Terminology
| Event | Any training course, coaching session or other activity that the client wishes to carry out |
| Client | The person undertaking an event delivered by Steeply Inclined |
| We | Adrian Wilson or anyone working on my behalf delivering Steeply Inclined events |
Scope
This document provides you with information about how we are handling, or are intending to handle, your personal information.
If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to us.
About Us
We are committed to protecting and respecting your privacy and complying with the principles of applicable data protection laws. This notice sets out the basis on which any personal data we collect from you, or that you provide, will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how it will be treated.
The data controller of the personal data referred to in this policy is Adrian Wilson, 23 Hamsterley Drive, Newcastle upon Tyne, Tyne & Wear, NE12 6TB.
Collection of Personal Data
We may collect and/or create or otherwise obtain and process the following data about you:
Information about you that you provide by filling in forms while registering for events via steeplyinclined.co.uk;
Information from your social media accounts, but only where you have given us permission to use it. For example, posts, pictures and video footage you share on sites such as Facebook and Instagram;
We may also ask you for information when you report a problem or make a complaint and, if you contact us, we may keep a record of that correspondence;
We may also ask you to complete optional surveys that we use for research purposes and to provide you with a more relevant client experience;
Information about emails and other communications we have sent to you and your interaction with them;
Information from third parties where you consent to those other organisations sharing information they hold on you with us, and where those other organisations lawfully share your information with us.
Uses Made of Your Information and the Basis of Processing
We will use your personal information to:
Ensure services provided are suitable and that risks are mitigated as far as possible;
Ensure that any specific medical or personal requirements are taken into account prior to and during service delivery;
Provide you with information, products or services that you request from us or which we feel may interest you, where legally entitled to do so; or
Notify you about changes to services.
We will not use any of the personal information we collect from you to make automated business decisions.
The legal basis on which we collect and process the personal data described above depends on the personal information concerned and the specific context in which we collect it.
However, we will only use your personal information where we:
Have your consent to do so;
Need the personal data to perform a contract with you;
Need to process your personal information for our legitimate interests and only where our legitimate interests are not overridden by your data protection interests or fundamental rights and freedoms;
Have a legal obligation to collect personal information from you; or
Need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time, and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information).
Information Security
We will take all steps reasonably necessary including policies, procedures and security features to ensure that your data is treated securely and protected from unauthorised and unlawful access and/or use, and in accordance with this notice. Unfortunately, the transmission of information via the internet is not completely secure and, although we will do our best to protect your personal data transmitted to us via the internet, we cannot guarantee the security of your data transmitted to our website from your device. Any transmission is at your own risk.
Where any payments are being collected on our behalf, we require our payment providers to be compliant with the Payment Card Industry’s Data Security standards (PCI-DSS).
Recipients of Personal Data
We will share information about you with some of our suppliers who process data on our behalf to help us to provide services to you. We undertake this data sharing on the basis of our legitimate interests.
Categories of Organisation and Purpose
Database hosting companies – to host our digital platforms to enable clients to interact with us;
Email broadcasting companies – to send emails to our clients;
SMS broadcasting companies – to send SMS and text messages to our clients;
Assistances and subcontractors – to enable delivery of appropriate services mitigating any risks as far as possible.
International Transfer of Personal Data
The information we collect may be transferred to organisations who may store and use such data at premises in other countries. Where we allow an organisation to process your personal information outside of the European Economic Area, we will ensure that we create and maintain appropriate safeguards with those organisations so that your personal information is subject to the same standards and protections as when we are processing your personal information inside the European Economic Area.
Data Retention Period
We will hold information about you in our data systems only for as long as we need it for the purpose for which we collected it, which is as follows:
As long as you continue to use our services (including attending events or engaging with emails) we will retain and process information about you. In such cases, you will be considered to be an ‘active’ client. If you have not been ‘active’ as a client for a period of three years, we will anonymise or delete any personal data relating to you;
Personal data linked to the processing of insurance claims, subject access requests, disputes, safeguarding investigations, disciplinary or police matters will only be kept for as long as is necessary for those purposes, as each is applicable.
The Data Subject’s Rights
Data protection laws grant you, as a Data Subject, certain ‘information rights’, which are summarised below:
Right of access – You have the right to obtain a copy of information we hold about you;
Right of rectification or erasure – If you feel that any data that we hold about you is inaccurate, you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Please note that we may be entitled to retain your personal data despite your request, for example if we are under a separate legal obligation to retain it. Your right of rectification and erasure extends to anyone we have disclosed your personal information to and we will take all reasonable steps to inform those with whom we have shared their data about your request for erasure;
Right to restriction of processing – You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we do not need to hold your data any longer but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data;
Right to Portability – You have a right to receive any personal data that you have provided to us in order to transfer it onto another data controller where the processing is based on consent and is carried out by automated means. This is called a data portability request;
Right to Object – You have a right to object to our processing your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling;
Right to Withdraw Consent – You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent;
Right of Complaint – You also have the right to lodge a complaint about any aspect of how we are handling your data with the UK Information Commissioner’s Office, which can be contacted at www.ico.org.uk;
Right to Opt-out of Marketing Communications – You have the right to opt-out of marketing communications we send to you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below.
Changes to our Privacy Policy
Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by date-stamped communication.
How to Contact Us
If you wish to contact us about your personal data or exercise any of the rights described above please contact: steeplyinclined@gmail.com