1. Introduction and Summary

This policy specifically relates to Juliette Lee Ltd (“we” or “us”) only and details the types of personal data we may collect about you when you interact or register with us. Furthermore, this policy explains how we store and handle that data whilst maintaining its safety. There is a substantial amount of information contained within this policy, but it is your legal right to be fully informed. Therefore, by reading this document in full, you should receive the detail required to understand what Juliette Lee Ltd does with your data and how we maintain contact with you using the data you provide. This document also explains how ‘cookies’ may influence your user-experience via our website and third-party booking system whilst also detailing how you can opt-out of our direct marketing.

EU GDPR – Data Protection Regulation 2018 The introduction of the new GDPR (General Data Protection Regulation 2018) in May 2018 outlines new rules for the way businesses collect data. To use our services, we must collect, use and hold some of your personal and contact data. With this new regulation, you can change the way we use your data or ‘opt-out’ of certain items at any time by emailing us: juliette@juliettelee.co.uk. Please note that if you choose to opt-out of certain items, you may be unable to access some or all of our services. For the ease of understanding this document, ‘data’, refers to any personal details we collect from you or in relation to your business. To ensure we are always compliant, we may need to update this Privacy Policy at any time. Any significant changes likely to influence you as a customer will be communicated via email. You can view this Privacy Policy at any time at www.juliettelee.co.uk

2. Juliette Lee

Juliette Lee Ltd, trading as Juliette Lee is an executive coach, facilitator and speaker based in Scotland. Juliette Lee Ltd is registered in England and Wales No: 5724342. Registered address: Enterprise House, Valley Street North, Darlington, DL1 1GY

3. The relevant lawful bases for processing your data

Data protection law outlines a number of reasons for which a company may collect and process your data. Juliette Lee Ltd has identified the lawful bases for processing your data as the following: Consent In certain circumstances, we can collect and process the data you provide us with your positive consent. For example, when you ‘tick’ a box to receive our newsletters. Contractual obligation In some cases, we need your personal data in order to comply with our contractual obligation to you. For example, if you purchase a coaching package from us, we require your contact details including home or registered business address and phone number. Legal compliance If the law requires us to, we may need to collect and process your data. For example, we may need to pass on your data to the police if by chance, you are involved in or subject to criminal activity. Legitimate interests In specific situations, we require your data to pursue our legitimate interests in a way that may reasonably be expected, to be able to run our business. Such action does not materially impact on your rights, freedom or interests. For example, we may use your email address to contact you with specific information relating to your business and/ or our services which you have purchased, important notices or changes and any other relevant information that is fundamental in our contractual obligation to you as our customer.

4. When do we collect your data?

5. What sort of data do we collect?

We use several third-party companies to support our business.

Please note that all third-party companies we use have their own and separate Privacy Policies, which can be viewed via the links below – beware when using external sites:

If you contact Juliette Lee Ltd by email, we will access your email address and may also request additional information such as your registered business or home address, phone number and the name and nature of your business, as well as social media handles for yourself and/or your business.

If you register for a Discovery Call or book a coaching package, we will ask you for:

If you access ‘Zoom’ in order to take part in a Discovery Call or coaching session, you may be required to issue your personal data through their secure site.

If you get in touch with us for any other reason, specifically through our website ‘contact form’, we collect the following personal data through our website host, Perch:

6. How and why do we use your data?

We only collect the data concerning you that is absolutely essential. It is important, given the nature of the services we offer, that we collect reasonable contact details from customers to be able to offer accurate and appropriate business advice. To meet our contractual obligation to you as a customer, we will use your email address and mobile number in order to:

We will only use your email address to send you marketing and/ or promotional material if we have your consent to do so. We sometimes use Mailchimp to send out email marketing campaigns. You can change how we use your data at any time and can request that we do so by emailing juliette@juliettelee.co.uk

Please be aware that some changes may result in us not being able to provide you with the services you have originally requested and may therefore result in request refusal. For example, if you are a current customer of Juliette Lee Ltd and you ask us to remove your email address and telephone number from our records we will then be unable to contact you about booking changes, new policy notices, outstanding balances and other important information relating to your bookings. In scenarios like this and depending on your individual situation, we may reasonably refuse any request you make.

Information you provide will be used for the purposes of booking in calls (name, email address and phone number). If you do not provide us with certain details, we are unable to fulfil our contractual obligations to you. For example, if you fail to provide your email address, we are unable to contact you via ‘Zoom’ to undertake our calls, meaning we are unable to fulfil our contractual obligation to you. If required by law, we may use your data and share this with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law, we are legally obliged to provide access to the personal data we have collected about you.

