Data Privacy Notice

 

Naveego Ltd (“we”, “us”, or “our”) is committed to protecting and respecting your privacy. We are registered with the Information Commissioners Office ICO: CSN0977626.

Our practice is based in England under company number 16677744, providing coaching and mentoring services to both organisations and self-funded clients. We are registered in England and Wales and act as the Data Controller for the personal data we collect. The registered address is: 61 Bridge Street, Kington, HR5 3DJ.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you engage with our coaching and mentoring services, whether as an individual or as an organisation.

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1.      What Data We Collect

We collect and process the following types of personal and organisational data:

For Individual Clients:

 

·       Names and contact details (phone number and email)

  • Coaching objectives and goals

  • Coaching contract/agreement

  • Payment information (processed via Stripe)

  • Session notes and reflections, coaching outcomes and feedback

  • Coaching outcomes and feedback

Initials based system will be used to protect your confidentiality.

 

For Organisational Clients:

  • Organisation name and contact details (phone number and email)

  • Names and roles of participants and stakeholders

  • Coaching contract/agreement

  • Invoicing and payment records

Sessions notes, reflections, feedback and any other sensitive information are stored using initials and dates as identifiers, so that no other person may connect these details alone to your personal identity. All information is stored digitally as confidential data on a password protected device.

2.      How We Collect Your Data

We collect data through:

  • Direct interactions (Email, phone messaging, MS Teams video communication)

  • Our website

  • Payments, Invoicing and Appointments Scheduling systems

3.      How We Use Your Data

We use your data to deliver coaching and mentoring services; manage client relationships and communication; process payments and issue invoices; evaluate and improve our services; comply with legal and regulatory obligations.

We process your data under the following lawful bases:

  • Contractual necessity: To deliver the services you have requested

  • Legitimate interests: To manage and grow our business responsibly

  • Legal obligation: To comply with tax and accounting regulations

  • Consent: For any optional communications or data uses beyond the above

“Usage Data” – We may process data about your use of our website and services. The usage data may include your IP address, browser type, geographical location, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

The website host employs Google Analytics to monitor the behaviour patterns of website visitors but does not identify individuals. It provides information on website usage such as the number of website visits, ‘bounce rate’ etc. Google’s ability to share information collected about your visits to the website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. https://policies.google.com/privacy

“Service Data” – We may process the personal data such as first name, last name and email address you provide in the course of the use of our services. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services and communicating with you. The legal basis for this processing is consent.

“Notification Data” – We may process information that you provide to us for the purpose of subscribing to our email notifications or newsletters. The notification data may be processed for the purposes of sending you the relevant notifications or newsletters. The legal basis for this processing is consent.

“Correspondence data” - We may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication.  Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

We do not use your data for automated decision-making or profiling.

4. Data Storage and Transfers

Your data is stored securely on encrypted devices and cloud-based systems with appropriate safeguards. We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.

5. Sharing Your Data

We do not sell or give your data to any third party except where such disclosure is necessary for compliance with a legal obligation to which we are subject. ‘Legitimate interest’ reasons may require us to break confidentiality due to safeguarding issues, or risk of harm to self or others. 

We will share your data with the following third-party providers:

  • Payment processors (e.g. Stripe) / accounting system

  • Cloud-based service providers (e.g. email, appointment scheduling, video conferencing, invoicing platforms).

All third-party providers are vetted for GDPR compliance.

6. Data Retention

We retain personal data for as long as necessary to:

  • Fulfil the purposes outlined above

  • Comply with legal and financial record-keeping obligations.

After this period, data is securely deleted or anonymised. Your data is retained in your name and your email address. We keep data for 7 years after your final session in line with the requirements of our professional insurance. Where clients are under 18, data is retained for 7 years after the age of 18 is reached.

7. Your Rights under GDPR

Right to be informed about the collection, storage and use of your personal data, as contained in the above privacy information.

Right to access - you can request to see information we hold about you.

Right of rectification if your data is incorrect or incomplete.

Right to erasure, or ‘the right to be forgotten’ except where lawful reason, legal obligation or legitimate interest takes precedence.

Right to restrict processing – you can object to or restrict certain types of processing except where lawful reason, legal obligation or legitimate interest takes precedence.

Right to data portability - to obtain and reuse your personal data for your own purposes across different services. In the event of your wish to take a copy of your case notes to another practitioner these may be provided as an encrypted and password protected document.

Right to object to data processing – you can object to processing such as direct marketing or for purposes of scientific research.

Rights related to automated decisions – you can object to your personal data being used for evaluating certain things about an individual, including profiling.

The ICO says these are not all absolute rights: https://ico.org.uk/fororganisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

To exercise your rights, please contact us at lenka@naveego.co.uk

Should you have any concerns about how we have used your data please do feel free to discuss it with us in the first instance, if you feel able to do so. You, however, have the right to lodge a complaint with the Information Commissioner’s Office (ICO): 0303 123 1113

8. Cookies

Our website uses cookies for basic functionality and analytics. These are text files which are placed on your computer by websites that you visit, to make websites work efficiently and to provide information to the owners of the site about how people’s use it.  ‘Session cookies’ are stored only temporarily during your browsing session and are deleted from your device when the browser is closed.  Personal information from your device is collected such as geolocation data, IP address, unique identifiers (e.g. MAC address) and other information which relates to your activity through the site.  You can choose your use of cookies via the pop-up cookie notification and by following the instructions of your device preferences.

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9. International Data Transfers

As part of providing our coaching services, there may be occasions when your personal data is accessed or processed from locations outside the United Kingdom, including countries within the European Union (EU).  We ensure that any such transfers are carried out in compliance with UK data protection laws and the General Data Protection Regulation (GDPR). Appropriate safeguards are in place to protect your data, and your rights and protections remain the same regardless of where your data is processed.

10. Further Data Sources

 E-signature - in the form of an IP address, which is kept according to the retention period information detailed previously. Sending information by email does not always ensure complete security as not all email systems are encrypted. We recommend being mindful of what personal information is shared in an email.

Website contact form: information from the contact form is not stored by the website and we retain the information provided in line with the confidentiality protocols identified above. If no coaching relationship ensues, we will delete that information as confidential waste.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website.

12. Contact Us

If you have any questions about this policy or how we handle your data, please contact:

info@naveego.co.uk
07810391902