Privacy Notice

Last updated: March 2021

We are dedicated to safeguarding and preserving your privacy when visiting our site or communicating electronically with us.

This Policy covers the following:

Who Tania Cuturi Coaching is
What information does TCC collect?
Who is the data controller?
How do we use your information?
Who may use your information?
Third party links and services
How do we protect your information?
Where is your information processed?
Marketing Communications
How long do we keep your information?
Change in Terms of Privacy
Your rights
Complaints

This Policy applies to all of the personal data Tania Cuturi Coaching (“TCC”, “we”, “us”, “ours”, “ourselves”) collects about you, including information collected at any events and/or information collected on https://www.taniacuturicoaching.com/ and any other websites (including mobile access), or social media platforms through which you contact us or access our Services (all of which are referred to as the “Site” in this policy).

TCC recognises the importance of protecting its users’ privacy. To that end we have created this privacy statement and policy in order to demonstrate our commitment to privacy. Information on how Site content can and cannot be used is also listed below.

This Privacy Policy should be read in conjunction with our Terms. We may occasionally amend this Policy. Any new policy will automatically be effective when it is published on the Site. You should therefore return here regularly to view our most up to date Policy. You should also print a copy for your records.

Who is Tania Cuturi Coaching?

Tania Cuturi Coaching’s website (available at https://www.taniacuturicoaching.com/) is owned and operated by Tania Cuturi. Tania Cuturi Coaching is based in London, United Kingdom.

We are registered with the Information Commissioner’s Office (ICO) under registration number ZA901275.

The Person responsible for data protection is Mrs. Tania Cuturi. For any queries relating to the management of your personal data please do not hesitate to send us an email at taniacuturi@me.com

Tania Cuturi Coaching’s website (available at https://www.taniacuturicoaching.com/) is created and operated by Wix.com.

What Information does TCC collect?

Most of the information we collect is information provided directly by you. This may include:

Contact information – information such as name, job title, company name, email address, physical mailing address and telephone number
Professional information – such as your employment background, job description and related information
Transaction information – your contact information, the services you are interested in, and your purchasing requirements
Responses to surveys – information you provide in responding to a survey on the Site, via an app or email, on the telephone or otherwise and,
Any other information collected.

TCC may also collect, and process information obtained through the Site or the device you are using, including:

Location information (including GPS signals sent by a mobile device, location information gathered from social media networks or sensors or IP address data from your device
information from cookies, web beacons or from the internet, including your IP address, browser type, operating system, domain name, access times, which pages you visit within our Site and referring website addresses – for more on this please see the next section below on how we use your information.

TCC may use publicly accessible information to verify information that we are provided with and to manage and expand our organisation.

Throughout the website there may be forms to request information and book consultations and/or Services. These forms typically ask for contact information, and sometimes demographic information. Information from these forms is used to deliver the information, products and/or Services that you request. It may also be used to notify you of our future products, Services and/or opportunities that may be of interest to you. When completing these forms, please do not supply another person’s personal data to us unless we prompt you to do so, and you have received that individual’s consent to do so.

TCC may also make audio and video recordings of your sessions for governance, quality control and monitoring purposes and for the purposes of your viewing only. These audio and video recordings will be shared with you only. . As a coachee, you are a partner in this journey of change and progress and having a record of your coaching sessions could be beneficial for the purposes of your progress. We assure you that all such personal data will be treated as confidential and will be held strictly in accordance with, and as long as required, under Data Protection Laws and our internal policies and procedures. By signing up for our Services and coaching sessions you consent to TCC making audio and/or video recordings of your sessions for the above-mentioned purposes.

TCC does not knowingly collect or process data from anyone under the age of 13 (thirteen) years old. Our Services and Site Content are not directed at minors, i.e., persons below the age of 18 (eighteen) years, especially children below the age of 13 (thirteen) years.

Who is the data controller?

For the purposes of Data Protection Laws the data controller is Tania Cuturi Coaching.

How do we use your information?

TCC uses information collected about you as outlined in this Policy.

General

All information collected and supplied by you to TCC will be treated as confidential and only processed to provide the Services you requested and those which we believe will optimise your use of the Site. We may use your personal data for the following purposes:

To provide the information, Services or support you request, and related after-sales services
To identify you, and to contact you from time to time with service updates
To send other messages that are useful to the Service we provide, including messages regarding our coaching program as well as messages regarding our sessions
To manage our relationship with you and to carry out any related administration
To provide personalised, targeted, or location-based content, services, and advertising from us and third parties
To promote Services, or the services of our suppliers, including by email and via social media platforms (subject to the relevant marketing permissions)
To compare information for accuracy, and verify it with third parties*
To detect, investigate and prevent activity we think may be potentially illegal, unlawful or harmful and to enforce our Policy or any other purpose referenced herein or therein*
To carry out research, including market research, statistical research on site traffic, sales and other commercial information to assist us in improving the Services we provide to you and tailor the Site*
To prevent any emergency, or in situations where the health and safety of our client(s) over-rides our obligations of confidentiality*
To keep track of the areas of our Site you visit, the amount of time you spend and the date and time you access our Site to enable us to tailor it to better match your interests and/or preferences
For internal use such as governance, quality control and monitoring purposes
To maintain records that we may need to submit to the ICF (International Coaching Federation) or any other regulatory body for the purposes of maintaining our credentials.