7. Direct marketing and opt-out

Only Juliette Lee of Juliette Lee Ltd, or duly authorised sub-contracted staff, can access or view your personal data and only under legitimate business interests. Juliette Lee Ltd will only ever contact you with relevant and honest marketing material if we have your consent to do so. If we do have your consent, we may periodically contact you via email or text to offer you our services in which we feel you would be genuinely interested in. To support our marketing efforts, we may also use Mailchimp, Facebook, LinkedIn, Pinterest and Instagram. To be able to use this service, we must upload your email address to the Mailchimp system for us to be able send out marketing campaigns or similar.

You will not receive marketing or promotional emails through Mailchimp if we do not have your consent and you can opt-out at any time after consenting. For example, if you are a current customer and we launch a new offering that we feel you would be interested in, we may contact you to see if you would like to know more about the service. This includes courses, packages and events.

We never share your data with any other third party other than those mentioned above under our contractual obligation to you.

If you no longer wish to receive direct marketing through email, text or Mailchimp regarding Juliette Lee Ltd offerings that may be of interest to you, then you can request to opt-out by either:

Please be aware that by opting-out, we may be unable to offer some of our services to you and you may miss out on some of our offerings. For example, if you ask us to remove you from the email/text mailing list(s), you will only receive information that is specific to your current package and you will not receive any updates regarding new packages, courses, challenges, special offers or similar. If you are in any doubt however, please let us know and we will be more than happy to clarify.

8. How we protect your data

The security of your data is extremely important to us and we have done our utmost to ensure that the third-party companies we use to support our business hold sufficient security procedures and protection. Classifications:

9. How long will we keep your data?

We only keep the data you have provided to us for as long as is necessary. For example, if you book a twelve-month coaching package in January 2020, we will hold your details on Outlook until the end of January 2021 (allowing for any over-running of your package) as we will use your personal data to get in touch, to schedule your coaching sessions and to offer continued coaching support following the end of your current package. Should you choose to decline such an offer, we will then remove your details from our active customer files.

Beyond this point, we may still retain certain information regarding any payments/transactions you have made to us to meet our own legal obligations. Any contractual documents in which you share personal data with us will be kept for up to 6 years after the date of the original transaction in order to comply with our own legal obligations regarding retention of financial records. Financial data, including payment documents and transaction details, may be stored for a period of up to 6 years after you cease activities with us due to our own legal obligations regarding retention of financial records. Any other personal data you share with us such as contact information via alternative methods such as email or text are deleted 12 months after sharing, unless you request us to remove such details before then. Please note, when you register any details with Microsoft Outlook, Mailchimp, SurveyMonkey, Facebook, LinkedIn, Pinterest or Instagram you hereby follow their Privacy Policy and their duration of data retention may differ from ours.

We can remove your details at any time – to request to have your details removed, please email us at juliette@juliettelee.co.uk. Please be aware, if you are a current customer of ours and you request to remove some or all of your personal data you shared with us, we may be unable to offer some or all of the services you requested when originally signing up and we may be unable to carry out your request if you:

Please note: web data is electronically deleted/removed and any data in hard-copy format is disposed of via an appropriate confidential waste method.

10. Who do we share your data with?

Other than the companies mentioned above who support our business activities (Microsoft Outlook, Mailchimp, SurveyMonkey, Facebook, LinkedIn, Pinterest and Instagram) we DO NOT share or sell your personal data to any other third party company. Your personal data is important to us, so it is important for you to know that we only use it for our specific business purposes and nothing else. Please be aware that it may be necessary for us to share your information with local authorities, law enforcement and for any other legal reason and in such cases, we do not require your consent to do so.

11. Where your data may be processed

As a business, Juliette Lee Ltd operates inside the European Economic Area (EEA) and therefore does not process the data that we receive from our operational support companies (Microsoft Outlook, Mailchimp, SurveyMonkey) outside the EEA. However, as we use third-party companies to support our business, there is a chance that your data is processed outside the EEA before it reaches Juliette Lee Ltd. Please refer to the respective company Privacy Policies for further guidance, links above. Otherwise, it may be necessary from time-to-time for staff or nominated sub-contractors to process your personal data (such as a name) privately between you and/or staff via email or on social media platforms such as Facebook or Instagram and/ or via mobile phone for the purposes of:

In addition, we have our public LinkedIn page which is viewable to anyone, publicly, who visits online. If you choose to comment or share any personal data (such as names, addresses, phone numbers etc.) on this public page, other LinkedIn users may be able to see this data too. Please be aware that LinkedIn, Instagram and other social media platforms operate their own privacy policies which are applicable when you use their respective sites/apps. Such social media pages or groups associated with Juliette Lee Ltd. are created solely for genuine business purposes and to assist with the delivery of our services to customers efficiently and informatively. You, as a Data Subject, should not wilfully share any specific personal or sensitive data about yourself publicly on any Juliette Lee Ltd associated social media platform. Please only do so at your own discretion and with full awareness of the potential risks of sharing such data. Any personal data that is wilfully shared with Juliette Lee Ltd on social media platforms is carefully and professionally collected and processed by staff only. Although we treat such data confidentially to the best of our abilities, we do not recommend sharing sensitive data in this way (such as addresses, phone numbers, medical records or bank details) due to discrepancies and risks relating to social media security. We recommend that, only if necessary, you email any personal or sensitive data instead, if circumstances permit.

