Privacy Policy

Introduction

This is the privacy notice of Rubicon Coaching Ltd with a registered address 37 Evenlode Crescent, Kidlington, Oxon, OX5 1RF It is designed to inform you about how we collect and use your personal data, and is divided into the following sections:

What personal data do we collect?
Special categories of personal data
Legal basis for processing your personal data
Why we collect personal data
Disclosures to third parties
How we protect your personal data
Data Retention
Your Rights in relation to your personal data
How to stop hearing from us
Our copyright statement
Changes to this privacy notice

We take our responsibility for the privacy and security of your personal data very seriously. This privacy notice tells you what to expect when we collect and process your personal data. We will ensure that:

any personal data you provide to us or we receive from other organisations is kept safe and secure;
we will be clear about our reasons for collecting and processing it; and
we will not do anything with it that you wouldn’t reasonably expect.

You have the right to complain to the Information Commissioner’s Office (ICO) if you have a concern about how we process your personal data and you can do this via ICO Concerns.

Our Privacy Notice is set out below. Please read this with care; it describes how we will process your personal data and what we will use it for. If you have any questions or comments, please.

Contacting Us

If you have any enquiries, questions or concerns about the information contained in this privacy notice or more generally about how we collect and use your personal data, you can address these via email to justin@rubiconcoaching.co.uk or by calling us on +34 711077597 or 07833296414.

What personal data do we collect?

There are a number of scenarios where we collect personal data about you. In most instances, these are where you choose to provide personal data to us. We set out the different scenarios below:

Submitting an enquiry

If you submit an enquiry to us, we will collect the following information to process your enquiry:

Your name (including first name and last name)
Your email address
Your contact number
Your enquiry

Event booking

If you book onto one of our events, we will collect the following information to inform you about the event, including times, content and venue:

Your name (first name and last name)
Your contact details (including email address and contact number)

Your employer and job title (if appropriate)
Booking and/or attendance details
Dietary requirements (where refreshment including lunch is provided)
Billing details (if appropriate)
How you prefer us to communicate with you

DISC Personality Profiling

If you elect to undertake a personality profile with the DISC tool, which may form part of your event / training, we will collect the following information to enable us to undertake the service:

Your name (first name and last name)
Your email address

Subscribing to newsletters

If you subscribe to one of our newsletters, we will collect the following information to enable us to provide the requested service to you:

Your name (first name and last name)
Your company
Your email address
Your job title (if applicable)

Customer satisfaction surveys

Sometimes when you submit an enquiry or attend and event, we may use a research organisation to contact you to see whether you will participate in an anonymised Customer Satisfaction Survey; while such organisations act as processors of your personal data on our behalf, we are responsible for your personal data always. If you don’t wish to take part just let us know, email justin@rubiconcoaching.co.uk or by calling us on +340711077597 or 07833296414.

Social Media
Depending on your settings and the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access personal data about you from those accounts or services.

Through our website

Like most websites, we use “cookies” and other tracking technologies to help create a better experience for you when using it. Cookies allow a website to remember you; they are small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields. For further information please see our cookie policy

In addition, the type of device you’re using to access our website and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us and how you can control that.

Special categories of personal data

Data protection law defines special categories of personal data as personal data revealing:

racial or ethnic origin;
political opinions;
religious or philosophical beliefs; or
trade union membership;

These categories also include:

genetic or biometric data processed for identification of individuals; and
data concerning health, sex life or sexual orientation.

We will not ask you for this information, however, you may provide some of this information in your enquiry to us. Where this is the case, we may ask you for your explicit consent to process that special category data before we can answer your enquiry.

You can revoke your consent at any time by emailing us at justin@rubiconcoaching.co.uk or calling us on +34 711077597 or 07833296414; we may still process your personal data, under the basis of a legitimate interest to provide satisfactory resolution of your enquiry that you have made to us, having first removed the special category data. If you still wish us to proceed with your enquiry, with the special category data removed, we will do so.

Legal bases for processing your personal data

The legal bases we will usually rely on are:

Legitimate interest;
Consent.

Legitimate Interests

In most instances, individuals supply us with their personal data with the intention and expectation that we will review their enquiry and provide them with a satisfactory outcome, and we therefore have a legitimate interest in processing their personal data for this purpose. We are not able to deliver our services without processing certain personal data about the individuals who bring enquiries or book onto events.

We only collect the minimal amount of personal data necessary to carry out our role as Rubicon Coaching and we put in place safeguards to ensure that any personal data provided to us is only used for limited purposes.

In certain instances, we will want to ensure that the personal data we hold on individuals is accurate. This is necessary for us when we are processing enquiries and arranging to deliver services or events to ensure we achieve our objectives in a fair way based on credible information. Therefore, we have a legitimate interest in accessing publicly available information found on Companies House, Post Office’s National Change of Address database, whois.com, websites and other reputable sources, to ensure that the records we hold about individuals is accurate.

