PRIVACY AND COOKIES POLICY

Version number: [1.2]

Effective date: {Aug 2021]

1. Who are we?

1.1 We are Success Psychology. For privacy queries, you can contact us at info@successpsychology.co.uk. Other contact details are on our website. 

2. What’s the point of this policy?

2.1 It tells you what to expect when we collect personal information from our clients and from users of our website. We are the “controller” of this information. Please only use our service if you are completely happy with this policy. 

2.2 Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies. 

3. Might the policy change?

3.1 Yes. We will take reasonable steps to give you notice of the new version.

4. What do we collect? 

4.1 Information which you upload to our service or otherwise give us such as:

· your name and contact details;

· other information you provide such as date of birth, school/university/employer, health information relating to you or someone else you are booking for such as your child ;

· details about your transactions with us; and

· information that you include in communications with us.

4.2 Some of this information will be “special category data”, such as details relating to health.

4.3 Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions. 

4.4 The following information about you may be provided to us by other people:

· Limited billing information sent to us by our payment provider for verification purposes e.g., your name, email address and billing address.

5. What’s our reason / legal basis for collecting the information?

5.1 Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to information such as initial enquiries and to contact, transaction and other information you supply in connection with an assessment. 

5.2 Because it’s necessary for the supply of health-related services by health professionals (in the case of health information).

5.3 Because it’s in our “legitimate interests”, e.g., managing and improving our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to information such as automated usage data.

6. How long do we keep personal information?

6.1 Until our contract with you has ended. 

6.2 We may nonetheless hold on to some (or all) of your information for longer if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions (typically up to six years).

6.3 We will generally keep automated browsing information for up to 26 months.

7. To whom do we send or make available your personal information? 

7.1 To other people who supply us with a service, e.g., hosts, payment providers, and businesses which help us send communications or monitor our service and which provide us with e-commerce, online advertising and other services. 

7.2 To regulators, the police and other law enforcement or official authorities to help deal with fraud and abuse and/or comply with legal requirements and/or to protect us or others.

7.3 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

7.4 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

8. Do we send  your information outside the UK?

8.1 Your personal information which we collect is stored within the UK and is not transferred to any other countries  except as follows.

8.2 Your personal information (e.g., name, contact details, IP address, browsing information) may be transferred outside the UK  (generally to the US) by some of the companies who provide us with analytics, advertising and other services. If so, we will ensure that there is a legal basis to do so, for example under contracts with standard contractual clauses sanctioned by the Information Commissioner that are designed to provide adequate safeguards for your personal information. 

9. What rights do you have? 

9.1 If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).

9.2 You may also have the right to object to use of your personal information in certain circumstances.

9.3 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).

9.4 For more information about your rights, visit the ICO’s website: www.ico.org.uk.

10. What about cookies?

10.1 We and/or other companies use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your web browser. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Some are session temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: www.allaboutcookies.org. Our site’s functionality will be limited if you configure your browser to reject cookies.

10.2 We ourselves may place the following types of cookies:

Type of cookies                                 Purpose

Logged-in status                               Assess whether you are logged   in to our site

“Remember me”                               Remember you and speed up your   login when you return to our site

Authentication                                 Identify and authenticate you   to help you move easily through the site 

Security                                               Provide security-related   features to protect our site, for example to help stop fraudulent logins

Cookie notice                                 Store your response to our   cookie notice

10.3 Companies which provide us with a service also place cookies. Some of these cookies (e.g., from Google) may involve certain information, such as your name and contact details and/or the IP and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):

· Analytics cookies: These kinds of cookies recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and where the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. These cookies are provided by:

· Google Analytics (“GA”). More information:

- Google’s overview of GA data practices and safeguarding 

- how to specifically opt out from GA cookies 

- Google’s use of its partners’ data 

· Advertising cookies: These kinds of cookies are typically used to personalise ads on this or other sites based on your use of our site, to measure ad effectiveness (for example, how often you click on or view ads and whether you go on to buy something from the advertiser) and to stop you being shown the same ad repeatedly. These cookies are provided by:

· Google (including Analytics Ad Features / AdSense / Doubleclick)

- how Google uses cookies and other technologies in advertising including how to opt out of advertising cookies (this explains how ad personalisation works)

- Google’s use of its partners’ data