GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Introduction
Rodetal Ltd (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms of use http://www.rodetal.co.uk/terms-and-conditions/ and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?
Rodetal Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: info@rodetal.co.uk. For all data matters contact Katy R Mahoney on info@rodetal.co.uk.

3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
• To manage our employees;
• To maintain our own accounts and records;
• To inform individuals of news, events or activities;
• You may give us information about you by filling in forms on our site http://www.rodetal.co.uk/coaching/free-coaching-taster/book/ (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order with us by fax/email/phone, participate in discussion boards or other social media
functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
• To provide you with a personalised coaching experience
• To ensure any training we provide for you is tailored to your needs
• To contact you to organise and arrange appointments, meetings and training

4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data
o The personal data you give us may include your name, address, e-mail address and phone numbers, fax number, skype name, financial information, personal description and photograph
 Special categories of data
o Family set-up, friends and family names, education history and achievements, medical history, career history, work status, values and beliefs, life and work goals, research interests

5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
*To keep clients and prospective clients informed of news events and activities – we will do this by asking you to complete a GDPR consent form
(Consent of the data subject;)

*To provide individually tailored coaching, training and consulting
*To fulfil ordered stock / training, coaching / consultancy
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract

*To maintain invoices and contracts for tax purposes
Processing necessary for compliance with a legal obligation

*To keep current and former clients informed of products, business developments
Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject

b) Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
*To provide holistic coaching and tailored training and development, we will ask you to complete a GDPR explicit consent form
Explicit consent of the data subject

*To provide holistic coaching and tailored training and development
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract.

More information on lawful processing can be found on the ICO website.

6. Sharing your personal data
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
· Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you.
· Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
· If Rodetal Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use of our website http://www.rodetal.co.uk/terms-and-conditions/ or terms and conditions of supply of goods and/or services and other agreements; or to protect the rights, property, or safety of Rodetal Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data.

General personal data. We keep this information for the duration of your programme or contract with us and up to 7 years after the end of your programme or contract. We keep this information so we can keep you informed about the services we offer and any changes to our business.

Special categories of personal data. We keep this information for the duration of your programme or contract so we can offer you a holistic coaching and training experience. This data will be kept securely and will be destroyed 12 months after the end of your programme or contract. We keep this data in case you decide that you want to return to your coach for additional support during this period.

8. Providing us with your personal data
We require your personal data as it is a requirement necessary to enter into a contract.

9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

10. Transfer of Data Abroad
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. Rodetal Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored securely. Unfortunately, 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 data transmitted via email or via our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Photography – we will use images of you with your consent across our social media platforms (Facebook, Twitter, LinkedIN, Instagram) and our websites. These platforms are part of the Privacy Shield

11. Automated Decision Making
We do not use any form of automated decision making in our business.

12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on on our privacy policy page  and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Katy R Mahoney on info@rodetal.co.uk.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.