Quiet Space Ltd Privacy Policy

INTRODUCTION

Welcome to the Quiet Space Ltd (“Quiet Space”) Privacy Policy.

Quiet Space respects your privacy and is committed to protecting your personal data. This Privacy Policy will tell you how we look after your personal data, inform you of your privacy rights, and explain how the law protects you.

Please use the Glossary at the end of this Privacy Policy to understand the meaning of some of the terms used in it.

Our Cookies Policy is set out below, at the end of this Privacy Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how Quiet Space collects and processes your personal data, including any data you may provide through our website when you sign up to receive our newsletter, take part in a competition, or purchase a service.

It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your data.

CONTROLLER

Quiet Space is the controller of your personal data (collectively referred to as, “we”, “us” or “our” in this Privacy Policy). If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at enquiries@quietspacecoaching.co.uk.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Quiet Space Ltd, a limited company registered in England and Wales with company number 10943544.

Postal address: 23 Hanworth Close, Leamington Spa CV32 7PP, Warwickshire, United Kingdom.

You can also contact us via email at enquiries@quietspacecoaching.co.uk.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). Please read https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may need to update this Policy at any time and where we do this we will notify our customers. This Policy was last updated on 13 July 2023.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use and store different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name and last name.
• Contact Data means the data we use to contact you including your billing address, email address and telephone number.
• Financial Data means the data we use to process any payments for orders you may make with us, including your payment card details. We do not store or process your card details ourselves; these are processed and stored via a third-party service provider. If you make a purchase from us online we encrypt your payment card details in your browser and securely transfer this data to the relevant third-party payment provider to process a payment.
• Transaction Data means details about any transactions you have made with Quiet Space including the payments to and from you along with other details of services you have purchased from us.
• Marketing and Communications Data includes your preferences in receiving marketing and communications from us.
• Technical Data means details about the device(s) you use to access our website. This may include your internet protocol (IP) address, browser type and version, and other related information.

(NOTE: Articles on this site may include embedded content (e.g. videos). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.)

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data, for example under the terms of any contract we may have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, where you do not supply suitable payment instructions for us to provide you with services).

3. HOW DO WE COLLECT DATA?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity Data, Contact Data, Transaction Data, Financial Data, Marketing and Communications Data and Technical Data by using our website, commenting on posts, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
– ask us to contact you to discuss our services;
– purchase a service through our website;
– request marketing to be sent to you;
– leave comments on our website;
– enter a competition; or
– give us some feedback.

Our website makes use of third-party essential service providers to help us collect or process your data for our legitimate interests of conducting business with you or to perform our contract with you. Currently these include Mailchimp, JotForm and Stripe. All these service providers enter into a contract with us that protects your personal data and restricts their use of any personal data consistent with this policy.

Further information is available in the privacy policies of these third-party service providers, as follows:
https://www.jotform.com/privacy/
https://mailchimp.com/legal/privacy/
https://stripe.com/gb/privacy

• Automated technologies or interactions. Our website makes use of Google Analytics to collect information about how you use our website. This includes your browsing patterns and information such as how long you might spend on one of our webpages and what you look at and for on our website, the click stream to and from our website, page response times and page interaction information such as scrolling and clicks. This information does not include any personally-identifiable information. Further information on “How Google uses data when you use our partners’ sites or apps” is available at http://www.google.com/policies/privacy/partners/. Please also see our Cookies Policy for further details.

4. THIRD PARTY SOURCES OF DATA/DATA SHARING

In certain limited circumstances we may share or collect data with/from the following providers:

• Essential Service Providers: As noted above, our website makes use of third-party essential service providers to help us collect or process your personal data for our legitimate interests of conducting business with you or to perform our contract with you.
• Professional Advisers and Legal Compliance: We may also share your data with professional advisers such as lawyers and insurers if this is necessary to manage any legal claims or our business security. This is in our legitimate interests.

The lawful bases for sharing and processing this data are set out in the table below. Please refer to the External Third Parties listed in the Glossary for further information.

5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where you have opted in to receive marketing communications from us or have requested that we contact you to discuss our services.
• Where we need to perform a service 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 relevant third party), and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

See the Glossary at the end of this Privacy Policy to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by visiting our Unsubscribe Page.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new contact when you fill in the contact form on our website, and for spam detection and prevention	(a) Identity (b) Contact (c) Technical	Necessary for our legitimate interests to allow us to contact you to provide you with further information on our services, and for the purposes of spam detection and prevention.
To add you to our customer database when you subscribe to our mailing list	(a) Identity (b) Contact (c) Marketing and Communications	Necessary in order to send direct marketing communications to you via email.
To process and fulfil any purchases of services that you may make through our website	(a) Identity (b) Contact (c) Financial (d) Transaction	Performance of a contract with you.
To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy	(a) Identity (b) Contact	Necessary for our legitimate interests of ensuring our customers are updated on these changes.
To help us improve our offering to our customers, including asking you to leave a review or take a survey, or provide customer insights	(a) Identity (b) Contact (c) Marketing and Communications	Necessary for our legitimate interests (to study how customers use our services, to improve our offering to our customers, to develop them and grow our business).
To respond to any comments you may leave on our website, to facilitate your leaving of comments, and for spam detection and prevention	(a) Identity (b) Contact (c) Technical	Necessary for our legitimate interests to allow engagement with commenters on our articles and allow visitors to conveniently submit comments, and for the purposes of spam prevention.
To enable you to partake in a prize draw or competition	(a) Identity (b) Contact (c) Marketing and Communications	Performance of a contract with you to fulfil the promotion and run the competition/prize draw. We may also subsequently use your entries for the legitimate interests of understanding our customer base more effectively.

