Privacy Notice
This is the privacy notice of Stellium. In this document, “we”, “our”, or “us” refer to Stellium. Stellium is a trading name of Stella Maris Coaching Limited which owns and operates our website.
INTRODUCTION
- This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website or cease to deal with us immediately.
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with English data protection law, including that required by the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR) (‘the Data Protection Legislation’).
- The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. These are set out in the Glossary below.
- Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website or in the course of providing products or services to you.
- THE INFORMATION WE PROCESS ABOUT YOU, HOW WE COLLECT IT AND THE BASES ON WHICH WE PROCESS IT
Our Site collects certain information automatically and the details of this information are set out below in Parts 3 and 4.
If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, we are the data controller responsible for such personal data.
The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the UK GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of our Site. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the UK GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes.
Wherever possible, we aim to obtain your express consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at coach@stellium.coach.
However, if you do so, you may not be able to use our website or our services further.
- HOW AND WHERE WE STORE THE INFORMATION WE COLLECT ABOUT YOU
Our Site is hosted by Amazon Web Services (‘AWS’). We have specified the UK as the region in which personal data is processed and accordingly your personal data will be stored in the UK. This means that it will be fully protected under the Data Protection Legislation.
In the event that it is necessary, for example to comply with a legal requirement, for personal data to be transferred to countries outside of the UK our agreement with AWS incorporates the UK Standard Contractual Clauses which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details in Part 9 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE
- COOKIES
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to record your answers to surveys and questionnaires on our site while you complete them
- PERSONAL IDENTIFIERS FROM YOUR BROWSING ACTIVITY
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
- OUR USE OF RE-MARKETING
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.
DISCLOSURE AND SHARING OF YOUR INFORMATION
- INFORMATION WE OBTAIN FROM THIRD PARTIES
Although we do not disclose your personal information to any third party (except as set out below), we may sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
- THIRD PARTY ADVERTISING ON OUR WEBSITE
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties and we advise you to check the privacy policies of any such third parties.
- HOW WE SHARE YOUR PERSONAL INFORMATION
As stated above, we will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way that we have used it, as specified in this Privacy Policy (i.e. to communicate with you).
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
As stated above, we contract with the following third party for hosting and data storage purposes:
Amazon Web Services EMEA SARL, Luxembourg.
If any of your personal data is transferred to a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 2 above.
- ACCESS TO YOUR PERSONAL INFORMATION
At any time you may review or update personally identifiable information that we hold about you.
To obtain a copy of any information that is not provided on our website you may send us a request at coach@stellium.coach.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
- VERIFICATION OF YOUR INFORMATION
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
OTHER MATTERS
- USE OF SITE BY CHILDREN
- We do not sell products or provide services for purchase by children, nor do we market to children.
- If you are under 18, you may use our website only with consent from a parent or guardian.
- ENCRYPTION OF DATA SENT BETWEEN US
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
- HOW YOU CAN COMPLAIN
- If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is coach@stellium.coach.
- If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
- If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
- RETENTION PERIOD FOR PERSONAL DATA
Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times.
- COMPLIANCE WITH THE LAW
Our privacy policy shall be governed by the laws of England and Wales. Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
- REVIEW OF THIS PRIVACY POLICY
We may update this privacy notice from time to time. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us at coach@stellium.com
GLOSSARY
YOUR RIGHTS
Under the Data Protection Legislation you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 9.
- The right to access the personal data we hold about you. Part 9 tells you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 9 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 9 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 9.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.