Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

This privacy policy is divided into the following sections:

1. Who we are
2. Our collection and use of your personal data
3. Who we share your personal data with
4. Transfer of your data out of the UK and EEA
5. Cookies and similar technologies
6. Marketing
7. Your rights
8. How long your personal data will be kept
9. Keeping your personal data secure
10. How to complain
11. How to contact us
12. Changes to this privacy policy
13. CCPA privacy information

1 Who we are

This website is operated by Founder Coaching Limited (“we”, “us”, “our”).

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we provide to individuals in the European Economic Area (EEA). 

Please see the 'How to contact us' section at the end of this policy if you have any questions about this privacy policy or the data we hold about you. 

2 Our collection and use of your personal data

How your personal data is collected 

We may collect personal data about you when you access our website, contact us directly, complete an onboarding questionnaire, engage with us during our coaching sessions or when your employer registers you for one of our services. 

We collect this personal data from you either directly, such as when you contact us or interact with us during coaching sessions or indirectly, from your employer or by monitoring your browsing activity while you are using our website (see “Cookies” below).

We also collect personal data about you from other sources as follows:

• from third parties such as the third party cookie providers listed in our Cookie Notice; and
• From publicly available sources such as Companies House, LinkedIn and other company websites.

Personal data we collect about you

The personal data we collect about you depends on the purpose for which you engage with us. We may collect and use the following data about you: 

• Identity Data - full name, date of birth, passport/national ID information and gender.
• Contact Data - address, email address and telephone number(s).
• Financial Data - bank account and payment card details.
• Transaction Data - data relating to the purchase of services by you.
• Technical Data - internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data - your username and password as well as photographs and audio or video recordings obtained during or in connection with your use of our services.
• Usage Data - data about how you use our website and services.
• Marketing and Communications Data - your preferences in receiving marketing from us and your communication preferences.

This personal data is required to provide our services. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you or your employer. 

This website is not intended for use by children and we do not knowingly collect or use personal data relating to children under the age of 13.

Special category data

We may collect information about your racial or ethnic origin for diversity monitoring and reporting purposes but will only do so where we have your explicit consent.

Apart from this, we do not request that you provide us with any special category personal data, for example personal data which is more sensitive such as data about your health or disabilities, however we acknowledge that you may provide this information during the course of a coaching session with us.

Where we process special category personal data, we will ensure we are permitted to do so under data protection laws, for example:

• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a lawful basis for doing so, for example:

• Consent: where you have given us clear consent for us to process your personal data for a specific purpose;
• Contract: where our use of your personal data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
• Legal obligation: where our use of your personal data is necessary for us to comply with the law (not including contractual obligations); or
• Legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides our legitimate interests).

The table below explains what we use your personal data for and why:

 

3 Who we share your personal data with

We routinely share personal data with:

• third parties we use to help provide our services to you, e.g. payment service providers including Stripe, PayPal & GoCardless; and
• other third parties we use to help us run our business, e.g. IT service providers including Kajabi, Albacross, Mailchimp, Google, HelloSign & Dropbox, third party content editors and program design consultants.

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers, to ensure they can only use your personal data to provide services to us and to you. 

We may disclose your personal data to law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, data will be anonymised but this may not always be possible. The recipient of the data will be bound by confidentiality obligations.

4 Transferring your personal data out of the UK and EEA

To provide services to you or your employer, it is sometimes necessary for us to share your personal data outside the UK and/or European Economic Area (EEA), for example, with our IT or payment service providers located outside the UK/EEA.

These transfers are subject to special rules under European and UK data protection law.

Non-UK/EEA countries do not have the same data protection laws as the United Kingdom and EEA which is why additional safeguards are required. We will, ensure the transfer complies with data protection law and that your personal data will be secure by putting these safeguards in place. Our standard practice is to enter into model clauses with the relevant data importer where required.

5 Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. Cookies help us recognise you and your device and store some data about your preferences or past actions.