Lawful Basis for collecting and processing your personal data

In more legal terms, TCC processes your personal data where we have your consent to do so, which you may withdraw at any time, or otherwise where this is necessary for:

The performance of our contract with you for the provision of our Services or to take preliminary steps at your request
To fulfil our legal obligations or,
The purposes of the legitimate interests pursued by us or by a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are those indicated with an “*” above, and we consider that we have implemented sufficient checks and protections to ensure that your rights and interests are not unreasonably intruded on.

*However, you can object to processing on any of these bases at any time and, if you do so, we will stop processing the personal data unless we can show compelling legitimate grounds which override your rights and interest such as, without limitation your own health and safety or the health and safety of any other person(s), or we need the data to establish, exercise or defend legal claims – see “Your rights” below.

Cookies

Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. Our Site uses “cookies” to help you access it. Also, our Site’s cookies help speed up navigation, keep track of items and help to provide you with custom-tailored content. In addition, this Site also uses cookies to remember information that you gave us, so you do not have to re-enter it each time you visit our Site.

Cookie consent

For more information on Cookie Consent you may also want to visit the UK Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.

Who may use your information?

We are committed to keeping your e-mail address confidential. We do not sell, rent or lease the subscription lists to third parties. We may disclose your personal data to enforce our policies, to comply with our legal obligations (such as if we are required to disclose your personal data under a court order, legal requirement and/or regulatory requirement) or in the interests of security, public interest or law enforcement in any country where we have entities or affiliates. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority. We may also disclose data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests.
Whilst we encourage you to inform your therapist and/or any other qualified healthcare professional you are consulting, that you are coaching with us, we will not share your information with your therapist/ NHS care provider/ GP/ any other qualified physician/medical expert unless we have your express written permission to do so or where there is an overriding public interest in disclosing the information without your consent or where your interests in terms of your health and safety over-ride our obligation of confidentiality. This is in accordance with the General Medical Council’s guidance which may from time-to-time change.
We will generally share your information/personal data with persons nominated as your “Emergency Contact” or where an “Emergency Contact” has not been nominated, with the next of kin, only in cases of emergencies where it is in the legitimate interest of the public or in the legitimate interest of our organisation or in your own legitimate interests for us to disclose the personal data or where your interests (health) over-ride our obligation of confidentiality. For such circumstances it shall be deemed that you have consented to your information being shared with the Emergency Contact or next of kin.
We share your information with third parties who help deliver our services to you. Examples include hosting our web servers, analysing data, providing marketing and administration assistance, and providing customer service. These companies will have access to your personal information as necessary to perform their functions, but they may not use that data for any other purpose.
We may share aggregated anonymised data with third parties in order to monitor our Services and to ensure consistent quality and safety relating to the Services provided to clients.
We may report to the ICF (International Coaching Federation), your participation in our coaching sessions, in order to maintain our credentials, as per the requirements of the ICF. For the purposes of submitting records to the ICF, only your name, email address, contact number, dates and duration of the coaching sessions, and no further details or notes relating to your coaching session will be shared. The only purposes for such personal data being shared will be for the ICF to verify that TCC is in compliance with its credentials requirements prescribed by the ICF.
Please remember that when you share information publicly on the Site or on social media platforms, for example a comment on a blog post, it may be indexable by search engines, including Google, which may mean that the information is made public.

Third party links and services

The Site may use and contain links to third parties’ websites. We are not responsible for the privacy practices or the content of those websites or services. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those websites. If you have asked us to share data with third party sites (such as social media sites), their servers may not be secure. Note that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result, others may nevertheless unlawfully intercept or access private transmissions or data.

How Does TCC Protect Your Information?

We take what we consider to be appropriate technical and organisational measures to guard against unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by the Site reduce our vulnerability to security problems to a level appropriate to the type of data involved. We have security measures in place to protect our user database and access to this database is restricted internally.[GD1] [MC2] [GD3] However, it remains your responsibility:

To ensure no-one else uses the Site while your device is logged on to the Site (including by logging on to your device through a mobile, Wi-Fi or shared access connection you are using)

Where is your information processed?

Hosting and back-end infrastructure

We use third-party hosting services for the purposes of hosting data and files that enable our Site to run and be distributed as well as to enable us to run specific features and functions within our Site. Some of these functions work through geographically distributed servers, thereby making it difficult to identify the exact location where the personal data is stored.

Transfer of Personal Data

We may also use outsourced services in countries outside the UK as well as the EEA (European Economic Area) from time to time in other aspects of our business. Accordingly, data obtained within the UK or any other country could be processed outside the UK and the EEA.

