Privacy Policy

Your privacy is important to us, and as such, we’ve sought to write this privacypolicy in plain, everyday language that will hopefully be clear and not full of legal jargon. To that end, we’d ask if you have any concerns, please contact us to discuss.

There are a few different areas of privacy that are covered in this policy:

your privacy when engaging us as your coach
your privacy when using our website (https://journeytogether.net/),
your privacy when contacting or engaging with us.
Who are we?

This is the privacy policy of Journey Together Ltd, a company registered in England and Wales under company number 14566144 with our registered office at Faversham House, Wirral International Business Park, Old Hall Road, Wirral CH26 3NX, UK (“we” or “us”). We are the controller responsible for your personal data.

We comply with “Data Protection Requirements”, which means the General Data Protection Regulation EU 2016/679 (“GDPR”), and any applicable laws, regulations, and other legal requirements relating to (a) privacy, data security, and protection of personal data; and (b) the processing of any personal data, which may include, but are not limited to, the EU law retained version of the GDPR (“UK GDPR”), the Swiss Federal Act on Data Protection 2020, Lei Geral de Protecao de Dados Brazil’s General Data Protection Law), the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act, the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act.

You can make a complaint at any time to the Information Commissioner’s Office ICO, the UK regulator for data protection issues (www.ico.org.uk). We would, we ask that you raise any concerns with us so we can deal with them before you approach the ICO, so please contact us in the first instance by emailing privacy@journeytogether.net

1. What are our obligations as a coach?

As part of our role as your coach, we will be bound by data protection and confidentiality obligations. We are bound by the International Coach Federation (ICF) Code of Ethics which covers matters of our professional behaviour. Confidentiality is paramount. Any information you provide us during our coaching engagement will be used solely for the purposes of providing you with coaching.

As such, we will protect the information you share with us, whether it is considered personal data under the Data Protection Requirements or not. As is explained in your coaching agreement, we will maintain confidentiality except in the following circumstances:

We are compelled to break confidentiality by law (i.e. court order) as coaching isn’t protected in the same way as a doctor-patient relationship
If you tell us that you’re going to do harm to yourself or another
If you tell us you’ve committed or will commit a crime.

As a professional coach, we also engage with a coach supervisor to help us develop further as a coach and for our own self-care. When working with a supervisor, we may discuss aspects of your coaching so we can learn, validate and understand ourselves better as a coach, but no personally identifiable information is shared with the supervisor; the focus is on our coaching rather than any particular client. We will always work with a supervisor who is a member of the ICF and is also bound by the same code of ethics that we are bound by.

During our initial discovery session, we will create a document that will contain details of how we will work together, any goals of coaching and other aspects of our coaching relationship. This will be shared with you via a third-party service currently Dubsado (explained later). We will also keep a copy of this agreement for seven years to comply with any legal and insurance requirements. After such time, it will be destroyed. This document, which we co-create, will also contain details of any other notes, actions or data that we agree to capture and how they will be handled.

During a coaching session, I may take notes of keywords that you use. this helps me reflect back to you and enables me to question through curiosity more effectively. A copy of these notes can be provided if requested but will be deleted after the coaching engagement, usually 6 weeks for security and your privacy.

3. What data may we collect about you?

Personal data/information means any information about an individual that enables them to be identified, but it doesn’t include 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, maiden name, last name, username or
similar identifier, marital status, title, date of birth and gender.

Contact Data

Includes billing address, delivery address, email address and
telephone numbers.

Financial Data

Includes bank account and payment card details.

Transaction Data

Includes details about payments to and from you and other details of products 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, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data

Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

Usage Data

Includes information about how you use our website, products, and services, but as explained below, we’re not able to track users over multiple visits or track individual behaviours

Marketing and Communications Data

Includes your preferences in receiving marketing from our third parties and us and your communication preferences.

Health Data

Includes information about your physical health, mental wellbeing, medical diagnoses, health risk factors, and what your occupation is. These are considered a special category of personal data.

Aggregated Data

Such as statistical or demographic data for any purpose, isn’t considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We don’t automatically collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). We also don’t collect any information about criminal convictions and offences. This is unless you have decided to share this information about yourself while you’re receiving our coaching services, and we will protect this personal data as detailed in this policy.

4. How is your personal data collected?

We will collect personal data about you through our direct interactions, and so it is personal data you choose to share with us. You may give us your Identity and Contact by filling in the contact form on our website or by corresponding or engaging with us by post, phone, email, social media or otherwise. It’s possible we may also receive personal data about you from third parties and public sources, such as Google or Companies House.

