Privacy Policy
This is the privacy notice of the websites, www.jasonkitts.co.uk, www.trustgap.co.uk, www.trust-gap.com, www.trustcharter.co.uk, www.trustninjas.com and www.trustninjas.co.uk. (collectively, the “website”), Jason Kitts and Coaching Watershed Limited. In this document, “we”, “our”, or “us” refer to Jason Kitts and Coaching Watershed Limited.
Coaching Watershed Limited’s company number is 12990407 registered in the UK, with registered office 62 Oakhill Road, Sevenoaks, Kent, TN131NT.
Introduction
1. How we process information about you
The GDPR requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.
If a basis on which we process your personal data is no longer relevant, then we shall immediately stop processing your personal data. If the basis changes, then if required by applicable law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
If you are located in the EU or UK, this section applies to you.
The GDPR requires us to explain the valid legal bases we rely on in order to process your personal data. As such, we may rely on the following legal bases to process your personal data:
- We may process your information if you have given us permission (i.e. consent) to use your personal data for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Performance of a Contract.We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our services , including a Trust Test, or at your request prior to entering into a contract with you.
- Legitimate Interests.We may process your personal data when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal data for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. express consent, including by taking the Trust Test) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your personal data without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes, or
- If the information is publicly available and is specified by the regulation.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal data, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal data; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal data. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
2. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, use the Trust Test, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal data, for example your email.
We may use your personal data provided in order to:
2.1 verify your identity for security purposes,
2.2 sell products to you,
2.3 provide you with our services, or
2.4 provide you with suggestions and advice on our products and/or services.
We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide or to determine results of a Trust Test that you have undertaken. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
3. Information we process with your consent
When there is no contractual relationship between us to govern our use, certain actions, such as when you browse our website or ask us to provide you more information about our business, including Trust Test results and information on our products and services, you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you may give your consent implicitly rather than explicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your personal data in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website or to aggregate results from a Trust Test.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your personal data on this basis until you explicitly withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us. However, if you do so, you may be unable to use our website or our services thereafter.
4. Information we process because we have a legal obligation
We are subject to the laws of England and Wales, and perhaps other applicable laws. As a result, we are required to process your information in order to comply with a particular statutory obligation.
For example, we may be required to give information to applicable legal authorities if they so request or if they have the proper authorisation, such as a search warrant or court order.
This may include your personal data.
5. Specific uses of information you provide to us
A. Job application and employment
If you send us information in connection with a job application with us, or to be a service provider / contractor to us, we may keep it for up to one (1) year in case we decide to contact you at a later date.
If we employ or contract with you, we collect information about you and your employment from time to time throughout the period of your employment/contract. This information will be used only for purposes directly relevant to your employment/contract. After your employment/contract has ended, we will keep your file for six (6) years before destroying or deleting it.
B. Sending a message to our support team
When you contact us, whether by telephone, through our website or by WhatsApp, Teams or e-mail, we collect the personal data you have given to us in order to reply to your request. We record your request and our reply in order to increase the efficiency of our company.
We keep personally data associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
C. Complaining
When we receive a complaint from you, we record all the information you have given to us. We use that information to respond to and hopefully resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
D. Use of information we collect through automated systems when you visit our website:
D.1. Cookies. Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a fixed period of time, such as one day or until you close your browser. Other cookies last indefinitely.
Your web browser should allow you to delete any cookies you choose to delete. It also should allow you to prevent or limit the use of cookies altogether.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
- to track how you use our website,
- to record whether you have seen specific messages we display on our website, and/or
- to record your answers to surveys and questionnaires on our site while you complete them.
D.2. Personal identifiers from your browsing activity. Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
D.3 Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.
Disclosure and sharing of your information
6. Information we obtain from third parties
Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.
No such information is personally identifiable to you.
7. Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
8. Data may be processed outside the UK
Our websites are hosted in the UK.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly, data obtained within the UK or any other country could be processed outside the UK or the European Union.
We use the following safeguards with respect to data transferred outside the UK:
8.1 the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
8.2 we comply with a code of conduct approved by a supervisory authority in the European Union [, specifically that in the country of the UK].
Access to your own information
9. Access to your personal data
9.1 At any time you may review or update personally identifiable information that we hold about you.
9.2 To obtain a copy of any information that is not provided on our website you may send us a request here.
9.3 After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
10. Verification of your information
When we receive any request to access, edit or delete personal data from you, we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your personal data.
Other matters
11. Use of site by minors
11.1 We do not sell products or provide services for purchase or use by children or minors, nor do we market to children or minors.
11.2 If you are under 18, you may use our website only with explicit consent from a parent or guardian.
12. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
13. How you can complain
13.1 If have any complaint in respect of privacy and your personal data, then please notify us by using our contact form.
13.2 If you are in any way dissatisfied about how we process your personal data, you have a right to file a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/.
14. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us to:
14.1 provide you with the services you have requested;
14.2 comply with applicable law, including for the period demanded by our tax authorities; or
14.3 support a claim or defence in court.
15. Compliance with applicable laws
Our privacy policy has been compiled so as to comply with the applicable law of England and Wales. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
Ultimately, it is your decision as to whether you wish to use our website.
16. Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.