We also have a duty to provide a safe working environment for our staff. In accordance with our Unacceptable Contact policy (see) we have a legitimate interest to process personal data on individuals who behave in an unacceptable way towards our staff and we will, where we consider necessary and proportionate, restrict such individual’s ability to communicate with us.

You have a right to object to your personal data being used on the basis of legitimate interests. However, in most cases, we will not be able to process your enquiry or deliver services if you exercise this right to object.

Consent

Where we send you marketing emails about our services or you sign up to our newsletters, we will only do so having collected your prior consent. You can withdraw your consent at any time.

Where the DISC personality profile is offered, and you wish to use this service or it forms part of your event or training we will ask for your consent before inviting you to take the survey; this is because the PeopleKeys company are based in the USA.

Why we collect personal data

We collect personal data for the following purposes:

To process your enquiry, including those based on event booking
To request additional information and provide feedback to you about your enquiry or booking
To invite you to take a DISC personality profile assessment
To identify you in relation to requesting additional information or feedback about your enquiry you have made to us
To keep a record of your relationship with us including general communications
To ensure we know how you prefer to be contacted
To provide you with information and access to services that you have requested from us or which we feel may be of interest to you, where you have consented to be contacted for such purposes.
We may also use your personal data to detect and reduce fraud to protect our interests.

Handling your enquiry

We collect, store and process the personal data you supply to us based on legitimate interest (please see further below) to handle, manage and provide you with information and advice about your enquiry that you have voluntarily submitted to us. We may also contact you, to request additional information that we may need about your enquiry.

If you have submitted an enquiry or booked and event or service with us we may invite you to take part in anonymised customer satisfaction surveys; we send such requests based on a legitimate interest in improving our services that we provide to you. If you do not wish to take part, you have the right to opt out of the surveys at any time by contacting us at the address in the ‘Contact Us’ section.

Event Booking

We will process personal data based on legitimate interest when you book onto an event and we will contact you with details of the event, the venue, location and timings. If the event is being held at another location, then we may need to pass limited personal data to the venue to facilitate access to the venue.

Where you decide not to receive any direct marketing communications from us, we will add your name to our marketing suppression list; this will require the retention of a small amount of your personal data (e.g. name and email address) to make sure that your name can be excluded from any future mailings. If you have requested that your personal data be erased, we will retain this small amount of personal data on our suppression list and you will be advised accordingly.

DISC Personality Profiling

We will process limited personal data e.g. name and email address based on your consent when you request or are invited to take a DISC Personality Profile assessment; this is because the company that supply the profile assessment, PeopleKeys are based in the USA; PeopleKeys have undertaken extensive work to ensure that they are compliant with the GDPR. If you have an enquiry about how PeopleKeys handle your personal data you should direct it to compliance@peoplekeys.com; you may also read their privacy policy which can be found at https://peoplekeys.com/policies/privacy-policy

Newsletters

Our e-newsletters are used to inform you of news related to Rubicon Coaching, including events and other useful resources which you may find interesting. If you have subscribed to one of our newsletters we will send them to you on the basis of your consent that you have provided to us by subscribing.

We use a third party provided product, ConstantContact, which is based in the USA, to deliver our newsletters; we gather statistics about the email opening and clicks using standard industry technologies. This helps us monitor and improve our newsletters, providing you with content that we believe is of greater interest to you.

We will not share our newsletter subscription lists with any other organisations. You can remove your name from any of our newsletter subscription lists at any time; you can do this by clicking on ‘unsubscribe’ at the bottom of the email; to see further information on how to do this it is under the section ‘How to stop hearing from us’ below.

Direct Marketing

We will contact you (in accordance with your preferences especially where we are required to obtain your consent to use a marketing channel) with information from Rubicon Coaching about our work (for example, new products that you may find useful and interesting, which may include paid-for services such as our online training and events. We will not share your personal data with other organisations for marketing purposes. Our marketing communications have clear marketing preference questions, and we include information on how to opt out whenever we send you marketing. If you don’t want us to contact you, you can update your preferences at any time; this can be found in our ‘How to stop hearing from us’ section below.

Disclosures to third parties

We reserve the right to disclose your personal data to third parties:

To facilitate and deal with your enquiry;
To process a DISC personality profile assessment;
To process our newsletters and marketing information;
if we are under any legal or regulatory duty to do so; and/or
to protect our rights, property or the safety of us, our personnel, users, visitors or others.

We also use third party service providers as our processors to only hold and use personal data on our behalf to provide us with a service.

We offer paid-for services e.g. event booking, and the payment for these are handled directly by third parties, PayPal and WorldPay. No credit or debit card information is stored by us. We have access to confirmed payment information, which is necessary for us to confirm payment and provide the service for which you have contracted with us to provide.

How we protect your personal data

Your personal data is held on secure systems in the UK and we ensure that there are appropriate technical controls in place to protect your personal data. For example, our online forms are always encrypted. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data when you transmit it to our site.

If a DISC personality profile is undertaken then your personal data will be stored on a secure PeopleKeys server located in the USA; they have taken appropriate steps, including the implementation of proper technical and organisational measures to ensure that your personal data is protected always.

