PRIVACY POLICY
1. WHAT THIS POLICY COVERS
This page informs you of my policies regarding the collection, use, and disclosure of personal data when you use this website and my services, and the choices you have associated with that data.
It's important that you read this policy so that you are aware of what data I collect from you and how I process it.
2. WHO I AM
Michael Aheirwe is the data controller, responsible for your personal data and operates this website, as well as providing related service, including coaching, workshops, and any related mobile or web applications.
If you have any questions about this Privacy Policy please send an email to: michael.aheirwe@gmail.com
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). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.
3. MY LEGAL BASIS FOR PROCESSING DATA
I may collect and use your personal data for several lawful reasons (referred to as “legal bases”), including:
1. Consent
In certain situations, I may collect and process your data based on your explicit consent.
2. Contractual Obligations
When it’s necessary to fulfil a contract, I process your data to enter into an agreement with you, deliver my services, meet contractual commitments, or provide information related to my offerings.
3. Legal Requirements
If required by law or regulatory authorities, I may need to collect, use, or share your data with relevant regulatory bodies.
4. Legitimate Interests
I may also use your data in the day-to-day running of my business, to ensure efficient operations, protect both clients and my business, and maintain effective systems and processes.
In some cases, I may process your information to pursue my legitimate business interests in ways that support normal business operations and respect your rights and freedoms.
4. WHAT DATA I COLLECT ABOUT YOU
I require your personal data when you indicate your interest and/or enquire about my services. Your personal data will also be used in any calls or communications I may have with you and to create and deliver any products or services which you may require.
Personal Data
While using my website or services, I may ask you to provide me with certain personal data that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
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Email address
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First name and last name
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Telephone number
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Address, State, Province, ZIP/Postal code, City
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Cookies and Usage Data (see section 13)
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Communication records via email or telephone correspondence.
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
Usage Data
I may also collect information that your browser sends whenever you visit my website or use my services, whether accessed by computer or mobile device (‘Usage Data’).
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of this website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
5. HOW I COLLECT YOUR PERSONAL DATA
Some data is automatically collected when you use my website. For more information, please refer to section 13, where I explain my use of cookies. Additional data will only be collected if you voluntarily provide it and consent to its use for purposes outlined in section 6.
Here is how and when this could happen:
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You sign up to my newsletter on my website, landing pages, emails or social media profiles.
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You contact me via email, telephone, short messaging service (SMS), or postal mail.
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You inquire about an element of my service.
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You instruct me to provide you the service.
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You opt in to my marketing communications.
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You interact with me on social media sites.
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You share information during a coaching session.
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You provide a testimonial about me either on my website or a third-party website.
I may also receive your personal data from the following third parties:
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Online coaching directories where you have posted your interest in coaching services.
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Social media sites where you have publicised your information.
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Third parties who refer you to me, such as fellow coaches or previous clients.
6. HOW I USE YOUR DATA
I use the collected data for various purposes:
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To deliver and facilitate my services to you.
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To notify you about changes to my service.
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To allow you to participate in interactive features of my service when you choose to do so.
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To provide customer care and support.
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To provide analysis or valuable information so that I can improve my service.
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To process payments.
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To share your testimonial.
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To transcribe and record coaching sessions for future reference and to provide insightful summaries of progress, breakthroughs and transformations.
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As part of regulation requirements by the International Coaching Federation and The Association of Coaching, I may be required to send names, contact information and session dates for accreditation validation purposes.
7. SERVICE PROVIDERS
I may work with third parties to provide products and deliver my service on my behalf, such as payment processing, coaching delivery, data storage, search engine support, advertising, and marketing. In some cases, these third parties may need access to certain data. When this is necessary, I take all reasonable steps to ensure that your data is handled securely, in compliance with legal obligations, and in accordance with your rights, my responsibilities, and the service provider’s legal requirements.
The service providers may use your personal data only to deliver my service to you on my behalf and are obligated not to disclose or use it for any other purpose.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow service providers to use your personal data for their own purposes and only permit them to process your personal data for the purposes specified in Section 5 and in accordance with my instructions.
8. WHERE YOUR DATA IS LOCATED
I retain your data only for as long as necessary to use it as outlined in section 6, or until you withdraw your permission. In any event, your data will be deleted if you notify me via email, telephone or post.
I will not transfer your data outside the UK. However, some of my external third-party service providers may use servers outside the European Economic Area (EEA), meaning that the processing of your personal data could involve a transfer of data outside the EEA. When your data is transferred outside the EEA by these providers, they are contractually obligated to follow EU data protection laws to maintain a similar level of protection for your data.
9. WHEN I MAY NEED TO DISCLOSE YOUR DATA
Legal Requirements
I may disclose your personal data in the good faith belief that such action is necessary to:
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Comply with a legal obligation
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Protect and defend the rights or property of my business
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Prevent or investigate possible wrongdoing in connection with my service
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Protect the personal safety of users of my service or the public
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Protect against legal liability
10. HOW I KEEP YOUR DATA SAFE
I 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. In addition, I 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.
I 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 I am legally required to do so.
11. CHILDREN'S PRIVACY
My services do not address children or anyone under the age of 18.
I do not knowingly collect personally identifiable information from children or anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided me with Personal Data, please contact me. If I become aware that I have collected Personal Data from children without verification of parental consent, I take steps to remove that information from my servers
12. LINKS TO OTHER SITES
My website may contain links to third-party websites that are not operated by me. If you click on such links, you will be directed to the third-party site. I strongly advise you to review the privacy policies of these external sites.
While I use reputable third-party providers directly involved in delivering my services, linked sites that are not part of my chosen service providers fall outside my control. Therefore, I cannot assume responsibility for the content, privacy policies, or practices of these external sites.
13. COOKIES ON MY WEBSITE
When you first enter my website, only essential cookies and scripts are loaded. Before any other cookies are loaded on your device, you will see a pop-up notification giving you the option to opt-out from the non-essential cookies.
By using my website, you may receive third-party cookies from other websites and services. These cookies are used for purposes such as advertising. These third-party cookies are not essential for my website to function.
My website uses analytics provided by Google, helping me understand how visitors use my website and improve the Service. While allowing these cookies is optional, doing so helps me enhance your experience.
The analytics service(s) used on my website include the following cookies:
Cookie Name: Google
First/Third Party: Third
Purpose: Analytics
You can control cookie settings in your internet browser, including choosing to disable all cookies or just third-party ones. Consult your browser’s help menu or device documentation for details on managing these settings.
Deleting cookies at any time may result in the loss of saved settings, such as login and personalisation options, that speed up access to my website.
To manage privacy effectively, keep your internet browser and operating system up-to-date and consult the developer’s help resources if you need assistance.
All cookies on my website comply with current UK and EU Cookie Law.
14. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.
Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.
Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you feel that processing your personal data impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios:
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If you want me to establish the data’s accuracy.
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Where my use of the data is unlawful but you do not want me to erase it.
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Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims.
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You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.
Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact me at michael.aheirwe@gmail.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.
What I may need from you
I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.
Time limit to respond
I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to michael.aheirwe@gmail.com
15. CHANGES TO THIS PRIVACY POLICY
I may update this privacy policy from time to time, either as necessary or to comply with legal requirements.
If changes to this privacy policy will directly impact how your data is processed, I will notify you in advance of these changes taking effect.
Sometimes updates may not directly affect your data processing and so I recommend reviewing this privacy policy periodically to stay informed.
Your continued use of my website or my services after these changes become effective will indicate your acceptance of the updated Privacy Policy.