For further information about cookies please see our Cookie Notice.

6 Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, or text message (SMS).

If you have given your consent to receive marketing communications, or it is in our legitimate interests to send them (for example because you have previously used our services or are a business user) you always have the right to opt out of receiving further promotional communications by:

• contacting us at [email protected]; or
• using the ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.

Please note that we may also send you other communications in relation to your use of our services or in order to respond to queries you have raised, such communications are service communications and are not a form of marketing. 

7 Your rights

You have the following rights, which you can exercise free of charge:

 

For further information about your rights please contact us or see the guidance provided by the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of your rights, please:

• see the 'How to contact us' section at the end of this policy; 
• let us have enough information to identify you e.g. your full name, address and your employer/company name);
• let us have proof of your identity (a copy of your driving licence or passport); and
• let us know which right you want to exercise and the data to which your request relates.

8 How long your personal data will be kept

We will not retain your personal data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal data. 

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

As an indication, if you or your employer purchase services from us, we will keep your personal data while we are providing such services. Thereafter, we will keep your personal data for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly; and
• to keep records required by law.

9 Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your data will do so only in an authorised manner and are subject to a duty of confidentiality. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10 How to complain

Please contact us if you have any query or concern about our use of your data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

However, if you are based in the UK, you also have the right to lodge a complaint with the Information Commissioner or if you are based in the EU any relevant European data protection supervisory authority. The UK Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113

11 How to contact us

You can contact us by email at [email protected] if you have any questions about this privacy policy or the data we hold about you, to exercise a right under data protection law or to make a complaint.

Individuals in the EEA

We have appointed David Christopher Bailey to be our data protection representative within the EEA. Their contact details are [email protected].

Individuals within the EEA can contact us directly (see above) or contact our European representative.

12 Changes to this privacy policy

This privacy policy was last updated in June 2021. We keep our privacy policy under regular review to make sure it is up to date and accurate. If we change our privacy policy from time to time, we will post the details of any changes here. We may also take reasonable steps to notify you if such changes affect how your personal data is processed.

13 CCPA privacy information

This section for California residents supplements the information contained in this privacy policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA's scope, such as:
• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from the forms you complete on our website, preferences you express or provide through our website, or from your purchases on our website.
• Indirectly from you. For example, from observing your activity on our website.
• Automatically from you. For example, through cookies we or our service providers set on your device as you navigate through our website.
• From service providers. For example, third-party vendors to monitor and analyse the use of our website, third-party vendors to deliver targeted advertising to you, third-party vendors for payment processing, or other third-party vendors that we use to provide the website to you.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

• To operate our website and provide you with our website.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our website.
• To fulfill or meet the reason you provided the information. For example, if You share your contact information to ask a question about our website, We will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Share of Personal Information

We may share your personal information identified in the above categories with the following categories of third parties:

• Service providers
• Payment processors
• Our affiliates
• Our business partners
• Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our website, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorised representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

• The right to notice. You have the right to be notified which categories of personal data are being collected and the purposes for which the personal data is being used.
• The right to request. Under CCPA, You have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:
• The categories of personal information we collected about you
• The categories of sources for the personal information we collected about you
• Our business or commercial purpose for collecting or selling that personal information
• The categories of third parties with whom we share that personal information
• The specific pieces of personal information we collected about you
• If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:
• The categories of personal information categories sold
• The categories of personal information categories disclosed
• The right to say no to the sale of personal data (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request please contact us.
• The right to delete personal data. You have the right to request the deletion of your personal data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) Your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:
• Denying goods or services to you
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to you
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us:

By email: [email protected] 

Only you, or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable request related to your personal information.

Your request to us must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it

We cannot respond to your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request
• And confirm that the personal information relates to you

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance

Do Not Sell My Personal Information

You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.

The service providers we partner with (for example, our analytics or advertising partners) may use technology on the website that sells personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.