Privacy policy & Cookie notice

Welcome to StreetLevel ReDefined’s privacy policy & cookie notice. We respect your privacy and are committed to protecting your personal data.

This policy outlines how we collect and look after your personal data when you visit our website (regardless of where you visit it from) as well as data gathered when we interact in the course of our business (such as any notes I am taking or information I store when you sign up or go through any form of coaching, training or interview) and tells you about your privacy rights and how the law protects you. This policy also provides you with information about the cookies that are in use.

The policy applies to anyone who has worked with us in the past, is our current client, uses our website, or provides us with personal data via surveys, questionnaires, interviews, during networking events, via the phone or email.

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our website(s) streetlevelredefined.co.uk, imolakomuves.com and streetlevel.ro, including any information you may provide to us through these websites, or by completing our various session questionnaires, via email, in person, when you enquire and/or purchase a product or service, sign up to the newsletter, use a free resource, or take part in free course/pilot, an interview, a prize draw or competition.

By providing me with your data, you warrant to me that you are over 18 years of age.

Controller & Contact

StreetLevel ReDefined is the trading name of Imola Komuves, Certified Positive Psychology Coach and sole trader who operates from London, United Kingdom.

For the purposes of GDPR Imola Komuves is the data controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

You can contact her at: imola@streetleveredefined.co.uk

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

2. INFORMATION THAT WE COLLECT FROM YOU

We will collect, process and store personal data only if it is directly provided to us by you. You may do this in your capacity as the user of our website(s), by enquiring in relation to our products or services, participating in in our surveys, interviews and course pilots, introducing yourself to us, interacting with us through our website(s) or social media sites, becoming a customer or supplier.

Personal data covers any information capable of identifying an individual. It does not include anonymised data.

Below are examples of the types of data that we may process about you:

(a) Identity Data - may include your first name, last name, username, title, date of birth

(b) Contact Data - may include invoicing; purchase order; billing and delivery address, email address and telephone numbers, personal or job title and position.

(c) Financial Data - may include bank account and payment card details.

(d) Transaction Data - may include payments made for products and services you have purchased from us, or in relation to payments that we have made to you.

(e) Technical Data - may include your login data, internet protocol (IP) address, 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 used to access our website(s).

(f) Profile and Usage Data - may include username and password, enquiries submitted by you, purchases and orders, your interests, preferences, feedback and survey responses, and how you use our website, products and services.

(g) Marketing and Communication Data - may include details of your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also collect non-personal data such as Aggregated Data which is data that may be obtained from your personal data, but which does not  identify you. This may include Usage Data detailing how you use our Website and the features and areas that you have interacted with.

Sensitive or Special Category Data

We do not collect any Sensitive Data about you. Sensitive or Special Category Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

(a) Direct interactions - with us in person, by post, phone, email or otherwise. You may give us your Identity, Contact and Financial Information

(b) Automated technologies or interactions - with using our website(s), we may collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies and similar technology. You can read our Cookie Notice further down in this document.

(c) Third parties or publicly available sources - we may receive personal data about you from various third parties and public sources (third parties may be used in processing Identity, Contact and Financial categories of personal data).

(d) Technical Data from the following parties:

  • analytics providers such as Google based outside the EU;

  • advertising networks [such as Facebook, Instagram, Twitter, LinkedIn and YouTube based inside OR outside the EU; and search information providers such as Google based inside OR outside the EU.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based such as Stripe, based inside OR outside the EU.

  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by opting out and emailing us at imola@streetlevelredefined.co.uk.

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at imola@streetlevelredefined.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below, listed in the following format:

(#) Purpose/Activity

  • Type of data

  • Lawful basis/Legitimate Interest

(1) To register you as a new client

  • (a) Identity (b) Contact (f) Profile

  • Performance of a contract with you

(2) To process and deliver your order

  • (a) Identity (b) Contact (c) Financial

  • Performance of a contract with you

(3) Prepare, deliver, review and update a suitable coaching plan (including hand-written session notes)

  • (a) Identity (b) Contact (f) Profile

  • Performance of a contract with you

(4) Manage payments, fees and charges

  • (c) Financial (d) Transaction

  • Performance of a contract with you

(5) Collect and recover money owed to us

  • (C) Financial (d) Transaction

  • Performance of a contract & recover debt

(6) Manage our relationship with you (by notifying you of changes, asking for reviews or taking part in surveys and in interviews)

  • (a) Identity (b) Contact (f) Profile (g) Marketing

  • Performance of a contract with you, keep our records updated, study how clients use our services, comply with legal obligations

(7) To enable you to partake in a prize draw, course pilot, or complete a survey

  • (a) Identity (b) Contact (f) Profile and Usage (g) Marketing

  • Performance of a contract with you, study how clients use our services, to improve them and grow our business

(8) To administer and protect our business and websites (incl. troubleshooting, data analysis, testing, system maintenance, support, reporting & hosting of data)

  • (a) Identity (b) Contact (e) Technical

  • Running our business, provision of admin and IT services, prevent fraud, in the context of business re-organisation/group restructuring, complying with a legal obligation

(9) To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

  • (a) Identity (b) Contact (e) Technical (f) Profile and Usage (g) Marketing and Communication

  • Study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

(10) To use data analytics to improve our website, products/services, marketing, customer relationships and experience

  • (e) Technical (f) Profile and Usage

  • Define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

(11) To make suggestions and recommendations to you about goods or services that may be of interest to you

  • (a) Identity (b) Contact (e) Technical (f) Profile and Usage

  • Develop our products/services and grow our business

Marketing Communications

You will receive marketing communications from us if you have:

(a) requested information from us or purchased goods or services from us; or
(b) if you provided us with your details when you registered to receive free resources, attend a pilot/free training online, took a Quiz on our website, entered a competition or registered for a promotion; and
(c) in each case, you have not opted out of receiving that marketing.

