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GDPR Policy

At PUSH we believe in the importance of looking after your information and ensuring you have maximum control over it, we’ve summarised the key points from within our Privacy Policy and Terms of Use that relate to GDPR, although we suggest reading all documents in full.

Definitions

“The Client” — The individual attending a coaching session within “The Business”.

“The Business” — The employer providing PUSH Coaching as a benefit to it’s employees (“Clients”)

“The PUSH Coach” — The Coach providing Coaching Services via PUSH.

“PUSH” — The organisation in relationship with The Business to provide the PUSH Coach and their Coaching Services.

Nature of the relationship

PUSH (PUSH Mind & Body Ltd) holds a relationship with The Business to provide PUSH Coaching to it’s staff.

PUSH has a team of PUSH Coaches who are self-employed contractors with PUSH who deliver PUSH Coaching within The Business.

Via PUSH’s relationship with The Business, PUSH Coaches offer coaching services to staff members (The Clients)

Summary

  • Nobody in The Business will have access to the personal information shared by Clients with PUSH and The Coach.

  • Discussions with PUSH Coaches (i.e. during a coaching session) are completely confidential and nothing is shared with PUSH or The Business.

  • PUSH holds your personal data in form of your name and e-mail address, the details shared when making a booking to see a PUSH Coach.

  • PUSH Coaches keep brief, high-level records of your sessions which include your name and a sentence on the content discussed in your session (see Terms of Use for examples of notes).

  • PUSH will share anonymised, cleaned, quantative data with The Business around overall PUSH usage.

  • PUSH Coaches may share your personal data with their regulatory bodies for their continuing professional development and coaching credentials.

  • We ask the individual to tick a box consenting to use PUSH, only if they have read, understood and agree with the terms of use.

  • PUSH Coaches may disclose content shared in coaching discussions for their continued professional development, such as supervision. However, they never disclose any identifying personal information.

  • PUSH’s contract with PUSH Coaches includes that they keep their physical notepads safe and stored away and any digital records sufficiently protected.

  • PUSH holds your personal data for correspondence and appointment scheduling only.

  • PUSH’s online booking provider is HubSpot, they store your data. You can view their Data Processing Policy here — https://legal.hubspot.com/dpa

  • If you’d like to access, amend or delete any information please contact enquiries@pushmindandbody.com

  • If at any time you are concerned or have questions about how we might be handling Your data, please reach out to our Data Protection Officer at julia@pushmindandbody.com

IF YOU DO NOT ACCEPT AND AGREE WITH OUR PRIVACY POLICY THEN YOU MUST NOT USE PUSH OR THE SERVICE.

PUSH Mind & Body Ltd (“PUSH”, “We”, “Us” and “Our”) remain fully committed to the protection of our users privacy at all times. The information contained in this policy has been published to inform you of the way in which any Personal Data (as defined below) you provide us with or we collect from you will be used. Please read this information carefully in order to fully understand how we treat such Personal Data.

Please read this policy in conjunction with the Terms of Use.

When you book a PUSH Session, you agree to our privacy policy and you consent to our collection, storage, use and disclosure of your Personal Data for the purpose of making PUSH and/or the Service available to you, in accordance with this policy.

Any terms not defined in this policy shall have the same meanings given to them in the Terms of Use or Privacy Policy.

We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).

For the purpose of Data Protection Laws, in relation to any Personal Data you submit to PUSH, you will be the data controller and we will be a data processor of such Personal Data.

Personal data we may obtain from you

“ Personal Data ” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We may obtain and use the following Personal Data about you:

  • Any correspondence we have with you should you contact us

  • Data you provide when you register to become a user of PUSH

  • Data and information you share with your PUSH Coach (See Terms of Use and Privacy Policy on Coaching Confidentiality)

  • Details of your frequency of use of PUSH

Where we store personal data

The Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be moved to and stored at a destination within the European Economic Area (“EEA”). Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the provision of support services and the delivery of your and your Users’ request(s) for us to provide the Service.

Without limiting the foregoing, you agree that Personal Data we obtain from you may be processed by our service providers based in countries outside of the EEA for the purposes of providing you with the Service. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA; however where such transfers of data occur, we will take steps to prevent the transfer of Personal Data without adequate safeguards being put in place and will ensure that your and your Users’ Personal Data collected in the EEA and transferred internationally is afforded the same level of protection as it would be inside the EEA. For further information on, or a copy of, the adequate safeguards adopted by us for the international transfer of Personal Data, please email enquiries@pushmindandbody.com

  • We store the Personal Data you provide us within the PUSH Online Booking System that is currently hosted by HubSpot.

