Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). 

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us by email at lynda@making-it-happen.co.uk at any time. 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• External Third Parties such as service providers, professional advisers, HMRC and regulators; and

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA)and/or the UK, eg:

• [if you are based outside the EEA and/or the UK];

• [where there is an international dimension to the services we are providing to you.]

These transfers are subject to special rules under European and UK data protection law.

If you are based in the UK whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it, by ensuring at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government, or; 

• Where we use certain service providers outside of the UK, we may use specific contracts or codes of conduct approved by the UK regulators which give personal data the same protection it has in the UK. 

• If you are based within the EEA, whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

• we may use US based providers that are part of an EU approved privacy framework; or

• where we use certain service providers outside of the EEA, we may use specific contracts or codes of conduct approved by EU regulators which give personal data the same protection as it has in the EEA.

If you would like further information, please contact us using the contact details in clause 1 above.

Data security

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. 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. 

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.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

If you are not a customer we shall retain your data for [2 years] following your last engagement with us. 

In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

8. Client data and AI use and protection

We shall only submit personally identifiable client data into public AI platforms, for example using a note taker during coaching calls, to the extent that such submission complies with GDPR and any other applicable legislation. We shall implement appropriate safeguards and comply with applicable data protection laws whenever we use AI. 

9. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data: 

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us by email at lynda@making-it-happen.co.uk

10. 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, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

11. Changes to this privacy policy

We may change this privacy policy from time to time – when we do, we shall inform you via our website.

Data Complaints Policy

1. 1. We are committed to providing a high-quality service, in accordance with data protection law. At all times, we seek to comply with data protection principles by ensuring we:

• process personal data lawfully, fairly and in a transparent way;

• collect personal data for specific and legitimate purposes and do not process personal data in a way that is incompatible with those purposes;

• collect and use adequate, relevant and minimal personal data;

• take reasonable steps to make sure personal data is accurate and kept up to date;

• do not keep personal data longer than necessary; and

• implement appropriate security measures.

2. 2. We acknowledge that we may not always get things right, so if something has gone wrong, we need you to tell us. This will help us to improve our standards of service and data protection controls.

   3. How to make a complaint

   You can contact us in writing (by email to the following email address lynda@making-it-happen.co.uk

3. 4. Acknowledging and verifying your complaint

4.1. We will contact you within seven working days acknowledging your complaint.

4.2. We will take reasonable steps to verify the identity of the person making the complaint. This may involve requesting further information or documentation from you. If the complaint is made on behalf of someone else, we will also need to check that the person making the complaint is properly authorised to do so.

4.3. If, having requested additional information, we are not in a position to identify the person making the complaint or we are not satisfied that they have proper authority to make the complaint, we may refuse to deal with it - see section 7.2.1 below.

5. Investigating your complaint

5.1. We will investigate your complaint. This will usually involve:

5.1.1. reviewing your complaint;

5.1.2. locating and reviewing the records we hold about you; 

5.1.3. establishing the relevant facts; and

5.1.4. liaising with individuals who you may have dealt with.

5.2. We may also need to ask you for further information or documents. If so, we will ask you to provide the information within a specific period of time.

5.3. We will update you on the progress of your complaint at appropriate times.

6. Notifying you of the outcome of our investigation

6.1. We will contact you at the end of our investigation to tell you what we have done and what we propose to do to resolve your complaint.

6.2. We usually aim to do this within 30 days of the date of receiving your complaint. However, this time period may be extended where:

6.2.1. we ask you to provide further information to verify your identity or your authority to make the complaint, or in relation to the complaint itself;

6.2.2. your complaint is complex or involves locating and/or reviewing a large volume of information; or

6.2.3. you have made several complaints, which we need to investigate at the same time.

6.3. We will tell you if we need more time to properly investigate your complaint and explain why.

7. Refusing to deal with your complaint or charging a fee

7.1. We prefer to deal with complaints and, preferably, to resolve them. We will not usually charge a fee for handling a complaint.

7.2. We may, however, refuse to deal with a complaint where:

7.2.1. after requesting additional information in accordance with section 4.2, we are not in a position to identify you and/or to verify that you are authorised to make the complaint; or

7.2.2. we have asked for more information in relation to the complaint itself (section 5.2), but you have not provided this within a reasonable time.

7.3. Where we consider the complaint to be manifestly unfounded or excessive, e.g. because you have made the same complaint repeatedly, we may:

7.3.1. refuse to act on the complaint; or

7.3.2. charge a reasonable fee for dealing with the complaint, based on our reasonable administrative costs - we will notify you of the proposed fee in advance of incurring it.

8. What to do if we cannot resolve your complaint

8. 8.1. If you are unhappy with the outcome of your complaint, you can complain to the Information Commissioner’s Office (ICO) or you can seek to take action in the courts.

   8.2. The ICO’s contact details are:

More details on how to complain to the ICO are available on the Complaints page of the ICO’s website. You should usually submit your complaint to the ICO within three months of your last contact with us.