Dale Culliford | Sound in Body

PRIVACY NOTICE

I respect your privacy and am committed to protecting your personal data.

This Privacy Policy explains how I handle and treat your data when you:

register or visit my website at https://www.soundinbody.co.uk/, or any associated sites or pages (the “Site”); or
engage with me to use the products or services that I provide (my “Services”).

This Privacy Policy is intended to assist you in making informed decisions when choosing to use the Site and my Services and/or to understand how your personal information may be processed by me as a result of me providing my Services to third parties. Please take a moment to read and understand it.

This Privacy Policy also explains my approach to any personal information which I have obtained about you from a third party and the purposes for which I process your personal information. It also sets out your rights in respect of my processing of your personal information.

Who I am

My name is Dale Culliford. I am a sole trader.

I am the data controller responsible for your personal data.

How I collect personal data

Directly: I may collect personal information from you in the course of my business, including through the use of my Site, when you contact or request information from me, or when you engage my Services.
Automatically: I may collect personal information from you by monitoring your use of, and interactions with, my Site and other electronic services and any electronic marketing I may send you.
Indirectly: I may also collect your personal data from third parties.
Public Data: I may also collect publicly available information, including public registers, social media platforms and electronic data sources.

The types of personal information I collect

The type of information I collect depends on my relationship to you and the context in which I obtain and process your personal data. A non-exhaustive list of the data I may collect and process is as follows:

contact information such as name, job title, addresses (postal and email), telephone and fax numbers and your gender;
identification information including passport information, other photographic identification and your date of birth;
payment information, including bank account details;
information you provide to me for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs;
other information relevant to the provision of the Services.

If you are an individual whose personal information is processed by me as a result of providing the Services to others (including individual clients and corporate clients) I will process a variety of different personal information depending on the Services provided.

The basis on which I process your personal information

I will only use your personal data when the law allows me to. The legal grounds I rely on for processing your data depend upon the nature of my relationship with you and the context of processing and are as follows:

Contract Performance: where the processing is necessary for the performance of a contract with you, or to take steps prior to entering into a contract with you.
Legal Obligation: where the processing is necessary for compliance with mandatory legal obligations to which I am subject; or
Legitimate Interests: where the processing is necessary for the purposes of my legitimate business interests (or those of a third party), except where those interests are overridden by the interests, rights or freedoms of affected individuals.
Consent: Where you have given your explicit consent to the processing.

What I do with your personal information

I use the personal information I collect for the following purposes:

a. To provide my services to you and to conduct my business

To administer and perform my Services, including to carry out my obligations arising from any agreements entered into between you and me, to contact you by email, phone, fax, social media platform or post.

Legal Grounds: Contract Performance; Legitimate Interests (to enable me to perform my obligations and provide services to you), consent (where given).

b. To maintain and develop my relationship with you where you are a client or a prospective client

To provide you with details of my services, updates, and invites to workshops, courses and other events.

Legal grounds: Contract Performance, Legitimate Interests (to allow me to develop my business with you), Consent (where given).

c. To contact you in the course of providing Services to my clients

To contact you by email, phone, fax, social media platform or post.

Legal grounds: Contract Performance, Legitimate Interests, Consent (where given)

d. To comply with my legal or regulatory obligations

Legal grounds: Contract Performance, Legal Obligation, Legitimate Interests.

e. To establish, exercise or defend legal rights

Legal grounds: Legitimate Interests (to protect my business)

f. To ensure that I am paid

To recover payments due to me and to enforce such recovery though engaging debt recovery agencies or taking legal action including commencing and carrying out court or other legal proceedings.

Legal grounds: Contract Performance, Legitimate Interests (to ensure that I am paid for my services).

g. To inform you of changes

To notify you about changes to my Services, terms of business or privacy notice etc.

Legal grounds: Legitimate Interests (to ensure that I can notify you about changes to my business)

h. To re-organise or make changes to my business

To transfer your personal data in the event of a reorganisation (for example incorporation or conversion to an LLP) of my business

Legal grounds: Legitimate Interests (to allow me to make changes to my business)

Who I share your personal information with

In providing my services I may provide your personal information with the following categories of third parties:

any professional whom I engage or sub-contract in the course of providing the Services from time to time;
my professional advisors such as lawyers and accountants, bankers, business advisors and insurers;
postal or courier providers;
any successors to my business, or as part of a merger of my business; and
to other third parties when required to do so by law or other regulatory authority or where I am under a duty to do so to comply with legal or professional obligations such as compliance with anti-money laundering requirements and counter-terrorism measures;

How long I keep your personal information

I will only retain your personal information for as long as is reasonably necessary for the purpose for which it was obtained and any other permitted linked purpose (for example satisfying any legal, regulatory, tax, accounting or reporting requirements).

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

I will typically retain your information for ten years, however I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of a dispute in respect of my relationship with you.

How I protect your data

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 my instructions and they are subject to a duty of confidentiality.

I will notify you and any applicable regulator of a breach where I am legally required to do so.

Where your personal information will be processed

Most of my data processing takes place within the EEA. However, I may from time to time transfer your data to one or more of my external third parties based outside of the EEA.

Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is in place:

we may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
where I use certain service providers, I may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
where I use providers based in the USA, I may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the USA.

Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the EEA.

How to access your information and your other rights

This section sets out the rights that you have in connection with my processing of your personal information. You will not have to pay a fee to exercise any of the rights detailed in this section, however I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

Where you are an existing client, depending on the nature and extent of your request, I may be unable to continue acting for you. In this event, you will remain liable for my fees and disbursements incurred before the request was made.

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.

Right of Access

You have the right to request details of personal information which I hold about you. If you would like a copy of your personal information, please write to us. If you require additional copies of any data I hold about you then I may need to charge a reasonable fee.

Right to Rectification

You have the right to ask me to correct any incorrect information I hold about you, or to complete any incomplete information. If you think that any information I have about you is incorrect, incomplete or needs updating then please contact us.

Right to Erasure

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.

Right to Restrict Processing

You have the right to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data’s accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) 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; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

Right to Data Portability

You have the right, in certain circumstances, to obtain personal information you’ve provided me with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask me to transfer this to a third party of your choice.

Right to Object

Where I am relying on a Legitimate Interest (or those of a third party) as my lawful ground for processing your personal data, and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to object to his processing. 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.

Right to Withdraw Consent

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.

Right to Complain

In addition to the above you have the right to be notified of a personal data breach if it results in a high risk to your rights and freedoms.

Contact and Further Information

If you have any queries or requests regarding this notice, or my practices concerning your personal data, please contact me by email: dalecello@hotmail.co.uk, or telephone on +44 (0)7773731390.

I will take reasonable steps to resolve or answer concerns as soon as possible and normally within 30 days.

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.