This Privacy Policy governs the manner in which this Website (www.vivapositiva.com) collects, uses, maintains and discloses information collected from users (each, a "User") of this website ("Site"). This privacy policy applies to the Site and all products and services offered though the Site for the purpose of providing coaching, workshop, training and consultancy. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller. A data controller is responsible for deciding how to hold and use personal data. Personal data is information or data from which you can be identified and is about you.
You may give your personal details to the Company directly or be part of a workshop or training session where data is collected. The Company must have a legal basis for processing your personal data. For the purposes of providing you with coaching, workshops or consultancy we will only use your personal data in accordance with the terms of the following statement.
1. Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will store and process your personal data for the purposes of providing you with work-finding services. The legal bases we rely upon to offer these services to you are:
• Legitimate interest
• Contractual obligation
b. Personal data
Your personal data includes personal contact details (such as name, title, address, telephone number, and email address), biographical data (such as your date of birth, gender, marital status and dependants) and financial data (such as bank account details).
In addition to processing personal data, the Company may also process sensitive personal data. Sensitive personal data is data of a more sensitive nature and includes information about your race, ethnicity, religious beliefs, sexual orientation, political opinions, trade union membership, information about your health, biometric data and information about criminal convictions and offences. Depending on the information that you provide, the Company may also process other categories of sensitive personal data. The Company’s legal basis for processing this data will be because it is necessary to do so for the purpose of carrying out obligations in the field of coaching, training, workshops and consultancy.
If you do not wish the Company to process your sensitive personal data do not provide it.
Web browser cookies: Our Site may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.
c. Legitimate interest
Where the Company has relied on a legitimate interest to process your personal data our legitimate interests are as follows:
• To provide coaching, training, workshops and/or consultancy services
• To keep you informed of relevant industry events
• To third parties whether that be regulatory or law enforcement where the Company is required to disclose such information in relation to any legal proceedings
• To improve our Site. We may use feedback you provide to improve our products and services.
• To run a promotion, contest, survey or other Site feature. To send Users information they agreed to receive about topics we think will be of interest to them.
• To send periodic emails. We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
d. Recipient/s of data
The Company will not share your details outside of the organisation. We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
The Company may transfer your personal data outside of the EU. If we do, you can expect a similar degree of protection in respect of your personal data, to the protection that you receive in the UK.
e. Statutory/contractual requirement
Your personal data is required by law and/or a contractual requirement You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:
• Failure to provide coaching, workshop, training and/or consultancy services.
2. Data retention
The Company will retain your personal data only for as long as is necessary to fulfil the purposes for which we collected it including for the purposes of satisfying any legal, accounting, or reporting requirements. Different laws require us to keep different data for different periods of time.
The Company will delete your personal data after five years if we have not had any ‘meaningful contact’ with you or if we do not hold any records on you that are in our legitimate interests to keep.
“Meaningful contact” is defined as any form of contact between us in relation to the Company assisting/providing coaching, workshop, training and/or consultancy services.
3. Your rights
Please be aware that you have the following data protection rights:
• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.
We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate. Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR). 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. We do this now, by requesting that you read the information provided at . Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
Where you have registered with the Company and acknowledged their legitimate interest to process your personal data, you have the right to withdraw that consent at any time by contacting Matt C Freeman, Director at Viva Positiva, matt@vivapositiva.com. Once the Company has received notification that you have withdrawn your consent, it will no longer process your data for the purpose or purposes you originally agreed to, unless the Company has another legitimate basis for doing so.
4. Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Matt C Freeman, Director at Viva Positiva, matt@vivapositiva.com.
You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.