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Privacy Notice - 6-May-22
Introduction
Rachel Jensen Money is committed to protecting your data and respecting your privacy.
This Privacy Notice sets out how we, Rachel Jensen trading as Rachel Jensen Money, will process any personal data we collect from you, or which you provide to us when you contact us, when you use our services, or when you are just visiting our website.
Our Responsibilities
When we are processing personal data, Rachel Jensen Money acts as the ‘data controller’ and is responsible for your personal data. This means we determine how and why your data is processed. We are registered as a data controller with the Information Commissioner’s Office (ICO) under number ZB285544.
Your Responsibilities
There isn’t much that you have to do, we ask that you:
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Read this Privacy Notice.
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If you are our client, please also check the contracts between us: they may contain further details on how we collect and process your data.
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If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this privacy notice.
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Contact Details
There are many ways in which you can contact us, including by phone and email. Our full contact details are:
Rachel Jensen Money
Data Protection Manager: Rachel Jensen
Email address: racheljensenmoney@gmail.com
Telephone Number: 07737344419
What Information Do We Collect About You?
We collect the following categories of information about you:
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Identity Data – including your full name, age, marital status;
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Contact Details – including your email address, telephone number, billing address, delivery address;
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Customer Data – including information about any services you have purchased from us. When you send us an email or chat with us using a communication platform or via social media, we register your messages, this will include any personal information that you choose to share with us. We register your communication preferences, for example when you request that we communicate through channels other than email (e.g. WhatsApp, Messenger, Signal or Voxer);
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Marketing Data – including your preferences in receiving marketing from us and our third parties and your communication preferences;
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User Data – including information about how you use our website and any online services;
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Technical Data - including your IP address, length of visit to pages on our website, number of times you use our website. The source of this data is from our analytics tracking system, you can find out more information in our Cookie Policy; and
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Social Media Data – depending on your social media network settings, we may receive information from your social network provider. For example, we receive visitor statistics from Facebook in connection with our Facebook Fan page.
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Special Category Data
We do not collect any special category data from users of our website or clients, except when we have your explicit consent, or when we must collect it to comply with the law. Special category data is also known as “sensitive data” (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sex life or sexual orientations, and offences or alleged offences).
How Do We Collect Your Information?
We collect personal information (as set out in Section 1) in the following ways:
Directly, when you:
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provide your information when you interact with us by phone, email, communication platform, or post;
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subscribe to our newsletter or to receive marketing communications;
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fill out the contact form on our website;
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participate in one-to-one coaching; or
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attend an online course;
Indirectly:
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when you give permission to other organisations to share it;
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where the information is publicly available;
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from social network providers; or
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through the use of website technology – please see our Cookie Policy for further details.
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Why Do We Process Your Personal Information?
Data protection law means that we can only use your data for certain reasons and where we have a lawful basis to do so. Here are the reasons for which we process your data:
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To deliver our service - when you enter into a contract with us for services, we need to process your personal information so that we can provide this to you. Our lawful basis is for the performance of a contract. We record our coaching sessions, with your consent, to enable attendees to access these sessions for a limited time following the course.
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To communicate with you – we use your contact details and your communication preferences to provide a flexible service that meets our clients’ needs. We may at your request, communicate with you via your preferred communication platform. Our lawful basis is for the performance of a contract and consent.
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Keeping Rachel Jensen Money running – the main purpose of Rachel Jensen Money is to provide money mindset coaching. We process personal information to enable you to use the services we offer, to keep you updated on any services we feel may be of interest to you, and to audit/administer our accounts. Our lawful basis is our legitimate interest.
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Improving Rachel Jensen Money - we want to ensure that content from our site is presented in the most effective manner for you and your computer/device. We also need your personal information to deal with enquires and complaints made by or about you regarding our business. We may use session recordings for our professional development. Our lawful basis is for our legitimate interests and consent.
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Marketing purposes – we like to keep you updated on any services we feel may be of interest to you. Our lawful basis is consent and legitimate interests.
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To comply with the law – sometimes we need to process data to comply with the law. Our lawful basis is a legal obligation.
Here is What Each Lawful Basis Means?
Contract – Processing your data is necessary for a contract that you have with us, or because we have asked you to take specific steps before entering into that contract.
Consent – You have given us your consent to process your data for a specific purpose. Remember you can change your mind and withdraw your consent at any time. You can do this by emailing us at racheljensenmoney@gmail.com.
Note: under the Privacy and Electronic Communications Regulation (PECR), if you have engaged with us previously (i.e., purchased services, or expressed interest in purchasing services) then we may send you relevant marketing information, unless you opted out of receiving it. All communication will contain an opt-out option. This regulation is not superseded by GDPR but works in tandem with it. For more information, please see What are PECR? | ICO
Legitimate Interest - The main purpose of Rachel Jensen Money is to provide money mindset coaching. Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities. Our legitimate interests are:
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Contacting you about services we feel may interest you, relevant news stories or blogs;
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Responding to enquires;
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Delivering products, services, or information that have been requested;
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Maintaining a database of clients and enquirers;
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Gaining insights from your behaviour on our website;
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Processing financial transactions and maintaining financial controls;
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Enforcement of legal claims; and
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Reporting criminal acts and compliance with law enforcement agencies.
