Website Privacy Policy
Welcome.
We respect your privacy and are committed to protecting your personal data. We fully support the ethos of GDPR which is designed to keep the ownership of personal data within the control of individuals. This means you have rights in relation to your personal data, including the right to request access, request correction and request erasure of your personal data.
This privacy notice will inform you as to how we collect and process your personal data when you visit our website and tell you about your privacy rights and how the law protects you.
We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.
This website is not intended for children and we do not knowingly collect data relating to children. By providing us with your data, you warrant to us that you are over 13 years of age.
This version was last updated in January 2020. We may make changes to this notice from time to time by updating this page, so please check back occasionally to ensure that you are happy.
Who we are
We are HUSTLE + hush LTD, a millennial leadership coaching business based in England. If you need it, our company number is 10832476 and our registered office is 13b The Vale, London, England, W3 7SH. All references in this policy to "HUSTLE + hush", "our", "us" or "we" refer to HUSTLE + hush LTD, or our suppliers which provide services to us, as appropriate. All references in this policy to "our website" are a reference to the website owned by HUSTLE + hush LTD at www.hustleandhush.com
HUSTLE + hush LTD is the data controller and as such, we are responsible for your personal data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Full name of legal entity: HUSTLE + hush LTD
Data Privacy Manager: Tee Twyford
Email address: tee@hustleandhush.com
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at tee@hustleandhush.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). We would, however, appreciate the chance to discuss with your concerns and come to a solution with you before you approach the ICO so please do contact us in the first instance.
Third Party Links
This 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
What data do we collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may process the following categories of personal data about you:
· Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
· Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
· User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
· Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
· Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy. We may use User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Social Media adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Sensitive Data
We do not collect any Sensitive Data about you unless you become a client and provide your express consent to share this and for us to store this. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
We may request sensitive data about you in order to deliver an effective service only if you were to become a client. This would include information about coaching or therapy services you may have used in the past in order to inform our work together. It is not compulsory that you provide this.
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How do we collect this data:
We use different methods to collect data from and about you, as set out below:
Direct interactions
We may collect Identity, Contact and Financial Data about you, by you providing the data directly to us (for example by filling in forms or by corresponding with us by post, phone, social media, email or otherwise). This includes personal data you provide when you:
sign up for our products or services;
subscribe to our service or publications;
make an enquiry about our products or services;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
Automated technologies or interactions
We may automatically collect certain Technical Data from you as you use our website by using cookies and similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties
We may receive personal data about you from various third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators, such as Stripe and PayPal.
Publicly available sources.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
How do we use this data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
where you have consented for us to do so;
where we need, to perform the contract we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
where we need to comply with a legal or regulatory obligation.
Marketing & Communications
Our lawful ground of 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 agreed to receive marketing communications and (ii) 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.
When you sign up for any HUSTLE + hush newsletter, we collect your name and email address. If you sign up to be kept informed of availability for our services (such as adding your name to a waitlist or registering your early interest), we collect your name and email address. This data is held in MailerLite.
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.
Disclosures of your Personal Data
We may also share your data with the following categories of third-parties (who may process your data on our behalf or as data controllers in their own right) in order to allow us to provide our services to you. This will include, but may not be limited to, the following:
Processors who we need to use in order to process and fulfill your orders such as payment services providers, warehouses, order packers and delivery companies;
Website hosting companies and other service providers who we need to use in order to run our business;
Credit reference agencies, law enforcement and fraud prevention agencies for the prevention and detection of fraud;
Other processors approved by you such as social media services (if you choose to link your accounts to us).
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers
Government bodies that require us to report processing activities.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
Examples of some of these Third Parties, the purpose of this disclosure, relevant summary of the company’s data policy and a link to their Privacy Policy is below:
Mailer Lite: to send email communications and manage email subscriber lists
Mailerlite’s data storage centre is in Lithuania (European Union)
Eventbrite: to manage and communicate with event attendees
Eventbrite participate in and comply with the EU-U.S. and Swiss-U.S. Privacy Shield Framework
Free Agent: accounting software to manage our company accounts, store client contact information and process invoices
FreeAgent are committed to being fully compliant with GDPR
Squarespace: to manage our website
Squarespace, Inc has certified its compliance to the Privacy Shield.
Google Analytics: to view, analyse and report on activity on our website
Google comply with the EU-US and Swiss-US Privacy Shield Frameworks.
Satori: to book and pay for coaching programs
Satori is incorporated and domiciled in New Zealand, Satori is subject to, and shall comply with its obligations under, the New Zealand Privacy Act 1993 in relation to its use of personal data. Satori also aims to comply with the EU General Data Protection Regulation 2016/679 (“GDPR”)
Thinkific: to host and facilitate our online courses
Where a Data Subject is located in the European Economic Area, that Data Subject’s Personal Data will be processed by Thinkific based in Canada. As part of providing the Services, this Personal Data may be transferred to other regions, including to Canada and the United States. Such transfers will be completed in compliance with relevant Data Protection Legislation.
We may also share your personal data with 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 notice.
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
International Transfers
We are subject to the provisions of the General Data Protection Regulations (GDPR) that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
How do we store your data?
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. 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.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
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.
I am required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years. After this point your information will be kept until you notify me otherwise; you have the right to be forgotten so contact me if you would like your data to be destroyed.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at tee@hustleandhush.com
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 or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Cookies
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