If you subscribe to our newsletter or respond to our marketing materials, then some of your personal data will be stored on a secure ConstantContact server located in the USA; they have taken appropriate steps, including technical and organisational measures to ensure that your personal data is protected always.

If we use external companies to collect or process personal data on our behalf, we undertake checks before we begin work with them to ensure that they have appropriate controls in place to protect your personal data e.g. PeopleKeys, and where appropriate put a contract in place that sets out our expectations and requirements e.g. non-disclosure agreements and expected levels of security; especially regarding how they manage the personal data they collect or have access to.

International Data Transfer

We use a third party processor PeopleKeys to provide the DISC personality profiling service which you may request or be invited to take as part of a product or training you have purchased from us; your data (name and email address) will be held on a secure server in the USA; PeopleKeys have undertaken extensive work to ensure that they are GDPR compliant; you may object to your data being processed and held by PeopleKeys, however this will limited the ability to provide the personality profile. If you have an enquiry about how PeopleKeys handle your personal data you should direct it to compliance@peoplekeys.com; you may also read their privacy policy which can be found at https://peoplekeys.com/policies/privacy-policy

We use a third party processor ConstantContact to provide our marketing and newsletter services, which with your consent you may subscribe to; some of your personal data (name and email address) will be stored and processed on a secure server in the USA; ConstantContact have undertaken extensive work to ensure that they are GDPR compliant; you may object to your data being processed by ConstantContact, however this may limit the services that we are able to provide to you. If you have an enquiry about how ConstantContact handles your data, you should direct it to mailto:privacy@constantcontact.com. You may also wish to read their privacy policy which can be found at https://www.constantcontact.com/legal/privacy-statement

Data retention

When you supply personal data to us to handle your enquiry, we will retain it in line with our data retention policy. Personal data is retained for the purpose and the length of time necessary for which it was collected i.e. to handle the enquiry. We may also be under a legal obligation to retain personal data for a specific period and compliance with our legal obligation may limit the right of an individual to have their personal data erased. Where you exercise your rights under data protection law (e.g. the right to have your personal data erased) and this conflicts with any requirement or need for us to retain personal data you will be advised that this is the case and we will give you the timeframe within which we expect to comply with your right.

Your Rights in relation to your personal data

You have the right to be informed about what personal data is collected and how that is used; this information is contained in this privacy notice in the section ‘What personal data do we collect’.

You have the right to ask us to erase all the personal data that we hold about you, and if it is no longer necessary for the purpose for which you provided it to us (e.g. processing your enquiry) and it is lawful for us to do so, we will erase your personal data and provide you with the outcome of that process.

You have the right to object to processing of your personal data, to stop us processing your personal data or restrict processing of your personal data, and if it’s no longer necessary for the purpose for which you provided it to us (e.g. processing your enquiry or registering you for an event) we will do so. Please contact us if you have any concerns.

You have a right to ask for a copy of the personal data we hold about you, although if the effort to provide such personal data is disproportionate (because of manifestly unfounded or excessive requests) then we may charge for processing these requests.

You have the right to have your personal data rectified, where it is shown to be inaccurate or incomplete; if there are any discrepancies in the personal data we use about you, please let us know and we will correct it.

You have the right to seek portability of your personal data in certain circumstances where we are relying on the lawful bases consent or performance of a contract to process your personal data.

If you want to access your personal data, please send a description of the personal data you want to see to justin@rubiconcoaching.co.uk. We may request proof of identity to ensure that we only provide the personal data to the right person.

If you have any questions or wish to exercise any of your rights please contact justin@rubiconcoaching.co.uk, and for further information see the Information Commissioner’s guidance here (link is external).

You have the right to lodge a complaint with the Information Commissioner’s Office.

How to stop hearing from us

If you decide that the information we provide to you is no longer relevant or interesting to you and you do not wish to hear from us any more, it would be useful for us to understand the reasons; you may change your contact preferences at any time by emailing us at justin@rubiconcoaching.co.uk or by calling us on +34 711077597 or 07833296414.

Our Copyright statement

All material either on this website or provided in hard copy is owned by or licensed to Rubicon Coaching Ltd and is protected by registered and/ or unregistered trademark rights, copyright, or other proprietary rights and laws.

Unless indicated as Crown-owned material or otherwise, the material featured on this website or provided in hard copy may be reproduced free of charge in any format or medium, provided that it is reproduced accurately and not used in a misleading context. The material must be acknowledged as Rubicon Coaching copyright and the title of the document/publication specified.

Any enquiries regarding the material on this website should be addressed by email to justin@rubiconcoaching.co.uk

Changes to this privacy notice

If we decide to change our Privacy Notice, we shall post changes on this webpage and update the relevant sections in our publications where we display how we use your personal data so that you are always aware of how Rubicon Coaching use your personal data. If we make significant changes to our Privacy Notice, we will use reasonable efforts to contact you to notify you of such changes.

This page was last updated on 15^th November 2021