When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.
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Links to Other Websites
Please note that if you click on, or follow, any links from our site to external websites, our privacy notice will no longer apply. Please check the privacy policies of any such external site before submitting any personal data, as we cannot accept any responsibility or liability in relation to them.
Do We Disclose Your Personal Information?
Rachel Jensen Money, like most companies, sometimes need to use third parties to help our business run. We have detailed other circumstances in which we may share your personal information below:
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Accountants – we share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts;
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Third party service providers – we share information for our legitimate business purposes and to enable us to provide our contractual service to you. For example, we use a cloud-based system to store client data, we use an IT service provider to ensure our IT systems are secure, we use a video conferencing platform to provide 1-1 and group coaching virtually; and
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If we are required to do so by law, any applicable regulation or to protect the rights, property, or safety of ourselves or others. This may include disclosing to other companies and organisations in connection with fraud protection and credit risk reduction.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Otherwise, then as set out in this privacy notice, we will only ever share your data with your informed consent.
International Transfers
We use Zoom, Microsoft Teams, and Vimeo to deliver our online coaching sessions. Use of Zoom and Vimeo will include the transfer of personal data to data centres based in the UK/EEA and US. You can find out more about their privacy information using the links below:
Privacy | Zoom
Privacy Policy on Vimeo
We use Wix Analytics with your consent. Wix has data centres outside of the EU, where personal data may be stored. You can view Wix’s privacy information here: About Privacy | WIX
Social Media and Instant Messaging Platforms
We use platforms such as Facebook, Messenger, WhatsApp, Signal and Voxer. If you post on Rachel Jensen Money’s social media pages or send us a private or direct message via these platforms, we will assume that you give us permission to respond. Messages posted on our social media pages are available publicly and we can’t take responsibility for those messages, which are subject to the privacy policies of the application provider and the specific privacy account settings of the user. If you choose to use these platforms, we suggest you familiarise yourself with their privacy information. We have added the links to their privacy notices below:
Voxer
Signal
Your Rights
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time.
You also have the following rights:
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right to be informed – you have the right to be told how your personal information will be used. This statement and other policy statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used;
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right of access – you can ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled see the information requested and we have successfully confirmed your identity, we have one calendar month to comply;
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right of erasure – under certain circumstances you can ask us for your personal information to be deleted from our records;
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right of rectification – if you believe our records of your personal information are inaccurate you have the right to ask for those records to be updated;
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right to restrict processing – you have the right to ask for processing of your data to be restricted if there is disagreement about its accuracy or legitimate usage; and
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the right to data portability – where we are processing your personal information with your consent because such processing is necessary for the performance of a contract (or enable us to take steps, at your request, prior to entering into a contract) AND that processing is taking place by automated means, you may ask us to provide it to you – or another service provider – in a machine-readable format.
To exercise these rights, please contact us using the contact details at the top of this privacy notice. Where we consider that the information provided does not enable us to identify the personal information in question, we may ask for personal identification and/or further information.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you consult ICO guidance - Individual rights | ICO – or please contact us using the details below.
How Do We Store Your Data and Keep it Secure?
We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclose of, or access to your personal information.
We may store your data manually or electronically. Any data stored electronically will be stored in secure servers, any data stored manually will be stored securely within the UK.
Due to the nature of the internet, we cannot guarantee the security of information that you send us via email, social media, or messaging platforms.
Data Retention
The data we collect from you is the minimum we require to facilitate the lawful processing described in this notice. Personal data is held for only as long as is required for the purpose we collected it or for our legitimate interest purposes. Unless otherwise required by law, your personal data will be stored for 7 years following the end of any commercial agreement or for 3 years after our last contact with you. However, if before that date:
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your personal information is no longer required in connection with such purpose(s);
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we are no longer lawfully entitled to process it; or
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you validly exercise your right of erasure
Then we will remove it from our records as soon as is practicable.
Should you ask us to stop sending your direct marketing or other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again.
Children’s Data
Rachel Jensen Money does not provide services to, or proactively collect any personal information from, any person under the age of 16. If we come to discover or have reason to believe that you are under 16, and we hold any of your personal data, we will delete that data within one month.
Complaints
If you feel that after contacting us, that we are not acting appropriately with respect to our data privacy, you have the right to contact the governing body. In the UK this is the ICO, the Information Commissioner’s Office, their web pages for handling issues are at:
https://ico.org.uk/make-a-complaint/
Or by post, telephone or email:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk.
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