  • You can view their Data Processing Policy here — https://legal.hubspot.com/dpa

  • Coaches may store your personal data in their own online physical and digital files.

As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your or your Users’ data transmitted to our Website or Service; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your and your Users’ data is executed as securely as possible, and upon receipt of your/their data we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorised access.

How we protect your personal data

We will take reasonable steps to maintain appropriate technical and organisational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data.

How we use your personal data

The Personal Data we hold about you may be used in any of the following ways:

  • To allow you to book PUSH meetings or calls.

  • To enable Coaches to claim accreditation and credentials for the coaching they do with you.

  • For coaches to confidentially and anonymously share and receive support for their coaching in supervision and training.

  • To evaluate the performance and professional integrity of a coach.

  • For research and analytics purposes (for example, to improve the quality of the Service).

  • To quantitively share usage of PUSH with your business, with all data anonymised and cleaned of personal information.

  • To comply with applicable Laws, court orders, government and law enforcement agencies’ requests.

  • To send you further information about our services for which we think you may have an interest. This information will be supplied only where you have given consent.

  • To send you further information about our services based on a request we have received from you.

  • To fulfill the obligations we have in relation to any contracts we have in place with you (including, without limitation, the Terms of Use).

  • To provide you with notification about any changes to the Service. We will never supply your or your Users’ Personal Data to third parties unless under the conditions stated beneath this section of our privacy

Disclosure of your information

Disclosure of your and your Personal Data to third parties will only occur in any of the following events:

  • We sell or purchase any business or assets. In such case, we may authorise the disclosure of your personal data to prospective sellers or buyers of such business or assets.

  • All or the substantial majority of our assets are sold to a third party. In such case, your personal data may be one of the transferred assets.

  • The Coach needs to submit the number of Coaching hours they have done with their regulatory body for their accreditation and professional development.

  • The Coach discloses anonymous information about coaching discussions in their own supervision, training, mentoring or continued professional development.

  • PUSH evaluates whether the Coach is keeping adequate records of sessions.

  • We are required to disclose your or your Users’ personal data in order to fulfil any legal obligation, to enforce our Terms of Use, or to protect the property, rights or safety of PUSH, users of our services or others. In such case, information may be exchanged with third party companies or organisations in order to prevent fraud or reduce credit risk. You acknowledge and agree that we may also disclose Personal Data (including, without limitation, Client Data) with: (i) our service providers involved in the provision, distribution, delivery and support of the Service, including the storage of any Client Data; (ii) fraud prevention agencies; (iii) law enforcement agencies, regulators, courts and public authorities; and (iv) emergency services.

Our service providers have to follow our express instructions when processing the Personal Data you or your Users provide and must have in place appropriate technical and organisational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.

Your rights

You retain the right to request us to refrain from processing your data for the purposes of marketing. To exercise such right, you may reply to any information we send you, detailing your request that we refrain from sending any marketing correspondence, or you can exercise this same right by contacting us electronically via email at enquiries@pushmindandbody.com

If at any time we intend to use your data for such marketing purposes however, it is standard practice for us to make you aware in advance of collecting such data.

We may at times provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates or advertisers. These websites have separate privacy policies, and we therefore cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites’ individual privacy policies before submitting any personal data.

You retain at all times the right to access / amend / delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request in accordance with Data Protection Laws, by emailing enquiries@pushmindandbody.com.

You may also lodge a complaint with the UK data protection regulator, the Information Commissioner should you be dissatisfied with the way that we handle your Personal Data.

How long we keep personal data for

We will keep your and your Users’ Personal Data for the duration of the Service and in accordance with your instructions or for such periods as may be required by law.

Changes to our privacy policy

If at any time we make a change to this policy, we will update this page to reflect such change. Where we feel it appropriate, we will notify you by email, however, we recommend you review this page periodically to ensure you remain happy with the latest version.

Questions, comments and getting in touch

We welcome any questions or comments in relation to this privacy policy, and advise you to send any such communication to enquiries@pushmindandbody.com.

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