or rent your data to other organisations for marketing purposes. 

 

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 policies. When you leave our website, we encourage you to read the privacy notice of every website you visit. 


International transfers

 

To deliver services to you, it may be necessary for us to share your data outside of the United Kingdom (“UK”). This will occur when service providers are located outside the UK. We shall ensure a similar degree of protection is afforded to your data when using these service providers.

 

How we protect your data

 

We are committed to keeping your personal data safe and secure. 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.  

 

The measures we have implemented are:

 

  • Strong passwords;

  • Limit access to personal data to those with a business need to know

  • Two – Factor Authentication

 

We will strive to protect your data in all means reasonably required by us to do so. However, no internet site can be 100% secure and so we cannot be held responsible for unauthorised or unintended access that is beyond our control.

 

We have appropriate measures in place to deal with any personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

How you can help us protect your data

 

We will never ask you to confirm any bank account or credit details via email, if you receive an email claiming to be from us asking you to do this, please ignore it and do not respond.

 

How long do we keep your data?

 

We will only retain your data for as long as necessary for the purpose we collected it for. 

 

If you no longer wish for us to hold your information, you can contact us (see rights below). However, please note we have a legal requirement to keep some of your personal data even after you have asked us to delete it to ensure that we can meet our legal or regulatory requirements, resolve disputes, prevent fraud or enforce our contract with you. 

 

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.

 

Your rights in respect of your data

 

You have rights relating to your personal information, these are: 

 

  • To ask for a copy of the personal data that we hold about you and check that we are lawfully processing it (right to access); 

  • To request that we delete or remove personal data held on you, where we no longer have any legal reason to retain it (right of erasure). Note: we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request; 

  • To ask us to update and correct any incomplete or inaccurate personal data that we hold about you (right of rectification); 

  • To opt out of any marketing communications that we may send to you and to object to using/holding your personal data if we have no legitimate reasons to do so (right to object); 

  • To ask us to restrict processing of data, this enables you to ask us to suspend the processing of your personal data (only in certain circumstances);

  • To ask us to supply you or a third party with some of the personal data we hold about you in a machine-readable format (right to data portability/transfer);

  • To withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide 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 above rights, please contact us using the contact details below.

 

You will not have to pay a fee to exercise any of the rights above. We may need to request specific information from you to help us confirm your identity, this is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

 

We try to respond to all requests within one month. This may be longer if the request is complex, we will notify you if this is the case.

 

Cookies 

 

We use cookies on our website. You can set your browser to refuse or block all or some of these cookies. Please note that if you disable or refuse cookies, some parts of our website may become inaccessible or not function properly. For more information on the cookies we use, please see our cookie policy. [insert hyperlink].

 

Exercising your rights

 

If you have questions about this Privacy Notice or want to exercise your rights, you may contact Vanessa Belleau using the details set out below. 

 

Contact Details: 

 

Correspondence address

Flat 12 Willow Court

11 Westwood Hill

SE26 6BQ London

 

 

Email address: hello[at]highfifteen.com

 

You have the right to lodge a complaint at any time with the Information Commissioner’s Office (ICO). You can find further information, including contact details at https://ico.org.uk

 

This notice was last updated on 9 July 2021.

 

We may update this notice from time to time so please check this page occasionally to ensure you are happy with any changes to this notice.