5. How do we use your personal data?

We’ll only use your personal data when we can rely on a legitimate (lawful) basis, such as:

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 obligation.

6. For what purposes will we use your personal data?

We have set out below the ways we may use your personal data and which of the legitimate bases we rely on to do so:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To enable you to contact us by completing the form on our website, by phone, email, or social media platform, or to book a coaching session using cal.com	Identity, Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable us to respond to your enquiry and/or scheduling of your contracted coaching sessions)
To register you as a new coaching client	Identity, Contact	(a) Performance of a contract with you
To process and deliver our coaching services to you including: (a) Manage payments, fees, and charges (b) Collect and recover money owed to us	Identity, Contact, Financial, Transaction, Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	Identity, Contact, Profile, Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to register for our mailing list/email marketing	Identity, Contact, Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable us to provide you with the newsletter/blog/email marketing and present you with information, goods or services we consider you will be interested in)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, Contact, Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical, Usage	(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing)

7. What cookies does our website use?

We use Google Analytics to help us understand how visitors use our website. Google Analytics uses cookies to collect information about your visit, such as the pages you view, how long you spend on the site, and how you arrived here. This information is used to improve our website and your experience.

The data collected is aggregated and anonymised where possible, and we do not use it to identify you personally. Google Analytics may set the following cookies: _ga, _gid, and _gat, which help distinguish users and control the rate of requests.

When you first visit our website, you will be prompted to accept or reject cookies. If you choose to reject cookies, Google Analytics will not be activated and no tracking cookies will be stored on your device. You can also change your cookie preferences at any time by revisiting the cookie settings on our website.

8. Who hosts our website?

Layershift LTD host our website, which may also maintain server logs which will be used in the event of any security issues. Layershift also ensures that the traffic to our website is encrypted; however, we also use Cloudflare to help maintain the security of our website. Through our website, we get rudimentary statistics on the geographic area where traffic to our website originates, but we don’t obtain any other personally identifiable information. It’s interesting to look at every now and then out of curiosity, but we don’t use this information for any purpose.

9. What third-party services do we use?

We use a variety of third party services (sub-processors) as part of our business activities and you/we will therefore share your personal data with these subprocessors. It’s important to note that we have no control over the privacy policies/practices of these sub-processors, and we’ve summarised them in the table below to explain why we use them and where you can find more information about them.

As things change, it’s possible that the links or details may become out of date – if that happens, please do let us know and we will update this policy to reflect that.

Sub-processor	What do we use it for?	How do they store/protect your data?	More information
Cal.com	To book coaching calls	Cal.com “strive[s] to use commercially acceptable means” to protect your personal data	Privacy policy
Cloudflare	To maintain the security of our website	Cloudflare has put in place “appropriate physical, technical and administrative measures to safeguard and secure” data	Privacy policy
Google Analytics	To understand how visits use our website	When you visit a website that uses Google services such as Google Analytics, your browser automatically sends information to Google, including the page URL and your IP address. Google uses this information to deliver and improve its services, measure the effectiveness of advertising, protect against fraud, and where applicable, personalise the ads and content you see. If you have ad personalisation turned on, Google may use your browsing behaviour across sites to tailor adverts to you. You can control this through Google’s Ad Settings, review your activity via My Activity, or opt out of Google Analytics entirely by installing the Google Analytics Opt-out Browser Add-on. For full details, see Google’s Privacy Policy.	Privacy policy
FreeAgent	To enable us to manage our accounting	FreeAgent takes security seriously, using industry-standard data collection, storage and processing practices to protect against unauthorised access, alteration or disclosure. Your data is held on secure, encrypted servers with regular backups maintained for up to two years. Any third parties used to support their service are required to meet the same security and confidentiality standards. While FreeAgent does everything reasonable to protect your data, they note that internet transmission cannot be fully guaranteed. You are responsible for keeping your account password confidential. If you cancel your account, your data is deleted after one year, though you can also delete it immediately via the in-app Delete Account option.	Privacy policy
Dubsado	To enable us to manage our client relationships	All information is encrypted using Secure Socket Layer (SSL) technology	Privacy policy
Stripe	To enable us to collect payment	Stripe maintains “maintain organisational, technical and administrative measures designed to protect your personal data”	Privacy policy
Layershift	To enable us to host our website	Our website is hosted by Layershift, who take data security seriously and have implemented appropriate physical, electronic and managerial procedures to protect your information. Your data is stored on secure, password and firewall-protected servers, and all financial transactions are protected by encryption technology. Layershift retains personal data only for as long as necessary — typically six months where no contract was established, or seven years following the end of a contractual relationship — in compliance with GDPR and the UK Data Protection Act 2018. While every precaution is taken, they acknowledge that internet transmission is inherently insecure and cannot be fully guaranteed.	Privacy Policy
Zapier	To enable us to keep an accurate record of data between the systems used	Zapier takes reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in the processing and the nature of the personal data	Privacy Statement
Pork Bun	To purchase our domain name(s).	Porkbun uses industry-standard practices to safeguard your personal data, including encryption, regular security updates, and strict staff confidentiality requirements. Your data is stored on Porkbun’s own servers as well as those of trusted partners, and may be transferred internationally where necessary. Physical, electronic and managerial procedures are in place to prevent unauthorised access, though Porkbun acknowledges that internet transmission cannot be fully guaranteed to be secure. Your data is retained only for as long as needed to provide their services, after which it is deleted upon request, except where contractual, legal or financial record-keeping obligations require otherwise. If you wish to request deletion of your data, you can contact them at privacy@porkbun.com.	Pork Bun
Design Wellness LTD	To enable us to keep our website up to date	Design Wellness LTD takes appropriate technical and organisational measures to protect personal data, including restricted access controls, role-based permissions, strong password policies, multi-factor authentication, SSL/HTTPS encryption, and malware and spam protection. Websites are hosted through Layershift LTD with up to 7-day backup retention, antivirus scanning, and security monitoring, though backups are intended for disaster recovery only. Personal data is retained only as long as necessary for its purpose and is never sold to third parties, though it may be shared with trusted service providers such as Google, Mailchimp, and Cal.com where needed to deliver services. Some providers may process data outside the UK, in which case appropriate safeguards and contractual protections are in place. As with all online services, complete security cannot be guaranteed.	Privacy Statement