PHOTOGRAPHY / VIDEOGRAPHY We will only process or share personal data such as photography and videography for marketing purposes, if you have permitted us to do so.

12. Your rights to privacy

It is important to know your rights. Whilst we are not experts on providing such advice, it is our understanding that you can request the following:

(If you wish to access, amend or remove the personal data that we hold about you, please email us: juliette@juliettelee.co.uk and allow up to 30 days for your request to be processed and your data updated). This means that you may receive some communications in the period of ‘cross-over’ until systems are fully updated. If we cannot satisfy your request for any reason, we will let you know why – this includes refusal of your request and any uncontrollable delays we may face in obtaining your information at short-notice.

Please be aware that if you have opted-in at any point with us (or any company) to use or process your personal data, it is your legal right to be able to withdraw your consent at any time. You can do this via the contact method above. We may, from time-to-time, rely on legitimate interest for using or processing your data however you may ask us to stop doing so in relation to your specific circumstance using the contact method above. We will action such requests only if we do not have a genuine reason to continue using or processing your personal data.

You can request that we stop using your personal data to contact you with marketing/promotional material at any time, even if you have given us previous consent. We will always honour such a request.

13. Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are used to give the owners of the website information about the visitors. Information such as what time of day they are coming to the website, and how long they spend on there. Cookies can also be used to improve websites. For example, we may see that lots of visitors from the south aren’t accessing their area information, so we could improve the website by making that information more prominent and easier to find. When you use this website and agree for us to place cookies on your computer, you are agreeing that we may use your personal information for the purposes set out in this statement. Other than as set out above, we will not distribute your personal information to third parties unless we have your permission or are required to by law. We will not sell or lease your information to any third parties.

YOUTUBE & VIMEO COOKIES We have several videos on our website that we’ve embedded from our Juliette Lee Ltd YouTube and VIMEO channel. Watching our videos on your computer can result in YouTube and VIMEO storing cookies on your computer, but these cookies will collect information anonymously and will not gather any information that would identify you personally.

SITE TRACKING We use tracking software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website to better meet the needs of visitors. This software does not enable us to capture any personally identifying information. We may also gather other non-personal information (from which we cannot identify you) such as the type of your internet browser which we use to provide you with a more effective service. By continuing to use www.nikihutchison.com, or the “site”, without acknowledging or taking action on the Cookie Notification that appears on the home page, you hereby agree to our/Perch’ use of cookies in the manner described in this notice. Cookies are small text files that are stored on your browser or hard drive on your computer, or other device, when you visit the site. This basically allows the site to recognise you, as a user, for the duration of your site visit (using a ‘session cookie’) or for repeat visits (a ‘persistent cookie’). These are not harmful in any way and do not contain any sensitive data such as your date of birth, address or card details. Effectively, cookies are in place to improve user experience when visiting websites, including ours. We use cookies for a number of purposes – some of which are strictly necessary, including but not limited to items such as language preferences and other user settings. Note that some cookies are automatically ‘enabled’ on browsers/devices, but read on should you need help on how to adjust your preferences regarding cookies. We use Perch to host our website, please refer to their statement regarding cookies within their privacy policy (detailed above). Please be aware that if you are using any external website including Mailchimp or any other external website, their own privacy and cookies policy should be acknowledged/understood before website use. You can manage the cookies on your computer or devices through your internet browser/settings, help links are provided below. Please note that Juliette Lee is not responsible for the content of external websites: Firefox: http://support.mozilla.org/en-US/kb/ Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internetexplorer-delete-manage-cookies Safari: https://support.apple.com/kb/PH19214 Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647

If you choose to disable the use of cookies, you may restrict your user experience on not only our site, but also the websites of the third-party companies we use to support our business activities.

14. Relevant contact information

We have done our utmost to ensure that this policy is clear and helpful in allowing you to understand the way we handle your data, including your rights over it. Should you have a question that has not been answered above, or simply want to discuss our Privacy Policy further, feel free to contact us by any of the following methods:

To find out more information regarding the GDPR and to make any complaints, please visit the governing body website at: www.ico.org.uk.