Privacy & Cookie Policy

Introduction

Welcome to our privacy policy. We know how important your personal data is to you, and we promise to treat it with respect.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from), purchase our courses or coaching, or sign up to receive resources from us, and it tells you about your privacy rights and how the law protects you.

It contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so, we are subject to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, and we are responsible as “controller” of that personal information for the purposes of those laws.

By providing us with your data, you warrant to us that you are over 16 years of age.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide when you fill in our contact form, sign up to receive our free resources or newsletter, book a discovery call, or purchase a course, programme or coaching service.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements those other notices and is not intended to override them.

Controller

Sophrology Limited, trading as SophroSport is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact us:

• Full name of legal entity: Sophrology Limited (trading as SophroSport)
• Company registration number: 12894921 (registered in England & Wales)
• Name of person to contact: Deborah Jenkin Jones
• Email address: contact@sophrology.coach
• Postal address: 8 Barrack Lane, Nottingham, Nottinghamshire, NG7 1AN, United Kingdom

How to make a data protection complaint

If you are unhappy with how we have handled your personal data, you have the right to complain to us directly using the contact details above. We will acknowledge your complaint within 30 days and respond without undue delay. Full details are set out in our Data Protection Complaints procedure.

You also 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). However, we care deeply about your data protection rights, and we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications (for example our scheduling, payment or email providers). 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.

The data we collect about you

Personal data 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 collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, last name and title.
• Contact Data includes billing address, email address and telephone number.
• Financial Data includes payment card details (note: card payments are processed securely by our payment provider, Stripe — we do not store full card numbers ourselves).
• Transaction Data includes details about payments to and from you and details of the courses, programmes and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, your purchases or orders, your interests, preferences, feedback and survey responses, and your progress through our courses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

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 it does not directly or indirectly reveal your identity.

Health and wellbeing information

Our services relate to mental performance, breathwork and wellbeing. If, in the course of coaching or correspondence, you choose to share information about your health, stress levels or wellbeing, we will treat that information as a special category of personal data and process it only with your explicit consent and only so far as necessary to provide the service you have requested. You are never required to share such information, and you may ask us to delete it at any time.

How is your personal data collected?

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email, phone or otherwise. This includes personal data you provide when you sign up to receive our free guide or newsletter, create an account, book a discovery call, purchase a course or programme, enter a survey, or give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies and similar technologies — please see the Cookies section below.
• Third parties or publicly available sources. We may receive Technical Data from analytics providers; and Contact, Financial and Transaction Data from providers of technical, payment and hosting services, including Stripe (payments), Kajabi (our website, course-hosting and email platform), and our email/scheduling tools.

How we use your personal 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 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.
• Where you have consented, for example to receive marketing or to share health/wellbeing information. You have the right to withdraw consent at any time by contacting us or by clicking “unsubscribe” in our emails.

Purposes for which we will use your personal data

Purpose / Activity	Type of data	Lawful basis for processing
To register you as a new customer	Identity; Contact	Performance of a contract with you
To process and deliver your order, including managing payments and collecting money owed	Identity; Contact; Financial; Transaction; Marketing and Communications	(a) Performance of a contract with you; (b) Legitimate interests (to recover debts due to us)
To deliver your course, programme or coaching and track your progress	Identity; Contact; Profile; Usage	Performance of a contract with you
To manage our relationship with you (e.g. notifying you of changes to terms or this policy, asking for a review)	Identity; Contact; Profile; Marketing and Communications	(a) Performance of a contract; (b) Legal obligation; (c) Legitimate interests (to keep records updated and improve our services)
To send you our free resources and newsletter where you have signed up	Identity; Contact; Marketing and Communications	Consent
To administer and protect our business and website (troubleshooting, data analysis, testing, maintenance, security, hosting)	Identity; Contact; Technical	(a) Legitimate interests (running our business, IT services, network security, fraud prevention); (b) Legal obligation
To use data analytics to improve our website, services and marketing	Technical; Usage	Legitimate interests (to keep our website relevant, develop our business, inform our marketing)
To make suggestions and recommendations about services that may interest you	Identity; Contact; Technical; Usage; Profile	Legitimate interests (to develop our services and grow our business)

Note that we may process your personal data for more than one lawful ground depending on the specific purpose.

Marketing

Our lawful ground for 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 (PECR), we may send you marketing communications if (i) you have purchased or asked for information about our goods or services, or (ii) you agreed to receive marketing communications, and in each case you have not opted out since.

You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message, or by contacting us. Where you opt out of marketing, this will not apply to personal data provided as a result of a purchase or service experience.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for their own marketing.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible reason. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis.

Cookies

Cookies are small text files placed on your device when you visit a website. We use them to make our site work, to remember your preferences and consent choices, and — only with your consent — to understand how the site is used.

When you first visit our site, you will be shown a cookie banner allowing you to accept or reject non-essential cookies. Essential cookies (needed for the site, your login and checkout to function) are always active because the site cannot work without them. Non-essential cookies (such as analytics) are only set after you have given consent.

You can change your mind at any time by clearing the cookies in your browser, which will cause the banner to appear again. You can also set your browser to refuse all or some cookies, or to alert you when sites set cookies — though if you disable cookies, some parts of this website may not function properly.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes described above:

• External third parties such as our service providers (including Stripe for payments, Kajabi for website/course hosting and email, and our scheduling and analytics providers), professional advisers, HMRC and regulators.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

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 it for specified purposes and in accordance with our instructions.

International transfers

Some of our service providers (for example Stripe and Kajabi) are based outside the United Kingdom, including in the United States. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection by relying on one of the following safeguards:

• transferring to countries that have been deemed to provide an adequate level of protection by the UK government (“adequacy regulations”); or
• using specific contracts approved for use in the UK (the International Data Transfer Agreement, or the EU Standard Contractual Clauses with the UK Addendum) which give personal data the same protection it has in the UK.

If you would like further information, please contact us using the details above.

Data security

We 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. We limit access to your personal data to those who have a genuine business need to know, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, for tax purposes.

If you are not a customer (for example, you signed up for our free guide or newsletter), we shall retain your data until you unsubscribe or ask us to delete it, and in any event we review marketing data periodically.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use it indefinitely without further notice.

Your legal rights

Under data protection laws you have the following rights in relation to your personal data:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of these rights, please contact us using the details at the top of this policy.

You will not normally 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 we may refuse to comply in those circumstances.

Changes to this privacy policy

We may change this privacy policy from time to time. When we do, we will update the “last updated” date at the top and, where appropriate, notify you via our website or by email.