We will not share your personal data with any third party for marketing purposes.

You can ask us to stop sending you marketing messages or other emails at any time by following the opt-out link on any marketing message or email sent to you OR by emailing us at imola@streetlevelredefined.co.uk at any time.

Where you opt out of receiving our marketing communications or emails, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at imola@streetleveredefined.co.uk

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws and the General Data Protection Regulation (GDPR) in relation to your personal data.

These include the right to:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

You can see more about these rights on the website of the Information Commissioner’s Office (ICO).

If you wish to exercise any of the rights set out above, please email us at imola@streetlevelredefined.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. THIRD PARTY LINKS

Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website(s), we encourage you to read the privacy notice of every website you visit.

Our website(s) are hosted on Squarespace. You can read Squarespace’s privacy policy here.

For appointments we use TidyCal and Facebook’s booking tool. You can read their privacy policies here and here.

For session questionnaires and surveys we use Google Forms and Google Drive. You can read their privacy policy here and terms of service here.

For contracts we use PandaDoc. You can read their privacy policy here.

For newsletters we use Mailerlite. You can find their privacy policy here.

For online calls we use Zoom. You can view Zoom’s privacy policy here.

11. COOKIE NOTICE

What’s a “cookie”?

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system.

If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

How do we use cookies?

We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.

Cookies are either:

  • Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or

  • Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. [We use persistent cookies for Google Analytics.]

Cookies can also be categorised as follows:

  • Strictly necessary/required cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

  • Analytics and Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.

  • Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.

Cookies used on our website(s):

FUNCTIONALITY AND REQUIRED COOKIES

There cookies help you navigate and use key features on our websites.

Cookies are listed in the following format:

COOKIE NAME

  • Purpose

  • Type

  • Duration

CART

  • Shows when a visitor adds a product to their cart

  • Cookie

  • 2 weeks

CHECKOUT_WEBSITE

client_username

  • Remembers a logged in Scheduling client's username between visits

  • Cookie

  • 1 year

Commerce-checkout-state

  • Stores state of checkout while the visitor is completing their order in PayPal

  • sessionstorage

  • Session

Crumb

*CSRF is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in.

hasCart

  • Tells Squarespace that the visitor has a cart

  • Cookie

  • 2 weeks

Locked

  • Prevents the password-protected screen from displaying if a visitor enters the correct site-wide password.

  • Cookie

  • Session

PHPSESSID

  • Securely authenticates a visitor during their checkout in Scheduling.

  • Cookie

  • 1 month

RecentRedirect

  • Prevents redirect loops if a site has custom URL redirects. Redirect loops are bad for SEO.

  • Cookie

  • 30 minutes

remember_client

  • Remembers Scheduling client’s login details if they have an account.

  • Cookie

  • 365 days

siteUserCrumb

*CSRF is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in.

SiteUserInfo

SiteUserSecureAuthToken

  • Authenticates a visitor who logs into a customer account

  • Cookie

  • 3 years

squarespace-announcement-bar

  • Prevents the announcement bar from displaying if a visitor dismisses it

  • localstorage

  • Persistent

squarespace-likes

  • Shows when you've already "liked" a blog post.

  • localstorage

  • Persistent

squarespace-popup-overlay

  • Prevents the promotional pop-up from displaying if a visitor dismisses it

  • localstorage

  • Persistent

ss_cookieAllowed

  • Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies

  • Cookie

  • 30 days

ss_sd

Test

  • Investigates if the browser supports cookies and prevents errors.

  • Cookie

  • Session

TZ

  • Allows a Scheduling client’s appointments to display correctly based on their time zone preferences.

  • localstorage

  • Persistent

ANALYTICS AND PERFORMANCE COOKIES

These cookies are used to collect information about how visitors interact with our website(s).

Cookies are listed in the following format:

COOKIE NAME

  • Duration

  • Purpose

ss_cid

  • 2 years

  • Identifies unique visitors and tracks a visitor’s sessions on a site

ss_cpvisit

  • 2 years

  • Identifies unique visitors and tracks a visitor’s sessions on a site

ss_cvisit

  • 30 minutes

  • Identifies unique visitors and tracks a visitor’s sessions on a site

ss_cvr

  • 2 years

  • Identifies unique visitors and tracks a visitor’s sessions on a site

ss_cvt

  • 30 minutes

  • Identifies unique visitors and tracks a visitor’s sessions on a site

12. CHANGES TO THIS POLICY

We may update these policies from time to time to reflect changes to our website(s) and based on customer feedback. Please regularly review these policies to be informed of how we are protecting your personal data.

We welcome any queries, comments or requests you may have regarding this Privacy Policy & Cookie Notice. Please do not hesitate to contact us at the email provided at the beginning of this document.

Version: August 2021