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Privacy Policy

Welcome to www.yoursoberpath.co.uk. Data protection and data security when using our website are very important to us. We would therefore like to inform you which of your Personal Data we collect when you visit our website and for what purposes it is used.

Who is responsible?

The person responsible in the sense of the UK`s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”) is Your Sober Path  (“Your Sober Path”, “we”, “us”, or “our”). Please direct any questions you may have to us using our Contact Form.

Principles of data processing

  a.  Personal data

Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behaviour.

  b.  What is Special Category Data?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing

  c.  Processing

The processing of Personal Data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis.

  d.  Legal basis

In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfilment of a contract / pre-contractual measures, iii) the data is necessary for the fulfilment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

  e.  Retention

Processed Personal Data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations.

Data we collect

  a.  Provision and use of the website

When you call up and use our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.

  b.  Hosting

The hosting service used by us for the purpose of operating our website is Wix.com LTD. In doing so, Wix processes inventory data, contact data, content data, usage data, meta data and communication data of interested parties and visitors of our website and services, on the basis of our legitimate interests.

  c.  Content Management System

We also use the Content Management System (CMS) of Wix to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to Wix. This represents a legitimate interest.

  d.  Google reCAPTCHA

We also use Google's reCAPTCHA from Google to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as you enter our website. The legal basis for using reCAPTCHA is our legitimate interest.

  e.  Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s counterpart the Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

  f.  Cookie consent

Our website uses a cookie consent management tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest.

 

  g.  Contacting us

We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.

 

  h.  Contractual Services

We process the Personal Data involved when you enter into a contract with us in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

  i.  When using our services

When you are using our services you can provide a variety of data. Doing so we process various data within the framework of the provision of our services and for the initiation and processing of the existing contractual relationship between you and me. Thus, if you have commissioned us to provide a service, we process your personal data and all information that is necessary in the context of fulfilling the services, exclusively for the purpose of processing and handling the contractual relationship.

Further and through the performance of our services we may collect Special Category data. Special category data is personal data that needs more protection because it is sensitive. This may include personal data revealing racial or ethnic origin, religious or philosophical beliefs, genetic data, biometric data, or data concerning health. If the processing of Special Category data during the course of the provision of services becomes necessary, we need to obtain the data subject's consent.

In this context, consent means any freely given indication of the data subject's wishes for the specific case in an informed and unambiguous manner, in the form of a declaration or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

Accordingly, and when you use our services, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfil our legal obligations and the consent of the relevant service user.

  j.  Payment Data

If you make a purchase your payment will be processed via our payment service provider Stripe. Payment data will solely be processed through Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract

  k.  Virtual Coaching Sessions

We also use Zoom to conduct our online meetings and coaching sessions. When using Zoom various types of data are processed. The scope of the data depends on the information you provide before or during the online meeting. The processing bases are your consent as well as our legitimate interest.

  l.  Discovery Call

For booking a Meeting in an easy and convenient way, we use Calendly. Your data from the form will be transferred to our appointment account at Calendly after you press the "Book appointment" button. You will then receive a confirmation email with a link to the event. Your data will be kept at Calendly until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. Calendly undertakes not to pass on your data to third parties. The legal basis is your consent as well as our legitimate interest.

  m.  Leave A Reply

When you leave comments in our blog, your IP addresses, your Name, and e-mail address are stored on the basis of our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts. Further, you are able to sign up via your email or using the convenience login and sign up from Google and Facebook. For Google or Facebook log in and sign up, you will be asked to provide your basic information (i.e., name, email address, and display picture) linked to your account. When registering via Google`s or Facebook`s connect function, you agree to the relevant terms and conditions and consent to certain data from your respective profile being transferred to us.

  n.  Testimonials

Within the Testimonial section, we may display certain Personal Data, share certain details, knowledge and insights. When you approve and submit your Testimonial to us your consent is obtained, and you have choices about the information in your Testimonial.  The storage of Testimonials is based on your consent.

  o.  Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

Data Security

We undertake to protect your privacy and to treat your Personal Data confidentiality. In order to prevent manipulation or loss or misuse of your data stored with us, we take extensive technical and organisational security precautions which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS).


However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. We have no technical influence on this. It is the user's responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

How we may share your Personal Data

We may share your Personal Data with our Business Partners for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customising our services to better meet your needs. We share your Personal Data only with Business Partners who agree to protect and use your Personal Data solely for the purposes specified by us.

 

We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests. Except as described above of which you will be informed in advance, we will not disclose your Personal Data.

Marketing

Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

If you have consented to receive our newsletter, we will use your email address and, if applicable, your name to send you information about us, our promotions, and news. You can revoke your consent to receive our newsletter at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data.

Social Media

General

We are present on social media on the basis of our legitimate interest (currently Facebook, Instagram and LinkedIn). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

Market research and advertising

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behaviour and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.

 

When you visit our profiles and interact with us and others

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

Advertising

We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website - for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.

We also analyse this data to evaluate the relevance of the advertisements and to optimise the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website. The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.

What we do not do

  • We do not request Personal Data from minors and children;

  • We do not use Automated decision-making including profiling; and

  • We do not sell your Personal Data.

Privacy rights

Under the DPA and the GDPR, you can exercise the following rights:

  • Right to information

  • Right to rectification

  • Right to deletion

  • Right to data portability

  • Right of objection

  • Right to withdraw consent

  • Right to complain to a supervisory authority

  • Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact me.

Updating your information and withdrawing your consent

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or want to withdraw any consents you have given us, please contact us.

Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority

The supervisory authority for Data Protection in the UK is The Information Commissioner's Office (ICO) (www.ico.org.uk). However, we would appreciate the opportunity to address your concerns before you contact the ICO.

Validity and questions

This Privacy Policy was last updated on Sunday, 21st of January, 2024, and is the current and valid version. However, from time to time changes or a revision to this policy may be necessary. If you have any questions about this policy or our data protection practices, please contact us using our Contact Form.

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