Privacy Policy (Website)

BACKGROUND:

CAM Solutions Ltd. a company incorporated in Scotland under registration number SC405805 whose registered office is at 14 South Trinity Road, Edinburgh, Scotland, EH5 3NR, trading as Coach Logic, understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://www.coach-logic.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy when visit Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Cookie”
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Personal data”
is defined by the General Data Protection Regulation (Regulation (EU) 2016/679) (EU GDPR) (where applicable in relation to the storage retention and processing of EU personal data), the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (the “UK GDPR”), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’; and
“We/Us/Our”
means the said CAM Solutions Ltd. (as above).

2. Information About Us

2.1 Our Site is owned and operated by Us.

2.2 Our VAT number is 124846215.

2.3 Our Data Protection Officer is Rūta Mankevičienė, and can be contacted by email at ruta@coach-logic.com or by post at 14 South Trinity Road, Edinburgh, Scotland, EH5 3NR.

2.4 We are regulated by UK’s supervisory authority, the Information Commissioner’s Office.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the Data Protection Legislation, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office details of which can be found here https://ico.org.uk/

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies):

5.1 name;

5.2 business/company name;

5.3 job title;

5.4 profession;

5.5 contact information such as email addresses and telephone numbers;

5.6 demographic information such as post code, preferences, and interests;

5.7 IP address;

5.8 web browser type and version;

5.9 operating system;

5.10 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

5.11 profile picture;

5.12 sport or sports played;

5.13 team history;

5.14 personal data pertaining to children (any person under the age of 18 years);

5.15 sporting performance level.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your access to Our Site;

6.2.2 Personalising and tailoring your experience on Our Site;

6.2.3 Supplying Our products and services to you;

6.2.4 Personalising and tailoring Our products and services for you;

6.2.5 Replying to emails from you;

6.2.6 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by unsubscribing using the links provided in Our emails or contacting us by email at info@coach-logic.com;

6.2.7 Market research;

6.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

6.2.9 For researching trends and demographics.

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone and/or text message and/or post with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 Third parties (including Google Inc, Brevo, Twitter, Facebook, YouTube and ActiveCampaign) whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.6.1 Personal data provided in connection with direct marketing or newsletter subscriptions will be retained as long as your direct marketing subscription remains active and your consent is considered to be valid.

6.6.2 Personal data provided during communication with our sales or/and support team either via email or submit a request forms will be retained for two years after your most recent communication with us.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2 We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

7.3 We store some of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

7.3.1 We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.

7.3.2 We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.

7.4 Please contact Us using the details below in Part 14 for further information about the particular data protection safeguards used by Us when transferring your personal data to a third country

7.5 Steps We take to secure and protect your data include, but not limited to:

7.5.1 All the personal data you provide to Us over https://www.coach-logic.com is transferred and protected over a secure SSL connection;

7.5.2 Password protected;

7.5.3 Role based access and admin roles to prevent unauthorized access to personal data;

7.5.4 Dual factor authentication;

7.5.5 Regular back-ups;

7.5.6 Data minimisation;

7.5.7 Anonymisation;

7.5.8 Pseudonymisation;

7.5.9 Dashboards and alerts to enhance system control and monitoring;

7.5.10 Systems, devices and software are kept up to date;

7.5.11 Data encryption at rest and in transit;

7.5.12 Regular data protection and security training;

7.5.13 Spam protection.

7.6 Notwithstanding the security measures that We take, it is important to note that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the Internet.

8. Do We Share Your Data?

8.1 We may share your data with other companies in Our group for administrative and internal management. This includes Our subsidiaries and/or Our holding company and its subsidiaries.

8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.4 The third-party data processors used by Us and listed below are located outside of the UK and the EEA. We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and the EEA and under the Data Protection Legislation:

8.4.1 Webflow (US servers)

8.4.2 Facebook Inc;

8.4.3 X Corp. former Twitter Inc; (US Servers)

8.4.4 ActiveCampaign LLC; (US server)

8.4.5 Google Inc; (EU and US servers)

8.4.6 Zendesk (EU and US servers) .

8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

10. How Can You Control Your Data?

10.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Your Right to Withhold Information

11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

11.2 You may restrict Our use of Cookies. For more information, see section 13.

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at, info@coach-logic.com, or using the contact details below in section 14.

13. Our Use of Cookies

13.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for advertising services, content display, analytics, performance monitoring, support. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

13.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.

13.4 Before Cookies are placed on your computer or device, you will be shown a pop-up/banner requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.

13.5 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

13.6 The following first party Cookies may be placed on your computer or device:

Name of Cookie
Strictly Necessary
Purpose
CookieConsentPreferences
Yes
Cookie mechanism allowing user to consent or reject cookies

and the following third party Cookies may be placed on your computer or device:

Name of Cookie
Provider
Purpose
__cfdiud
Zopim.com / Zendesk
Used by the content network, Cloudflare, to identify trusted web traffic.
lang
ads.linkedin.com
Remembers the user's selected language version.
__zlcmid
Zopim.com / Zendesk
Preserves users states across page requests.
_hjIncludedInSample
hotjar.com
Determines if the user's navigation should be registered in a certain statistical place holder.
ads/ga-audiences
Google.com
Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor 's online behaviour across websites.
Bcookie, bscookie, lidc
Linkedin.com
Used by the social networking service, LinkedIn, for tracking the use of embedded services
BizoID
Linkedin.com
Provides LinkedIn insights and ads tags
fr
Facebook.com
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
guest_id
Twitter.com
Collects anonymous data related to the user's visits to the website, such as the number of visits, average time spent on the website and which pages have been loaded, with the purpose of personalising and improving the Twitter service.
PREF
Youtube.com
Registers a unique ID that is used by Google to keep statistics of how the visitor uses YouTube videos across different websites.
personalization_id
Twitter.com
This cookie is set due to Twitter integration and sharing capabilities for the social media.
YSC

Youtube.com
Registers a unique ID to keep statistics of what videos from YouTube the user has seen.
zte#
Zopim.com / Zendesk
Saves a Zopim Live Chat ID that recognises a device between visits during a chat session.

13.7 Our Site uses analytics services provided by Google Inc. . Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and/or services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you. We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google Inc. within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States.  To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

13.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

13.9 The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie
first
Provider
Purpose
_ga
Third
Google Analytics
Registers a unique ID that is used to generate statistical data on how the visitor uses the website
_gat
Third
Google Analytics
Used by Google Analytics to throttle request rate.
_gid
Third
Google Analytics
Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

13.10 In addition to the controls that  We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. Alternatively, websites such as “All About Cookies” provide comprehensive guidance:

http://www.allaboutcookies.org/

13.11 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

13.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

14. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@coach-logic.com or by post at 14 South Trinity Road, Edinburgh, Scotland, EH5 3NR. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

End of policy