Where we transfer personal data to third parties outside of the UK and the EEA, we will ensure that the recipients are aware of the provisions of the GDPR and UK Data Protection Laws and that they provide an adequate level of protection for the rights of persons whose personal data has been shared with them.

In addition, all our inbound and outbound email communications are TSL (Transport Security Layer) encrypted.

Marketing communications

If you have given permission, TCC may contact you about any of the following:

Client & booking information
Occasional information about our coaching services
Updates about Tania Cuturi Coaching
Newsletters (if you have opted-in to receiving them)
New blog posts

In compliance with relevant Data Protection Law, all emails sent from TCC will clearly state who the email is from and will provide clear information on how to contact the sender. In addition, all marketing email messages will also contain concise information on how to remove yourself from our mailing list should you wish to, so that you receive no further email communication from us.

We are committed to keeping your information confidential. We will use your email address solely to provide timely information about TCC and we will maintain the information you send via email in accordance with applicable international law.

How long do we keep your information?

We will retain your personal data for only as long as it is necessary for the purposes set out in this Policy, or as is required by applicable law, and then we will delete it.

Change in Terms of Privacy

TCC reserves the right to alter its privacy policies. Any changes to the policy will be posted on this page. This site is controlled and operated by TCC from its offices within the United Kingdom. TCC makes no representations that materials, information, or content available on or through this Site are appropriate or available for use in other locations, and access to them from territories where, accessing such materials, information, or content is illegal is prohibited. Those who choose to access this Site from other locations do so on their own volition and are responsible for compliance with applicable local laws.

Site Content

You may access, download and print materials on this Site for your personal and non-commercial use. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any information, software, products or services obtained from this Site without first obtaining written consent from TCC. Furthermore, you may not use the materials found on this Site on any other websites or in a networked environment without first obtaining written consent from TCC.

All materials on this Site (as well as the organisation and layout of the Site) are owned and copyrighted by TCC. © Copyright Tania Cuturi Coaching. All rights reserved. No reproduction, distribution, or transmission of the copyrighted materials available on this Site is permitted without the written permission of TCC.

Your rights

As explained above, you have the right to opt-out of receiving marketing communications from us. In addition, to the extent permitted by the laws of your country, you may have the right to object to the processing of your personal data for direct marketing purposes. If your objection is not in relation to direct marketing in general, but to direct marketing by a particular channel, for example email or telephone, please specify the channel you are objecting to.

Under the Data Protection Act, you have the following rights in relation to your own personal data:

to request copies of your personal information
to request us to rectify incorrect information. You can also request us to complete information that you think is incomplete
to request us to erase your personal information in certain circumstances
to ask us to restrict the processing of your information in certain circumstances
Applying only to information you have given us; you may ask that we transfer the information you gave us from one organisation to another, or that we give it to you.
to object to automated decisions. We do not, however, use automated decision making
the right to withdraw consent from us continuing to process your personal data and
a right to object to processing that is likely to cause or is causing damage or distress

If you want to (1) tell us to stop using your data for direct marketing or withdraw consent from us processing your personal data for any of the purposes mentioned in this Policy; (2) exercise your subject access rights; (3) tell us about inaccurate personal data you think we hold on you; or (4) object to a use you believe we’re making of your data which is causing, or is likely to cause, damage or distress, please contact our Data Protection Manager at taniacuturi@me.com or write to us at this address:

Tania Cuturi Coaching

48a Ledbury Road

Flat 6

London

W11 2AS

Phone: +44 (0)7595 369 241

Unless the law permits us to do so, we will not charge you to exercise your subject access rights but may charge a reasonable fee reflecting our administrative costs should you request further copies of the personal data. When you contact us to exercise any of the above rights, we will first ensure that the person requesting the data is the person whose data is being sought (or that it is being requested on that person’s behalf). This may involve providing us with proof of your identity or your authority to act for the data subject. We may also ask you for any information we need to help us find the personal data you’re enquiring about.

We will also provide you with the following information relating to your personal data:

the purpose for which we’re processing it
what categories of data about you we process
the recipients of your data, if any, including specifically international or foreign organisations
our expected retention period or how we’ll calculate this, if we don’t know yet
your rights in relation to the data and
the source of the data, if we didn’t get it from you.

Should you contact us in relation to us holding incorrect, incomplete or inaccurate data about you, we will make the required corrections promptly.

Complaints

If you have any concerns about the way we are processing your personal data or our use of your personal information, you can make a complaint to us by emailing taniacuturi@me.com or by sending your complaint to:

The Data Controller

Tania Cuturi Coaching

48a Ledbury Road

Flat 6

London

W11 2AS

Phone: +44 (0)7595 369 241

You can also complain to the Information Commissioner’s Office (ICO)

The ICO’s address is:

Information Commissioner’s Office

Wycliffe House

Water Lane