MARKETING

We generally only send electronic marketing – such as email marketing – to people who have previously bought services from us or who have expressly opted in to receive these marketing communications. We provide you with control regarding the use of any personal data that you have provided to us.

We will always offer a way out of receiving any marketing communications when you first purchase our services and in every marketing communication afterwards.

Where you have not previously bought from us but have registered your details with us (for example by entering a competition or signing up for a newsletter), we will only send you marketing communications if you opted into receiving marketing at the time and thus given us your express consent (which you may withdraw at any time – see Opting out below).

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the unsubscribe link on any marketing message sent to you or by emailing us at marketing@quietspacecoaching.co.uk at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and only ever as permitted by law.

COOKIES

We primarily process anonymised cookie data, through Google Analytics. Google Analytics mainly uses first-party cookies to report on visitor interactions on our website. You can set your browser to refuse all or some browser cookies. For more information about the cookies we use, please see our Cookies Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with all applicable rules, if this is required by law.

6. DISCLOSURES OF YOUR PERSONAL DATA

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. These third parties can only use your data for the purposes we specify in our contract with them. We will always work with them to protect your privacy.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to your personal data is limited to Quiet Space employees and third parties who have a business need 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.

You acknowledge that the Internet is not a completely secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via the Internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements. For example, details of your orders will be kept for as long as we need to retain that data to comply with our legal and regulatory requirements. This is generally 7 years unless the law prescribes a longer period.

In some circumstances you can ask us to delete your data. See Your Legal Rights below for further information.

If we utilise anonymised data we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it for example where you consider that we do not need it any longer for the purposes for which we originally collected it as explained to you in this Privacy Policy, where you have withdrawn your consent to our using it and we had relied on that consent according to this Policy, where you consider that we cannot show a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest to process it as explained to you in this Policy . You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) if our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please email us at enquiries@quietspacecoaching.co.uk.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We will respond to all legitimate requests within one month.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

EXTERNAL THIRD PARTIES

Website form providers – when you fill in any forms on our website or our linked subscription pages, your personal data is transmitted to us via our website form providers so we can respond to your query or add you to our mailing list.

Email service providers – in order to send you marketing content, we share your details with our email service providers.

Analytics tools – we use analytics tools to track the way that users interact with our website.

Payment providers – in order to facilitate any payments made on our site, we facilitate the sharing of your Financial Data with payment providers.

Spam detection and prevention – Visitor comments may be checked through an automated spam detection service.

Quiet Space Ltd Cookies Policy

By visiting this website with your browser settings adjusted to allow cookies, you are consenting to Quiet Space Ltd (“Quiet Space”) using cookies for the purposes outlined below.

WHAT IS A COOKIE?

A cookie is a small text file which is downloaded and stored on your computer or mobile device by websites that you visit. Where cookie technology is not available, an anonymous identifier may be used. An anonymous identifier is a random string of characters used for the same purposes as a cookie.

Your browser accesses the cookie file only when you visit the website that generated it. The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only the information that you have disclosed to the site.

Our website uses the following types of cookie:

• Performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These cookies are not essential but enhance your use of our website. For example, if you leave a comment on our website you may opt in to saving your name, email address and website in your cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies last for 12 months.

The list below details the cookies used on Quiet Space. We have outlined who sets these cookies and their purpose.

Category	Party	Purpose
Performance	Google Analytics	Google Analytics use cookies (or, if applicable, anonymous identifiers) to collect data that helps us understand how people are using the site. We use this information to identify how and where we can improve the experience of our website users, and to help us determine where our ads will be most effective online. The data collected through these cookies is anonymous, does not collect specific customer data and is never shared with other third parties.
Performance	Social media plugins	Sites such as Facebook serve cookies in order for our website visitors to be able to share and discuss Quiet Space’s services and content on social networks.
Functionality	Quiet Space	To facilitate the leaving of comments by website visitors

DURATION OF COOKIES

Session (or Transient) Cookies
Session cookies are stored in your computer’s memory for the length of your browsing session. They become inaccessible after the session has been inactive for a time and are automatically deleted from your computer when the browser is closed. They allow you to move from page to page without having to log-in repeatedly.

Persistent (or Permanent) Cookies
Persistent cookies are stored in your computer memory and are not deleted when the browser is closed. They are used to keep your preferences for the website, so they will be remembered for next time you visit the website, leave comments etc. They are also used to collect information about the numbers of visitors and the average time spent on a particular page. This information is used to find out how well the website works and where it can be improved.

Sharing with social networks
If you use the buttons that allow you to share content with your friends via social networks like Facebook and Google+, these companies may set a cookie on your computer memory. Find out more about these here:
https://www.facebook.com/about/privacy
www.google.com/policies/privacy/partners/
https://www.whatsapp.com/legal/#privacy-policy
https://www.linkedin.com/legal/privacy-policy

MANAGING COOKIES

You can use your browser to enable and manage cookies. Each browser is different, so check the settings of your particular browser or mobile handset to learn how to change your cookie preferences.
• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (on mobile devices)
• Safari (on your Mac)
• Google Analytics Opt Out

Last amended 13 July 2023