Where we share your personal data with those sub-processors, they will be bound by confidentiality and data protection obligations. We do this to ensure your personal data is kept safe and secure.

When else might we disclose your personal data?

In addition to the third parties listed above, we may also disclose your information in the following cases:

If we want to sell our business or our company, we can disclose it to the potential buyer
We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006
We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety, or rights
We can exchange information with others to protect against fraud or credit risks.

How do we secure your personal data?

Data security is of great importance to us, and to protect your data, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the data we collect. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions, 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.

If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further recurrence.

Can we transfer your data internationally?

We may transfer your personal data outside of the European Economic Area EEA) or the UK where we engage third parties to provide services on our behalf (such as those sub-processors listed above). Whenever we transfer your personal data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data
where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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

How long will we retain your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

What are your legal rights?

Under certain circumstances, you have rights under Data Protection Requirements in relation to your personal data:

Request access to your personal data.
Request correction of your personal data.
Request the 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 the rights set out above, please email us at privacy@journeytogether.net

You won’t have to pay a fee to access your personal data (or to exercise any of the other rights), but we can charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we can refuse to comply in these circumstances. We may need you to provide evidence of your identity as a security measure, and we may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month, but it could take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

What if you live in California?

If you are a California resident, we process your personal data in accordance with the CCPA, and you have a right to know when or before we collect your personal data. The CCPA gives you the following rights:

How we collect, use and disclose your personal data

This is explained throughout this policy

Your CCPA rights and choices

As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

Exercising the Right to Know

You can ask that we disclose to you the personal data we’ve collected about you. You also have a right to request additional information about:

Categories of your personal data collected, sold, or disclosed.
The purposes for which we collect or sell your personal data.
The categories of sources of personal data.
The categories of third parties with whom we disclosed this personal information.

This is all set out in this policy. It is important to emphasise that we don’t under any circumstances sell your personal data, nor do we ever plan to.

Exercising the Right to Delete

You can ask that we delete the personal data, subject to certain limitations under applicable law.

Non-Discrimination

We’re not permitted to discriminate against you for exercising your rights under the CCPA.

If you would like to exercise any of these rights, please email us at **privacy@journeytogether.net**. You can choose to do this by designating in writing a power of attorney or an authorised agent who can make these requests on your behalf to the same email. We will need to have proof that you have authorised any other person to make the request on your behalf, and we may need you to verify your identity directly with us.

If you would like us to provide or delete certain bits of personal data we have collected about you, you will need to verify your identity to the degree of certainty required by law. We will then verify your request by asking you to send it from the email address associated with your account or requiring you to provide the information necessary to verify your account.

What about third-party links?

This policy only relates to our website. We might have links on/within our services to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

Will we make changes to this policy?

We can update this policy from time to time as laws change or as our website or services change. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.