1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Means an account required to access and/or use certain areas and features of My Site; http://tomassvitorka.com
Means a small text file placed on your computer or device by My Site when you visit certain parts of My Site and/or when you use certain features of My Site. Details of the Cookies used by My Site are set out in section 12, below;
Means this websites and all its subdomains,
“UK and EU Cookie Law”
Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
Means Tomas Svitorka Coaching, a Sole Proprietor, whose business registered address is Kemp House 152-160 City Road EC1 2NX
2. Information About me
2.1 My Site, is owned and operated by Tomas Svitorka Coaching, a Sole Proprietor, whose business registered address is Kemp House 152-160 City Road EC1 2NX. My VAT number is: 290 6599 62
3. What Does This Policy Cover?
4. What Data Do I Collect?
4.1 Full Name;
4.2 Email Address
4.3 Telephone Number
4.4 Company name
4.5 Company Information
4.7 Credit / Debit card details
4.8 IP address
4.9 Web browser type and version
4.10 Operating System
4.11 A list of URLs starting with a referring site, your activity on My Site, and the site you exit to
5. How Do I Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.5.2 I use your data to provide the best possible products and services to you. This includes:
5.2.1 Providing and managing your Account
5.2.2 Providing and managing your access to My Site
5.2.3 Personalising and tailoring your experience on My Site
5.2.4 Supplying My products and services to you
5.2.5 Personalising and tailoring My products and services for you
5.2.6 Responding to communications from you
5.2.7 Supplying you with email newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the ‘update your preferences’ link in the email or by contacting me at firstname.lastname@example.org
5.2.8 Market research
5.2.9 Analysing your use of My Site and gathering feedback to enable me to continually improve My Site and your user experience
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and I will be limited in the products and services I can provide you without your consent for me to be able to use such data.
5.4 Once you have submitted your data, I use your data for marketing purposes which may include contacting you by email, telephone, text message with information, news and offers on my products and services. I will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that your rights are fully protected and comply with my obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Advertisers whose content appears on My Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that I do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on My Site.
5.6 Under GDPR I will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. I will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which I are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by me or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do I Store Your Data?
6.1 I only keep your data for as long as needed in order to use it as described above in section 5, and/or for as long as I have your permission to keep it. In any event, your data will be deleted if you notify me via email, telephone or post.
6.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using My Site and submitting information to Me. If I do store or transfer data outside the EEA, I will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Me and any third parties I engage with.
6.3 Data security is of great importance to Me, and to protect your data I have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through My Site.
6.4 I shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
• All employees, agents, contractors, or other parties working on my behalf shall be made fully aware of both their individual responsibilities and my responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
• Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
• The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
• All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
• All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation.
6.5 Notwithstanding the security measures that I take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Me data via the internet
7. Do I Share Your Data?
7.1 I may only share your data with wholly owned subsidiaries of Tomas Svitorka Coaching.
7.2 I may contract with third parties to supply products and services to you on My behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, I will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, My obligations, and the obligations of the third party under the law. I currently contract with:
Below are details of Third-party Name and Type of data subject
Google: First name, last name, email address
GetResponse: First name, last name, email address
Facebook: First name, last name, email address
Xero: First name, last name, email address, company information, purchase invoices
Typeform: First name, last name, email address
Royal Mail and Couriers: First name, last name, Company Name, Address
7.3 I may compile statistics about the use of My Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. I may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances I may be legally required to share certain data held by Me, which may include your personal information, for example, where I are involved in legal proceedings, where I are complying with the requirements of legislation, a court order, or a governmental authority. I do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Me.
8. What Happens If My Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will] be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
9.1 When you submit information via My Site, you may be given options to restrict my use of your data. I aim to give you strong controls on My use of your data (including the ability to opt-out of receiving emails from Me which you may do by unsubscribing using the links provided in My emails or by emailing me to let me know your preferences).
9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access certain areas of My Site without providing any data at all. However, to use all features and functions available on My Site you may be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Me to use your personal data as set out in section in 5 at any time by contacting Me using the details set out in section 15, and I will delete Your data from My systems. However, you acknowledge this may limit My ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Me (where such data is held). Please contact Me for more details at email@example.com,or using the contact details below in section 15.
12. What Cookies Do I Use and What For?
12.2 By using My Site you may also receive certain third party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Me. I use third-party Cookies on My Site for advertising services. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of My Site.
12.3 All Cookies used by and on My Site are used in accordance with current English and EU Cookie Law.
12.5 Certain features of My Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that My Site may not work as intended if you do so. I have taken great care to ensure that your privacy is not at risk by allowing them.
12.6 I do not place first-party Cookies on your computer or device, however, the following third-party Cookies may be placed on your computer or device:
Name of Cookie :Facebook
12.7 My Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Me to better understand how people use My Site. This, in turn, enables Me to improve My Site and the products and services offered through it. You do not have to allow Me to use these Cookies, as detailed below, however whilst My use of them does not pose any risk to your privacy or your safe use of My Site, it does enable Me to continually improve My Site, making it a better and more useful experience for you.
12.8 The analytics service(s) used by My Site use(s) Cookies to gather the required information. These Cookies may be placed immediately when you first visit My Site and it may not be possible for Me to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.
12.9 The analytics service(s) used by My Site use(s) the following Cookies:
Name of Cookie: Google
First / Third Party: Third
12.10 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.11 You can choose to delete Cookies at any time however you may lose any information that enables you to access My Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Me;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14. Contacting Me